Starting January 2022, things are changing in the European PMU market. The European Chemicals Agency – ECHA – has announced a reform of the regulations of pigment and tattoo ink production and packaging that will either ban or limit the presence of over 4000 substances and harmonize their labeling.
The concern is that the PMU pigment and tattoo ink market is not regulated strictly enough, and as a result, formulas that may be unsafe and cause adverse effects are used on clients. ECHA wants to change this and make the industry safer.
But such a huge reform has caused mixed reactions. Tattoo and PMU artists claim that some aspects of the reform will do more harm than good, arguing that the logic behind the selection of ingredients to be banned is faulty and that there is no sufficient evidence to proclaim certain substances unsafe.
Let’s take a look at the most prominent reactions.
What’s the Motivation Behind the Regulations?
The REACH Regulation will, to quote ECHA, “introduce maximum concentration limits either for individual, or groups of substances used in tattoo inks or permanent make-up. [It will] prevent a number of substances that cause cancer or genetic mutations and [those] that are toxic to reproduction as well as skin sensitizers and irritants.”
They further claim that “over 1 000 cases of chronic allergic reactions will be prevented every year as a result of the restriction.”
Obviously, making tattooing and the PMU industry as safe as possible is in everyone’s best interest, but the regulations need to be carefully thought through, and the feedback from people performing the treatments needs to be taken into account.
The financial aspect can’t be overlooked, and the negative effects of the regulations on the livelihood of artists, who make up a significant portion of the population, need to be mitigated.
To complete your understanding of the upcoming regulations, read the general overview in this article.
Image source: Unsplash
Will This Affect the US Market?
Yes.
Although the regulations will come into effect on EU and EEA soil, they will affect the global tattoo ink and PMU pigment market. Many of the biggest manufacturers whose products are imported into the US are based in EU states and their products have to comply with local regulations.
Furthermore, US brands often adjust their products to comply with EU regulations to enable export.
So don’t be surprised if you notice changes in pigments starting next year, no matter where you buy them.
What’s Problematic About the Upcoming Regulations?
The proposal prescribes introducing safer substance alternatives wherever possible. This is a good solution in the long run, and there will be a transitional period of 24 months for the manufacturers to reformulate their products.
The issue arises in the case of 2 pigments that do not have safer, high-quality alternatives at this moment: blue 15:3 and green 7.
Here’s the problem – these 2 shades are found in 70% of tattoo inks and PMU pigments in varying amounts. So not just blue and green pigments; traces of these shades are found in black, brown, red, and purple pigments, so a huge part of the palette.
Here’s another problem – PMU and tattoo artists claim that there is no substantial evidence to show that these pigments are unsafe. The decision to ban them is based on Annex II of the European Cosmetics Regulation, which bans their use in hair dyes and topical cosmetics. This regulation does not apply to the injection of these pigments, only their topical use.
Apparently, at the time of adopting the annex, the 2 pigments shades were prohibited for use in hair colorants because the toxicology dossier for their safety in hair products hadn’t been submitted, so they were banned automatically. So some criticism aimed at the regulations says that what ECHA is trying to do now is copy the already inadequate reasoning and apply it to an entirely different group of products.
Artists who support the Save the Pigments initiative claim that this logic is faulty, and that the arguments provided for banning blue 15:3 and green 7 are insufficient.
What Is the Save the Pigments Initiative?
A group of Europe-based tattoo artists has come together under the Save the Pigments Initiative, a movement that pushes for the reconsideration of the ban on blue 15:3 and green 7.
According to them, banning these 2 shades will affect almost the entire palette available for cosmetic and decorative tattoos, yet the decision to do so is not backed by sufficient evidence that they are in fact hazardous for injection.
The German Federal Institute for Risk Assessment conducted an assessment and came back with the conclusion that the 2 pigments have “a comparatively low level of toxicity,” but due to lack of data, they couldn’t give a more precise conclusion.
It’s important to understand that the Save the Pigments Initiative is not trying to keep the pigments legal at all costs, but rather to push for more research and not base the decision on speculations.
They go on to say that banning these colors from legal practices will prompt clients to seek illegal services and go to artists who use these shades despite the ban. The integrity of the entire tattooing and PMU industry will thus be compromised, with a black market emerging.
While the harmful effects of the shades are speculative, the negative effects of the ban are imminent.
Image source: Instagram @savethepigments
How Is the Initiative Fighting for Reconsideration of the Decision?
Apart from the media campaign, the Initiative has started a petition already signed by a long list of artists that will be submitted to the European Parliament in the months to come, asking for the ban on blue 15:3 and green 7 to be reconsidered.
You can read more about the Save the Pigments Initiative here, and find the petition here.
Are There Any Positive Reactions?
The regulations are largely supported by the tattoo and PMU community, except in the case of the 2 pigments in question. Artists want to keep their clients safe, but they also don’t want to sit idly by and lose a huge part of their color palette without sufficient information that would prove its harmfulness.
One aspect of regulations has been universally praised – harmonizing the labeling system and making the formulas 100% transparent.
Artists have always struggled with the lack of transparency from pigment and ink manufacturers, some of whom often don’t disclose the entire list of ingredients. This leaves artists in the dark, not knowing what they’re injecting into people’s skin.
