The idea of regulating the ink used in tattoos is obviously good. Having some kind of commonly accepted system for ensuring that inks used in tattoos do not pose any unnecessary risk to consumers is certainly to the benefit of all. Making such regulations international across the entire EU is certainly also a good idea.
But instead of doing this, the EU and the REACH legislation has done something that looks like the opposite.
As 2021 comes to a close, tattoo artists and their customers across Europe are in a very real state of uncertainty and distress. Nobody knows whether there will be any legal inks on the market when the new regulations come into force at the beginning of the 2022. Nobody knows how strictly the new regulations will be enforced. Will there be police officers waiting outside every tattoo parlour come January 4th?
And what is perhaps even worse, getting proper information on tattoo inks and REACH is incredibly difficult. Reading the relevant EU documents in itself is a daunting task – many of them are several hundred pages long and written in inaccessible prose. Finding the relevant EU documents is no picnic either. Getting information on the consequences of the new legislation after they enter into force is virtually impossible. The ink manufacturers we have interviewed all say that they are working on inks that comply with the new regulations, but that’s all they can say. At the time of publication (less than a month before the new regulations come into force), we have heard of no one who has been able to do it.
We do not think that the result speaks well of bureaucracy and legislation in the EU, nor do we think that the process leading up to the current state of affairs has been fair. Indeed, the mere fact that an entire industry feels uncertain as to whether it will be effectively banned from the start of the new year speaks to the fact that something has gone terribly wrong.
As dire as the current situation feels to anyone involved in the tattoo industry in Europe, it is nonetheless our firm belief that regulating tattoo ink is the right thing to do. We are furthermore certain that most if not all tattoo artists would agree. What tattoo artists would not embrace a system that would enable them to guarantee the highest quality of ink and the greatest level of health and safety possible to their customers? And likewise we are certain that most customers would prefer to have the inks in their tattoos tested in a professional manner. Our worldwide survey on the matter confirms this belief.
This fact of course only adds to our frustration with the entire situation. We could have had new legislation across the EU that would have set equal and fair standards for tattoo ink, and which would have made getting a tattoo much safer than before. But instead we got confusion, an entire industry in distress, and a future that potentially includes the prospect of tattoo practices turning to illegalities and hidden activities.
In this situation, questions abound and answers are few. We have done our best to get an overview of the situation in order to understand what it all means and how we got here. The results of this work can be found in the following pages.
The consequences for the tattoo industry are catastrophic; tattoo artists are being regulated out of existence.
Chief physician, Jørgen Serup, professor, Dr.Med.Sc. at the Department of Dermatology and Head of the Tattoo-clinic, Bispebjerg University Hospital, Copenhagen, Denmark
In general, it is always good for tattoo artists and their customers to know about the contents of tattoo ink. With regard to REACH, however, it is crucial.
We believe that REACH was not the ideal framework for regulating tattoo ink, as we have explained elsewhere.
The EU process of creating the new legislation was muddled and the results are likewise
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