REACH vs. NOT REACH: What You Should Know About Tattoo Pigments

REACH vs. NOT REACH: What You Should Know About Tattoo Pigments

Since January 2022, the tattoo industry in Europe has undergone a significant change: the entry into force of the REACH Regulation. This regulation now applies specifically to pigments used in tattoos and permanent makeup, imposing new rules on the formulation, sale, and use of these products.

In this article, we explain what it means for a pigment to be REACH compliant, what distinguishes NOT REACH pigments, and what the associated risks, responsibilities, and legal implications are.

 



What characterizes REACH pigments


REACH pigments are those that comply with the requirements of Regulation (EC) No. 1907/2006 — known as REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals).

Since January 4, 2022, this regulation has included specific standards for tattoo pigments and permanent makeup pigments (PMU). The main objective is to protect the health of consumers and professionals by prohibiting or limiting potentially dangerous chemicals.

A REACH-compliant pigment:

  • Does not contain substances prohibited or highly restricted by the EU;
  • Has undergone chemical safety testing;
  • Has formulations considered safe for subcutaneous application;
  • Is legally authorized for use on human skin in the European Union;
  • Provides greater confidence to the tattoo artist and safety to the customer.



 

What distinguishes NOT REACH pigments


NOT REACH pigments are all products that do not meet the criteria required by European regulations. This can occur for several reasons:

  • They contain ingredients that are not approved by ECHA (European Chemicals Agency);
  • They include substances in concentrations higher than permitted;
  • The brand has not yet submitted the product for the required assessment;
  • The product was formulated outside the EU and has not been adapted to the new standards.

Although they have been used frequently in the past, many of these pigments are no longer legal for use on human skin within the European Union.





The sale and use of NOT REACH pigments


It is important to clarify that the sale of NOT REACH pigments is not illegal, provided that it is clearly identified that they are not for use on human skin.

These pigments are often used for:

  • Training on synthetic skins or pigskin;
  • Artistic painting on canvas, wood, or paper;
  • Technical demonstrations;
  • Creation of visual content (video, photography, etc.).

However, if they are used in human tattoos, the responsibility lies entirely with the artist. Such use may result in legal sanctions, especially if identified by health inspection authorities.




Where does the REACH Regulation apply?


REACH is a European Union regulation that applies to all Member States. This means that:

  • Only REACH-compliant pigments can be legally used for tattoos within the EU;
  • Inspections may take place in studios, online stores, or customs offices;
  • Countries outside the EU, such as the United Kingdom or Switzerland, are not required to comply with REACH, although they may have their own legislation.

Therefore, it is legal to purchase NOT REACH pigments in the EU and use them outside the European Union, for example, in sessions as a guest artist in countries where regulations are different.




Industry transition and the impact of REACH


REACH has introduced a significant change for brands, distributors, and tattoo artists. Reformulating a pigment requires time, laboratory testing, registration, and approval, which explains why some pigments have not yet been adapted.

This transition is ongoing, and many renowned brands have already launched lines certified as “REACH Compliant” or “EU Approved.” Still, there is an adaptation period in which compliant and non-compliant products coexist—it is up to the professional to verify this information.

 



How to identify a REACH-compliant pigment


Knowing whether a pigment complies with REACH regulations is essential for any tattoo artist operating in Europe. Here's what you should look for:

  • Information visible on the packaging (label, mention “REACH compliant” or “EU certified”);
  • Reference in the product data sheet;
  • Availability of the Safety Data Sheet (SDS), which lists the chemical substances present;
  • Declaration by the manufacturer or distributor with explicit mention of compliance with REACH.

If the brand or store does not provide this information, it's a warning sign




Risks and consequences of the misuse of pigments NOT REACH


Using a NOT REACH pigment on human skin is illegal within the European Union and poses several risks:

  • Health risk: allergic reaction, inflammation, toxicity, reproductive problems, and even cancer, depending on the substances present;
  • Legal risk: inspection by health authorities may result in fines, lawsuits, and suspension of activity;
  • Reputation risk: if adverse reactions occur, customer confidence and the artist's reputation may be seriously damaged.

The artist is responsible for any misuse. Neither the brand nor the retailer can be held legally responsible if the information is clear.





Why are NOT REACH pigments still being sold


Despite legal restrictions on tattoos, these pigments continue to be sold legally because they are still useful for other purposes. Their sale is legal provided that:

  • They are not labeled for use on human skin;
  • They are not advertised as safe for tattooing;
  • The retailer makes clear their NOT REACH status.

These pigments are intended for artists who work on canvas, for education or training purposes, and for those operating outside the European Union.





Substances prohibited or restricted by REACH


REACH defines a strict list of restricted or prohibited substances. In tattoo pigments, the following stand out:

Heavy metals: lead, cadmium, mercury, arsenic, hexavalent chromium.
Carcinogens: compounds with carcinogenic potential.
Mutagens: substances that can damage DNA.
Reproductive toxins: affect fertility or embryonic development.
Sensitizers and allergens: cause inflammatory reactions in the skin.

These compounds are associated with serious effects, and their elimination aims to ensure safer practices in the art of tattooing.




An ethical issue


REACH represents an important step towards professionalization and safety in the tattoo industry. It is up to each artist to stay informed and ensure that the products used are safe, certified, and compliant with European legislation.

If you operate in the European Union, use only REACH-compliant pigments. If you work in other markets or in an artistic context, non-REACH pigments may be useful—but they must be used conscientiously and responsibly.

For detailed information, the official source is the European Chemicals Agency (ECHA). On the website https://echa.europa.eu, you will find documents, lists of substances, regulations, and FAQs dedicated to the tattoo industry.



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