Position paper HEAL EEB proposed EU restriction on tattoo inks

For millions of Europeans, a tattoo can be a means of self-expression. It may also, however, represent a direct source of exposure to a complex cocktail of chemicals. It is estimated that the number of tattooed people in Europe more than doubled between 2003 and 2014 (EEA 31), from about 30 to 60 million [1].

No EU-wide regulation currently exists to protect tattoo recipients from hazards found in tattoo inks. The Council of Europe (CoE) has twice passed nonbinding resolutions, most recently ResAP (2008), providing guidelines for chemical safety of tattoo inks. To date, seven Member States – France, Belgium, Germany, the Netherlands, Spain, Slovenia and Sweden – have incorporated these guidelines into national regulations. In 2017, the European Chemicals Agency (ECHA), along with Denmark, Italy and Norway, proposed two REACH restriction options for substances in tattoo inks [2]. After a public consultation period, a revised set of proposals was developed in a combined opinion issued by ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC), and published in June 2019 [3].

The Health and Environment Alliance (HEAL) and the European Environmental Bureau (EEB) support the proposal for an EU-wide restriction on tattoo inks, building on existing national legislations and based on the highest standards of protection of human health. In this brief note, we provide feedback on the revised proposal, which will now be taken up for development into a legal proposal by the Commission before being discussed for final agreement with Member States. We also highlight some important systemic problems with the restriction process…