EU Pigment & Ink regulations are changing from January 2022
by Yasmin AshrafOctober 05, 20215 min read
Latest pigment, ink requirements and how you are already affected.
Permanent make up & tattoo industry pigments are under scrutiny and there’s a huge revamp happening in order to get all of the current pigments compliant. No matter who is your pigment manufacturer, brand you trust, country of origin, pigment colours and tones you use - everyone is affected as a list of 4000 hazardous substances are banned or restricted. Don’t be quick to think this is something you do not need to worry about, don’t be complacent. Ignoring these could mean your insurance is voided in case of a claim, your salon may be fined and most importantly, you’re not making the most ethical & safe decision for your clients.
In this blog I would like to address some of the questions you may have as an artist and help understand how these changes affect you, your salon and your clients.
Why are pigments and inks changing, does it mean previous formulations were not safe?
All industries are always striving for better and safer products and this is an ongoing process. With long term studies and research done on certain ingredients, technologies and techniques; we learn about their effects. Saying that, some pigment manufacturers and lines (such as Everlasting Brows) are extremely forward thinking and produce pigments in accordance with the latest findings long before they are made a compulsory requirement (but you’ll also be surprised how many big brands don’t!). It is a long process from the moment when we learn about potentially hazardous ingredients, until these are actually banned or restricted. It is not uncommon for some manufactures not to even be aware of impurities in the raw ingredients they purchase that may have negative health implications. You’ll find that reputable beauty suppliers who care about their clients health and formulations, will be compliant well before regulations come into force, but this is a small minority, for many brands, this might be the end of the road as compliant raw ingredients are expensive or difficult to find.
What kind of hazards are posed by ingredients being banned or restricted?
It is long known, that the effects of pigments and inks can be seen way past the area they are tattooed in. Although visually it seems that pigment stays put in one area, effects not seen by the naked eye can extend to the whole body. Besides the obvious possible consequences of skin reactions and chronic allergies, there are other, more serious carcinogenic or mutagenic issues that may arise. Additionally, As the pigment breaks down, studies have shown that nano particles of pigments becomes trapped in lymph nodes, these particles then prevent the lymphatic system to effectively remove toxins and eventually present a whole new array of health related issues, including but not limiting to cancer and immune deficiencies, ones that you may never connect to your favourite tattoo or even brows on fleek.
When are the new regulations coming into power?
In 2015 a request was put forward by the EU commission to EU chemicals agency to asses the risks of certain chemicals used in mixtures for tattooing and permanent make up purposes, only today we are seeing the effects of this request. Officially the changes have already been effective from the 4th of January 2021, however, manufacturers, brands, resellers and artists have until 4th of January 2022 to make the switch.
Besides pigment formulations, the labels are also required to change, why?
Currently the labelling requirements have not been the same throughout the EU for permanent make-up and tattooing industries. Therefore for the ease of monitoring and enforcement by authorities; all labelling requirements are being harmonised across the European Union. Text needs to meet minimum sizing, certain information must be present and full list of ingredients must be issued with every purchase. This means that you are likely to see the label designs change of your favourite pigments and also additional information provided either on a leaflet or through a QR code.
What do artists need to do in order to be compliant?
All artists are expected to ensure pigments/inks used in their salon meet the requirements that are becoming a law. If your chosen pigment line is produced in the EU by a reputable company, it is likely that they will meet all the necessary requirements, but if your pigment line is produced outside of the EU, there is a chance that these will not be met even by reputable companies, therefore artists have to work extra hard to be aware of what is needed in order to protect their business, reputation and health of their clients.
Because simple is our second name, we have summarised what the annex states artists need to do to comply:
1. Ensure the pigment brandyou use is compliant, look for information on their website or ask them, don’t assume. 2. Look out for this statement present on the label: ‘Mixture for use in tattoos or permanent make-up’ (this is one way of ensuring your pigments are compliant). This statement must be provided in the language of your country. 3. Hand out leaflets to your clients with pigment information of ingredients that were used during the procedure (the requirements state: “the tattooist should provide information marked on the packaging, or included in the instructions for use, to the person undergoing the procedure.”) 4. If you’re stocking up on pigments before 4th of January 2022, ensure they are already compliant, otherwise it may been you will not be able to use them after the 4th of January 2022.
Is this really necessary?
At first all changes are often met with scepticism, but knowing the potential effects of the ingredients on the list is necessary for the safety and evolution of our industry. The reality is such that PMU's & Tattoo’s can cause health issues, but they would never even be considered as suspects.
If you are an Everlasting pigment client (thank you so much!), you’ll be glad to know that our pigments meet and exceed all ingredient requirements and you do not need to worry about your favourite colours being impossible to recognise. Saying that, we had some work to do on our labels to ensure they are harmonised in-line with the EU regulations and you might already be seeing these in circulation. If you see the below label style on your bottle, know that your pigment is compliant already. Also expect a bright turquoise label applied in the language of your EU country.
We applaud this movement by the EU and we expect to see similar changes coming into force across the world. Now let’s get back to creating our favourite PMU.