Letter regarding Legal uncertainties of the current REACH Restriction on tattoo ink and permanent make-up
Dear Ms Emily O’Reilly,
We, the European Society of Tattoo and Pigment Research, were funded in 2013 with the aim to advance
safety of the tattooing practice and ink ingredients. We promote research in this field to understand the
relation of ink ingredients and side effects of tattoos. Our board comprises dermatologists, researchers
specialized in toxicology, chemistry and other related field that add up to decades of knowledge on tattoo side effects and ingredients.
Soon, the amendment of Annex XVII to Regulation (EC) No 1907/2006 (REACH regulation) that include
substances in tattoo inks or permanent make-up will enter into force. We intensively commented on the initial draft in the public consultation phases and reached out to members of ECHA and the European Commission afterwards, but main issues that are pointed out in the following were not or insufficiently addressed: