Update Tattoo Inks

Update Tattoo Inks

15 December 2021

The January 4 deadline is now getting very close and we understand that this is causing a certain amount of nervousness for many of you, so we' re providing a small update with some tips and clarifications.

I AM INK

The I AM INK greywash line is currently the only REACH compliant ink already available. As expected, demand is greater than what we are supplied with, as a result we are working with a pre-order system. Orders are shipped in the order they are received. Usually the full delivery is needed to finish the pre-orders and thus there will not be much stock available on the website, so do not wait to order this ink. Early next week we should receive another delivery, hopefully this will allow all backorders to be shipped before our year-end closing.

Coloured and other inks

We are informed that Eternal, Intenze, World Famous and Silverback are working on the final testing phase of a (colored) REACH compliant ink. However, we have not received a deadline for this and we receive no response to our e-mails or a blunt "We are working on it". As soon as we know anything specific about the range, prices or availability, we will immediately pass this information on via our social media, website and newsletter. There is no point in emailing or calling us to ask if we know anything yet; as soon as we do, we share the information!

Misses...

Unfortunately, some manufacturers have not done their homework properly and created a new ink that still does not comply with the REACH Regulation. So always ask for an infosheet when you want to order a new brand or version. At a minimum, ask for a picture of the label with the ingredients so that you can check that the content is in line with what is still allowed and the mandatory statements are on the label.

Label requirements

It seems there is some confusion around some of the new label requirements so we are happy to list them again:

  • The label must be at least in the language of the area where the ink is used. Thus, it MUST have at least a Dutch text on it.
  • The label must literally say "Mixture for use in tattoos or permanent makeup".
  • The bottle must have a lot number on it.
  • The ingredients must be listed on the label, along with the statement "pH regulator" for the ingredients with this purpose.
  • The upper limit for Nickel and Chromium is 0.0005% and 0.00005% respectively. As soon as there is a chance of Nickel or Chromium in the ink below this value, the statement "Contains Nickel. May cause allergic reactions." or "Contains hexavalent chromium (VI). May cause allergic reactions." must appear on the label. These upper limits are similar to what was already applicable to inks, this does not mean that this ink contains Nickel and the old one did not, it simply did not have to be mentioned before.

What about my old ink?

The regulation says that inks that do not meet the conditions are not allowed to be used for tattooing. This does not mean that you can no longer have these inks in your possession! We have presented this to Astrea Lawyers and this is their answer:

The Regulation prohibits the marketing and use of the substances (listed in Annex XVII of the Regulation) in mixtures for "tattooing purposes". This includes: 

"the injection or introduction of the mixture into a person's skin, mucous membranes, or eyeball by a process or procedure (including procedures commonly referred to as "permanent makeup," cosmetic tattooing, "micro-blading," and "micro-pigmentation") for the purpose of leaving a permanent mark(s) or drawing on that person's body." 

Based on this, it can be concluded that using the ink for other purposes, such as applying it to a silicone practice skin during training, is allowed.

Specifically, this means that your old ink may still be present in the shop, but make sure it is very clear that it is no longer used to tattoo customers. Keep the old ink separate from the workshop and label it clearly as "Practice ink - not for tattoo".