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What should have been done instead?

What should have been done instead?

We believe that REACH was not the ideal framework for regulating tattoo ink, as we have explained elsewhere. That of course poses the question of how the regulation should have been put together in our view.

We do not see ourselves as capable of spelling EU legislation out in detail, but what we can do is to present an idea in the abstract of the kind of framework we would have proposed for regulating tattoo ink.

Our proposal includes three different and crucial elements:

  1. A part of the regulation should take the form we know from REACH. It should in other words present a list of substances that in all cases are unwanted in tattoo ink. heavy metals, known carcinogens and allergenes. Preferably this list should be less restrictive than REACH, and crucial substances for which there are no alternatives should at the very least be tested for their hazardous nature, before being put on the list of banned chemicals and substances (case in point Pigments Blue 15 and Green 7).
  2. Another important part of the legislation should take the form of a regulation of the production procedures manufacturers must follow in order for their inks to be allowed on the EU market.
  3. A final and equally important part of the legislation should take the form of a uniform and easily accessible feedback system that would enable the market to report back when certain inks are causing problems.

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