Survey of tattoo ink and Permanent Make Up (PMU) manufacturers
ECHA (the European Chemicals Agency) together with Denmark, Germany, Italy and Norway are preparing a proposal for European Union (EU) wide regulation on the chemical composition of tattoo inks. For further information, see:

-https://echa.europa.eu/registry-of-current-restriction-proposal-intentions/-/substance-rev/14501/term
-https://echa.europa.eu/addressing-chemicals-of-concern/restriction/previous-calls-for-comments-and-evidence/-/substance-rev/14502/term
-http://ectp2017.org/fileadmin/user_upload/ECTP/Evgenia_Stoyanova.pdf

While a lot of information has been gathered to date, with this survey we would like to confirm some concerns indicated by stakeholders and gather information in particularly about the anticipated impacts of the proposed regulation on tattoo ink and PMU manufacturers and about available alternatives.

The information you provide below will be used in the preparation of a restriction proposal and your responses are important to understand how the proposal will affect your industry and if specific measures are needed to address certain issues.

The survey is expected to take about 10 minutes. While many of the questions are not mandatory, we would appreciate you responding to all. Individual responses will remain anonymous and the results will be presented in aggregation for the developed assumptions made in the analysis.

Please respond by 10 September 2017. If you have any questions, please contact echa-restriction-tattoo-inks@echa.europa.eu

Thank you.
1. Are you a manufacturer of
2. Where are you located (headquarters)?
3. If you are to comply with ResAP(2008)1[link] or a similar EU-wide legislation, how would your costs change?
4.
How difficult is it to comply with the concentration requirements for impurities in Table 3 of ResAP(2008)1[link]?
Which concentration limits you won’t be able to comply with?
What would be the lowest concentration limit you can comply with?
What is the lowest concentration limit for nickel you can comply with?
Why is this concentration unavoidable?
5. Restricting the following pigments has been indicated as a concern. Are there technically comparable alternatives at similar prices for the following pigments?
Pigments banned on Annex II but allowed under Annex IV of the EU Cosmetic products regulation (CPR) [please reply to Pigment Blue 15:3 below]
Pigment Blue 15:3
Pigment Green 7 (Are there other technically feasible alternatives in addition to Pigment Green 36?)
6. Are there inks compliant with the requirements of ResAP(2008)1[link] currently on the EU market in all major colours? (assume that Pigment Blue 15:3 is allowed) What is their average price in the EU?
7. What is the average price in the EU of tattoo inks not compliant with ResAP(2008)1[link]? (Please exclude counterfeited and tattoo ink mixed by tattoo artists for own use.)
8. What is the average price in the EU of PMU compliant with ResAP(2008)1[link]?
9. What is the average price in the EU of PMU not compliant with ResAP(2008)1[link]? (Please exclude counterfeited and PMU mixed directly in studios for own use.)
10. How much do you have to spend to develop a new ink family?
11. How long does it take to develop a new ink family?
12. How much do you spend annualy on testing the chemical content of your materials and final product?
13. How much tattoo ink is used by tattoo artists on average annually?
14. How much PMU is used by beauticians (or other professionals) on average annually?
15. What is the industry profit margin (net profits divided by revenues)?
For tattoo inks sold in 30 ml container? (%)
For PMU sold in 10 ml container? (%)
Please specify the geographic region you are referring to (global, US, Europe, Asia, other)
16. How many litres of tattoo inks and/or PMU do you manufacture annualy?
For the EU
& EEA market only
Average price per 30 ml (tattoo inks)
and 10 ml (PMU)
Average
price per litre
Tattoo inks
PMU
17. What is the current growth rate of the market?
18. How do you expect the market growth to change in the future?
19. Historical information suggests that industrial grade pigments (i.e. used in plastics, coatings, printing, textiles) are primarily used in tattoo inks and PMU. Is this still the case or has industry transitioned to pigments used for food, cosmetic or medical purposes?
20. Please feel free to give us any other comments