REACH regulations

4.1.22 The REACH regulation, which will enter into force, tightens the legislation in the field of tattoos.

The regulation has been prepared since 2017 and aims to guarantee a safer tattoo experience for the client. Changes caused by the regulation:

1. Restrictions on the use of substances in tattoo inks
2. Labeling requirements for tattoo inks
3. Customer form or tattoo contract with the client
4. Giving written care instructions to the client
5. Preparation of self-monitoring plan and safety document

Restrictions on the use of substances in tattoo inks

The use of thousands of harmful substances in tattoo and permanent pigmentation inks will be restricted in the EU, so that products that exceed the limits will not be sold or used for tattoo purposes from 4.1.2022. TUKES does not pre-test or inspect products, so there is no listing of compliant inks. The responsibility lies with the manufacturers, importers and operators, i.e. the tattooists. The tattoo artist can verify the legality of the ink by asking the manufacturer, importer or TUKES for chemical advice.

As few inks under REACH have yet become available, this means in practice that tattoo artists will have to renew their entire color inventory by 4.1.2022. The old inventory must no longer be used.

Labeling requirements for tattoo inks

In the future, each ink bottle must be labeled in Finnish and Swedish to identify any allergens. Tattoo inks must also bear the words: "Mixture used in tattoos or permanent pigments." Unless otherwise stated, the product must not be used for tattoo purposes.

The importer is always responsible for the labeling of tattoo inks. If the tattoo artist orders inks from abroad, he or she must ensure that the products comply with the Reach Regulation and print the packaging labels in Finnish on them.

The inks must also bear the following information:

• Batch number
• List of ingredients
• Additional statement “PH adjuster” For PH adjusters with concentrations below 0.1%
• Safety instructions for use
• Indication:  “Contains nickel. May produce an allergic reaction” if the nickel content is less than 0.0005%
• Indication:  “Contains chromium IV. May cause allergic reactions” if chromium IV is less than 0.00005%

Client form/Tattoo contract and care instructions

The tattoo artist must provide the client with the information marked on the packaging and in the instructions for use before using the ink so that the customer can identify substances that may cause them hypersensitivity reactions, for example from the list of ingredients.

Before commissioning a tattoo, the client must also be provided with other information relevant to safety about the tattoo service in a clear and comprehensible manner. In practice, this makes the most sense with a client form or tattoo contract that the client fills out and signs.

According to the regulation, the customer form must state at least the following:

• The customer understands the permanence
• The client understands how difficult and expensive tattoo removal can be
• Tattoo aftercare instructions
• What long-term effects the tattoo may have.

In addition, we recommend to ensure that the client is of legal age, is not pregnant or breastfeeding, and that the client's medical condition is suitable for getting the tattoo.

The service provider, i.e. the tattoo artist, is responsible for the safety of the service, and the signed disclaimer does not release the service provider from the safety responsibility. The customer does not participate in the service at his / her own risk. (Consumer Safety Act 920/2011).

In the future, the customer must be given written aftercare instructions, which also include instructions for possible allergic reactions, infections and other health problems.