Field Notes · · 2 min

Why our Pigment system is closed until 2027: MoCRA, REACH and the label

What it takes to put a name on a bottle of tattoo ink in the United States and in Europe, why we will not do it before we can carry it, and what a studio should ask its ink brand today.

Ink is the biggest search term in this category and the one material we list without selling. The Pigment system is closed until 2027, and this note is the reason, written out, so it reads as a decision and not an excuse.

What the name on the label means

In the United States, tattoo inks are regulated as cosmetics, and the Modernization of Cosmetics Regulation Act, MoCRA, changed what that means. The name on the label is the responsible person: the one who registers the facility, lists the product, holds the safety substantiation and reports adverse events. Put your name on a bottle and you have taken on the whole chain, whether or not you made what is inside.

In the European Union, the REACH restriction on substances in tattoo inks and permanent make-up has applied since January 2022, with two widely used pigments, Blue 15:3 and Green 7, restricted from January 2023. An ink sold in the EU has to be formulated within those limits and labelled accordingly, and the person placing it on the market answers for it.

To sell ink under our name United States European Union
Who answers for it The responsible person on the label The one placing it on the market
What has to exist Facility registration, product listing, safety substantiation, adverse-event reporting A formulation within the REACH limits, a compliant label, documentation per batch
What we would need per lot The full composition, the pigment sources, the test reports, and a label we can stand behind in both places

Why we wait

Every other material we sell can be documented from the supplier's paperwork and a box we opened ourselves. Ink cannot: the documentation is chemical, per pigment, per batch, and it has to be ours to hold. We are not there, and pretending otherwise would break the one rule this site is built on, which is that we do not write what we cannot document. 2027 is the date we think the documents can exist. If it moves, the closed label moves with it.

What to ask your ink brand today

  • Who is the responsible person on the label, and are they registered?
  • Is there a safety data sheet and a composition list per colour, and will they send it?
  • For Europe: is the range formulated to the REACH restriction, and does the label say so?
  • Is the batch number on every bottle, and do they keep records against it?

A brand that answers those four in writing is one we would be glad to sit next to. Until we can answer them ourselves, buy ink from them, not from us.