Tattoo inks and REACH: what the European rule bans and what tests show

• Fact: Regulation (EU) 2020/2081, in force since 4 January 2022, added a restriction on substances in tattoo and permanent make-up inks (entry 75 of Annex XVII of REACH).
• Fact: two recent studies on inks on the market found samples above European limits for some metals and other substances.
• Context: these studies measure composition, not absorption or health effects; the authors themselves say so.
• Uncertainty: samples are few and do not represent the whole market; enforcement may vary between countries.

REACH is the European regulation on chemical substances. The tattoo restriction, introduced by Regulation (EU) 2020/2081, limits the placing on the market and use of mixtures intended for tattooing that contain certain substances. According to regulatory summaries more than 4,000 substances are covered: among them those classified as carcinogenic, mutagenic or toxic for reproduction, skin sensitising, corrosive or irritant to the skin, eye irritants or causing eye damage, each with a concentration limit.

Two widely used pigments, Pigment Blue 15:3 and Pigment Green 7, benefited from a derogation until 4 January 2023.

The declared aim is not to ban tattooing, but to make colours safer. For concentration limits and labelling obligations the reference is the text of the regulation.

The first study also estimated risks with a dermal exposure model and concludes that a substantial share of inks is non-compliant and may pose risks; the second, in the authors' own words, is to be read as "a signal for closer scrutiny, rather than a verdict on the safety of tattooing itself".

• Content and absorption are not the same thing. That an ink contains a substance above the limit does not say how much the body absorbs. Recent research is beginning to study the bioaccessibility of metals in inks, but it is a developing field.
• Few samples. Fifteen or forty-one inks do not represent thousands of products. They show that the problem exists, not how widespread it is.
• The regulatory context matters. A study on Australia compares with European limits that are not binding there; it does not describe the European market.
• The test method. Different laboratories and techniques can give different values, and the limits concern specific substances and concentrations.
• Compliance and safety. A product compliant with the rule respects the limits set; it is not an absolute guarantee, and a non-compliant product is not harmful in every condition.

Practical pointers, not legal advice:

• Supplier documentation. Ask for the declaration of compliance with the regulation and information on the composition of the batch.
• Label. Check that the data required by the rule are present and legible, including the batch.
• Safety alerts. Consult recalls and notices from the authorities, including the European Safety Gate alert system.
• The rules of one's own country. Enforcement and checks may vary: for legal obligations the text of the rule and the competent authority prevail.

On Odisage, an ink's REACH compliance is reported as declared by the manufacturer and is not verified by us.

For those who tattoo, inks are a product on which clients, reputation and responsibility depend. Three reasons to follow the topic:

• Compliance is not a commercial detail. Since January 2022 the European rule sets concrete limits: knowing them helps in asking suppliers questions.
• Independent tests are increasing. Studies on real inks, even with limited samples, enter public debate and generate client questions.
• The difference between signal and verdict. A headline such as "all inks fail" is not the same as "all inks are dangerous". Being able to explain it is part of the trade.

Sources consulted (information gathered on 2 October 2026)

• Regulation (EU) 2020/2081: text on EUR-Lex.
• Toxics, 2025: Heavy Metal Content in Tattoo and Permanent Makeup Inks and European Standards.
• UNSW Sydney, January 2026: Toxic metals and carcinogens found in Australian tattoo inks.
• Research on metal bioaccessibility: Beyond Total Content (Analytical Science Advances, 2026).