TATTOO REACH 2022

TATTOO REACH 2022

On January 04, 2022, the time has come. The new REACH regulation for tattoo inks will come into force in Europe and the European Economic Area (EEA). It is thus currently the strictest chemicals legislation in the world.

What is the REACH Regulation?

The REACH Regulation, or more precisely Regulation (EC) No. 1907/2006 (Registration, Evaluation, Authorization and Restriction of Chemicals) came honestly already into force and is valid since June 2007. For tattoo inks valid from January, 4th 2022. 

It fundamentally harmonizes and simplifies the existing chemicals legislation and replaces various decrees, such as the EU Nickel Directive. It replaces the non-binding Resolution ResAP(2008)1 and refers, among other things, to the Cosmetics Regulation (EC) No. 1223/2009 and the CLP Regulation (EC) No. 1272/2008 (Classification, Labelling and Packaging).

As a result, the former patchwork of regulations with varying degrees of strictness will be standardized and bindingly regulated throughout the European Economic Area (EEA).

NO DATA, NO MARKET

The REACH is based on the principle of “NO DATA, NO MARKET” and the principle of industry’s own responsibility. Thus, only chemical substances that have been registered in advance may be placed on the market. Every EU manufacturer or
-importer must have his own registration number for these substances. In the further supply chain thus also the tattoo ink manufacturers and tattoo supplies.

The restriction concerns a variety of substances with different properties (from possible carcinogenic to skin irritant) and introduces concentration limits for individual substances or groups of substances that may be used as a maximum in tattoo inks or permanent make-up. Examples include: Azo dyes, aromatic amines, polycyclic aromatic hydrocarbons (PAH), metals and methanol.

Classification, Labelling and Packaging

Labels on color bottles and packaging of tattoo inks and permanent make-up must also be adapted to the new REACH Regulation down to the smallest detail and contain a list of ingredients and relevant safety information.

Exempted by an extended transition period within the REACH Regulation, the pigment Blue 15 and the pigment Green 7 remain usable until January 4, 2023.

What is the REACH Regulation?

The REACH Regulation, or more precisely Regulation (EC) No. 1907/2006 (Registration, Evaluation, Authorization and Restriction of Chemicals) came honestly already into force and is valid since June 2007. For tattoo inks valid from January, 4th 2022. 

It fundamentally harmonizes and simplifies the existing chemicals legislation and replaces various decrees, such as the EU Nickel Directive. It replaces the non-binding Resolution ResAP(2008)1 and refers, among other things, to the Cosmetics Regulation (EC) No. 1223/2009 and the CLP Regulation (EC) No. 1272/2008 (Classification, Labelling and Packaging).

As a result, the former patchwork of regulations with varying degrees of strictness will be standardized and bindingly regulated throughout the European Economic Area (EEA).

NO DATA, NO MARKET

The REACH is based on the principle of “NO DATA, NO MARKET” and the principle of industry’s own responsibility. Thus, only chemical substances that have been registered in advance may be placed on the market. Every EU manufacturer or
-importer must have his own registration number for these substances. In the further supply chain thus also the tattoo ink manufacturers and tattoo supplies.

The restriction concerns a variety of substances with different properties (from possible carcinogenic to skin irritant) and introduces concentration limits for individual substances or groups of substances that may be used as a maximum in tattoo inks or permanent make-up. Examples include: Azo dyes, aromatic amines, polycyclic aromatic hydrocarbons (PAH), metals and methanol.

Classification, Labelling and Packaging

Labels on color bottles and packaging of tattoo inks and permanent make-up must also be adapted to the new REACH Regulation down to the smallest detail and contain a list of ingredients and relevant safety information.

Exempted by an extended transition period within the REACH Regulation, the pigment Blue 15 and the pigment Green 7 remain usable until January 4, 2023.

Here you'll find an interesting Q&A to the REACH Regulation

From January, 4th 2022, all tattoo inks commonly used to date, including those approved under the Tattooing Products Regulation ResAP 2008_1, will no longer be REACH-compliant and will therefore be banned. They may therefore no longer be used for tattooing within Europe.

The international tattoo ink manufacturers have been working feverishly for months on their new product mixtures and are having their REACH conformity tested by institutes. After successful REACH registration, they will begin shipping to tattoo supplies, where they will then be available for tattoo artists to purchase.

We are in direct and indirect contact with tattoo ink manufacturers through the European Tattoo Artists Associations and various tattoo supplies.

According to their own individual announcements, the tattoo ink manufacturers will successively bring their REACH-compliant ink ranges onto the market in the first quarter of 2022. Unfortunately, we can’t find adequate offers of the supplies for tattoo inks except some black and white so far.

So far, we can only say that new and already REACH-compliant black and white tattoo inks that we have already seen make a really good impression. However, it also depends on the respective manufacturer and a lot will have to be tried out in the coming months.

Replacement pigments or substitutes exist for all pigments. Except for pigment blue 15 and pigment green 7, why these have also received the extended transition period in the REACH Regulation.

The new product lines and color palettes already announced by some tattoo ink manufacturers will be quite meager in scope and take some getting used to at first. They’ll have to be tried out.

Tattoo inks that were purchased in 2021 and are not REACH-compliant may no longer be used for tattooing within the EU and the European Economic Area.

We have discussed the issue several times. In our opinion and so far it is EU country dependent, which regulation also prevails in relation to the storage of old stocks of tattoo inks.

If an authority should ever visit your studio and find such residual stocks, you would possibly be in need of explanation.

Our tip: Non-REACH-compliant tattoo inks better dispose of properly or ask the tattoo supply until 04 January 2022!

For this you should please contact your tattoo supplies and tattoo ink manufacturers. A uniform European solution is not provided for this, as far as we know.

This is a very good question, which we now get asked every day and why we, among others, together with Save the Pigments and many European tattoo associations fight with the EU petition 1072/2020 against the REACH Regulation and plead for an extension of the transition period.

We can only ask for patience here and refer to Black & Grey Tattoos until further notice. Until then, it is also not yet clear which European countries will first be equipped with REACH-compliant tattoo inks.

If you find or are offered allegedly REACH-compliant tattoo inks on the Internet, then be sure to obtain the corresponding safety certificate in advance. The tattoo ink manufacturers and the tattoo supplies will gladly make this available to you.

Since there have been cases for several weeks, where a seller of allegedly REACH-compliant tattoo inks has apparently tinkered with certificates and “REACH-compliant” seals themselves, please be vigilant and ask in case of doubt directly to the testing laboratories. They will be happy to give you information.

Editor’s hint:

The ingredients or substance mixtures of colorful tattoo inks that are REACH-compliant are very different from the previous tattoo inks. And since the quality and behavior of a tattoo ink is particularly apparent only after complete healing, we recommend collecting enough long-term experience with the new colors before tattooing large motifs such as backpieces or entire sleeves.