Wtf is REACH?

Wtf is REACH? EU Tattoo Ban Blue Green Tattoo Panel Copyright 2021

REACH stands for Registration, Evaluation, Authorisation and Restriction of CHemicals.

It is a regulation of the European Union. Basically, it should be attractive in the sense of every European citizen or even beyond European borders, because it’s about the health and welfare of everyone. No matter if human, animal or plant.

The idea of this regulation is to improve the protection of human health and the environment from risks, that can be caused by chemicals. And at the same time to increase the competitiveness of the chemical industry in Europe.

In doing so, the REACH regulation targets our entire lives and all chemical substances found therein. No matter whether it is clothing, furniture, electrical appliances or cleaning, hygiene or cosmetic products. REACH wants companies, that manufacture or sell their products in Europe, to identify the risks to them. And – above all – to know and control them. The same must now be proven by the ECHA (European Chemicals Agency) and risk management measures must be provided for the user and consumer.

Wait a minute – who is this ECHA again?

The European CHemical Agency is an EU agency that implements legislation on chemicals to protect health and the environment. In other words, it bans chemical substances or, in cases of increased risk, calls on industry to develop safer alternatives.

How does it do this? Among other things, by means of the REACH regulation.

The REACH Regulation sets out procedures for collecting and evaluating information on the properties and hazards of substances.

European companies or companies that place their products on the market in Europe must register the substances they use.

ECHA evaluates individual registrations for compliance with REACH requirements. While individual EU member states also re-evaluate selected substances themselves to address initial concerns for human health or the environment.

ECHA’s authorities and scientific committees also assess whether the risks of substances can be managed.

In Germany, for example, about 3.000 companies with about 12.000 substances and about 28.000 related registrations have submitted to REACH since 2008.

Unfortunately, the statistics do not show how many substances or even companies have fallen victim to REACH so far.

In any case, the authorities can ban allegedly hazardous substances, restrict their use or make them subject to prior approval, if their risks cannot be proven to be under control. The burden of proof – as mentioned – lies with the companies. This sometimes costs vast sums of money, which is why many smaller companies cannot afford to develop alternative substances and therefore have to close down. 

Who are the scientific committees that perform risk assessment for ECHA?

Since ECHA itself is not authorized to conduct its own studies on substances, a Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) prepares opinions on risks of substances to human health and the environment. The members of the committee come from various European member states. They are elected for a renewable term of three years.

What does all this mean for the European tattoo industry?

In advance so much – nothing good!

In the wake of the cosmetics industry, the massive demand for tattoos has been drawn into the focus of the regulatory authorities. Doing so, ECHA points to its assumption, that around 12% of people (aged 18-35) in Europe have one or more tattoos in their skin.

That is, 27 EU member states with an estimated 447,7 million inhabitants, of which about 54,0 million are tattooed (whole Europe, 746.000.000 inhabitants, 89.5 million tattooed – source: statista.com).

Our mistake – sorry! We simply put ECHA’s 12% in the 18-35 age group of tattooed people in proportion to the total European population. In only 8 EU-countries we have selected right now, like Italy, France, Spain, Germany, ff., we recognize according to the data of statista.com already 140.000.000 tattooed people (source: Proportion of tattooed people in different countries worldwide in 2018/ statista.com).

That’s not a small number (either)! And since ECHA has made it, its mission to make our lives healthier, they turned their attention to tattoo inks well over a decade ago, after investigating health risks associated with the use of tattoo tools.  

The result means, that thousands of chemicals classified as hazardous and found in tattoo inks and permanent makeup will be subject to EU restriction under the REACH regulation from January 2022.

This doesn’t mean banning tattoos! But rather banning chemicals, that ECHA and its risk assessment committees believe should be removed from tattooing products to make tattoos safer.

This is triggered by statistics on more than 1.000 cases of chronic allergic reactions and various other skin reactions and serious effects due to tattoos and permanent makeup every year. So writes the ECHA on her website.

But what does that mean now? Do we have to put 1.001 tattoo-allergies in proportion with 54.000.0000 tattooed people? To justify the urgency of an ingredient ban? And above all at the expense of many thousands of employees in the tattoo and cosmetics industry?

“What are the concerns?”

On its website, ECHA asks itself this question (quote):

“Tattoo inks and permanent makeup are mixtures of several chemicals. They may contain hazardous substances, that cause skin allergies and other more serious health effects, such as genetic mutations and cancer.

In addition, color pigments can travel through the skin to various organs such as lymph nodes and the liver. Sometimes tattoos are removed using a laser, which breaks down pigments and other substances into smaller particles. If these are harmful chemicals, they are released by the removal and then circulate in the body.

Because chemicals used in tattoo inks and permanent makeup can remain in the body for a lifetime. There is also the possibility of long-term exposure to potentially harmful ingredients.”

(Note: “consider”: to think about, to consider carefully, to ponder, to think through).

If you want to go deeper into the topic around the EU ban of tattoo inks, we strongly recommend to visit the websites of:

“Save the Pigments”

and also again the website of

“Tattoofarben retten”

to take care of.

What’s happening right now, is not good!!!

This makes among other things also a newsletter published on September 15, 2021 by some tattoo supplies in Germany very clear. Perhaps you have also already read it.

Enclosed also at the Tattoo Panel again as a quote:

Important information for all tattoo artists and tattoo parlour owners

As you all have probably already noticed, we are currently in the transitional period of the Commission Regulation (EU) 2020/2021, also called: Tattoo-REACH, which will come into effect on January 4th, 2022.

This new law regulates tattoo inks throughout the European Union and is intended to create an EU-wide uniform standard. It also limits the use of certain ingredients, among other things including some pigments and preservatives that were previously allowed for use in production of tattoo inks.

In the future, some of these pigments may only be allowed in very small amounts in tattoo inks. Maximum limit values in the range 0.02% and below therefore practically prohibit the use of these substances. Prominent examples of this are blue 15 and green 7. Many ambitious petitions have been started in order to sustain tattoo colors, which, by the way, are still running. For the pigments blue 15 and green 7, however, there is a transition period until 2023.

(At this point we want to call on everyone again to support the petition “Save the Pigments”. For more information just click here!)

However, other pigments and preservatives are affected by this reagulation as well, some of which are found in the tattoo ink brands we sell. For various reasons, the manufacturers of these brands have not yet succeeded in replacing the regulated ingredients with other ingredients and achieving a guaranteed and consistent quality of the affected color shades. After several discussions on the current situation, we have to inform you that a large part of the currently offered tattoo inks in our range may no longer be sold, bought, used and stored from January 4th, 2022.

Unfortunately, we have not received sufficient information from our suppliers as to when alternatives can be expected. Shortly all colors that are still stored and offered by us in our online shop will be provided with a notewill be marked for your convenience and overview.

We understand the uncertainty that has existed on your side since the beginning of the year with the publication of the REACH and still persists to this day.

We have been trying to utilise our reach and influence for years and will continue to try and find a timely solution together with the manufacturers of tattoo inks and all stakeholders for this industry-wide problem.

If you have any current questions on this topic, please send an email to @yourtattoosupply. We will of course try as best we can to help you. As soon as there is news on this topic, you will be informed immediately.

We will get through this probably rather colorless time together! We hope that we will all soon be able to enjoy the full color spectrum of all tattoo colors again.”

Conclusion:

To make it clear again – the European Tattoo Panel is not political itself!!! We are a network for communication with and among each other. But of course, we have a stance and will support the tattoo industry with all our strength.

What’s being done or accomplished at the EU level and in the course of consumer protection, is certainly good. Or at least not bad in the broader sense.

The fact, that several industries are being brought to their knees by regulatory authorities due to assumptions and concerns about health product safety, is debatable in that estimated limits on ingredients of tattoo inks and permanent makeup, currently seem unattainable.

To make it clear again from our point of view. With an estimated 540 million tattoo wearers worldwide, we are honestly missing the “death by tattoo”. Sounds nasty – but would certainly make it easier for us in the field of research around tattoo health. By the way, of course, also for the ECHA when it comes to consumer health protection.

What the EU authorities seem to have unfortunately not understood until today is, that an estimated 7.000 years old tradition and customer demand cannot simply be impressed by an official ban. Customers are like water and always find their own way. So the consumer protection is not really helped by the pigment ban and the tattoo industry certainly not. 

What can you do together for the European tattoo industry? 

Support the petition of the European Parliament to preserve the two pigments Blue 15:3 and Green 7 !!!

54.000 votes (increased to 107.715 supporters 10/2021) have already made a good impression on the EU Petitions Committee and the EU Commission due to their uniqueness so far. But that is not enough!

If you have already cast your vote yourself, then talk to your customers about it. After all, they are the ones who will be restricted in their colorful tattoo design in the future.

Further Sources:

Council of Europe, Committee of Ministers: Resolution ResAP(2008)1 on requirements and criteria for the safety of tattoos and permanent make-up (supersedin) Resolution ResAP(2003)2 on tattoos and permanent make-up).

Cosmetics Regulation:

Official Journal of the European Union: REGULATION (EC) No 1223/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, of 30 November 2009, on cosmetic products

Tattoo-REACH:

PUBLIC CONSULTATION: ECHA proposes a restriction on substances in tattoo inks

Official Journal of the European Union: COMMISSION REGULATION (EU) 2020/2081 of 14 December 2020 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards substances in tattoo inks or permanent make-up.

ECHA Hot Topics – Tattoo Inks and Permanent Make-up

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Responses

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  1. The non-quoted text part is quite poorly written tbh. You make mistakes in calculations and then try to put next to each other cases per year and the overall estimated count of tattoo wearers. Noted this is an opinion piece, but you’re not helping the cause by not understanding statistics.

    1. Dear Trent, thank you very much first of all for taking the trouble and reading our blog post. Also great, that you used a throwaway-email (from sharklasers) to write your important comment below.

      If you were familiar with research and statistics, you would know, that there are currently no acceptable figures on how many tattoos are stung per year in Europe.

      But you are absolutely right, that the number of 1000 (quotation: ECHA) allergic reactions caused by tattoos and PMU per year should not be put in relation to the total number of tattooed people.

      NOT? BUT YES, OF COURSE! Because it’s not related to fresh tattoos at all. Allergy can occur even after decades of wearing a tattoo.

      However, it’s much more important to make clear, that the number of tattoo wearers in Europe is much higher, than assumed and published by ECHA.

      Furthermore, where did ECHA get the number 1000? Diced? Guessed? The IVDK in Göttingen (Germany) is confronted with increased numbers of intolerance tattoo reactions. Maybe you should ask them…
      But btw., this article is an info piece about ECHA and REACH – not allergic reaction.

      Many thanks anyway for your attention.
      Best regards, Thomas – statistic-greenhorn from Tattoo Panel

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