UK REACH for tattoo inks, what artists must know

The UK REACH restriction on substances in tattoo inks and permanent make-up had its restriction decision published on 30 December 2025, with draft Annex 17 amendment text released 15 January 2026. The final amending SI is not yet on legislation.gov.uk as a made law. This is the regulatory shift the trade was waiting on for four years. This guide describes what changed, the GB/NI split under the Windsor Framework, the transition period, and what you should be demanding from ink suppliers from now on. The deeper supplier-audit material lives in the equipment-inks section.

At a glance

	Great Britain (E/W/S)	Northern Ireland
Operative regime	UK REACH	EU REACH (Windsor Framework)
Restriction decision published	30 December 2025	4 January 2022
Restriction published	15 January 2026 (draft amendment)	EU Reg 2020/2081
Pigment Blue 15:3 + Green 7	Fully restricted (no derogation, 0.1% limit)	Restricted from 4 January 2023
Enforcement body	HSE	HSE NI / EU framework via Windsor
Operative amendment text	Defra draft Annex 17 entry + Appendix 13	Commission Regulation 2020/2081
Transition (from SI entry-into-force)	2 years placing ban + 3 years use ban	Already in force

The short version

Great Britain (England, Wales, Scotland). UK REACH restriction decision on substances in tattoo inks and PMU published 30 December 2025. Defra chose stricter limits (RO3) than the Agency's preferred RO2a, and rejected the proposed derogation for 19 pigments. Transition is 2 years for the placing-on-market ban + 3 years for the use ban, both measured from the SI entry-into-force date. The SI itself is not yet on legislation.gov.uk as at May 2026.
Northern Ireland, tracks EU REACH under the Windsor Framework. The EU's Commission Regulation 2020/2081 has applied in NI since 4 January 2022 with Pigment Blue 15:3 and Pigment Green 7 restricted from 4 January 2023.
What artists must do now: only buy from suppliers who can document UK REACH compliance for GB premises (or EU REACH compliance for NI premises), with Safety Data Sheets and Certificates of Analysis on file for every ink in the kit. The deeper substance-level detail and verbatim Appendix 13 table live in [[uk-reach-annex-17-and-cpnp-notification]].

How the law got here

For four years between Brexit and end-2025, the UK had a regulatory gap. The EU restricted thousands of substances in tattoo inks via Commission Regulation 2020/2081 (effective January 2022, with extended deadline for Phthalocyanine pigments to January 2023). Great Britain did not mirror it. UK REACH was a separate regime, the dossier was being prepared by HSE, and there was no operative restriction. Northern Ireland tracked EU rules under the Windsor Framework, creating a GB/NI internal divergence within the UK.

That gap closed on 30 December 2025. Defra published its restriction decision on the UK REACH restriction, with the draft amendment text released 15 January 2026. The restriction is implemented under UK REACH governance, different agency (HSE), different enforcement route, different update mechanism. The amending SI is not yet on legislation.gov.uk as at May 2026; the operative draft text and Appendix 13 substance table live in the Defra draft amendment PDF.

What's actually restricted

The Annex 17 entry applies to substances falling into any of four categories: CMRs and skin/eye hazards on the GB mandatory classification and labelling list, substances on Annex 2 to the assimilated Cosmetic Products Regulation, conditioned substances on Annex 4 to the same regulation, and the specific substances listed in Appendix 13 to Annex 17.

General concentration thresholds for substances not in Appendix 13:

CMRs (carcinogen, mutagen 1A/1B/2) and substances on the cosmetic-prohibited list: 0.00005% by weight.
Reproductive toxicants and skin sensitisers: 0.001% by weight.
Skin corrosives and serious eye damage substances (not used as pH regulator): 0.01% by weight.
Skin corrosives and serious eye damage substances (used solely as pH regulator): 0.1% by weight.

Appendix 13 names specific substances with their own concentration limits, including the heavy metals (mercury, nickel, antimony, arsenic, cadmium, chromium VI, cobalt, lead, selenium etc), polycyclic aromatic hydrocarbons (Benzo[a]pyrene at 0.0000005%), methanol at 11%, 31 aromatic amines at 0.0005% each, and 44 pigments and dyes at 0.1% each. The verbatim Appendix 13 table is reproduced in [[uk-reach-annex-17-and-cpnp-notification]] and phase-b-reach-citation-recheck.md.

Nickel and Chromium VI label triggers. Even where the mixture contains nickel or chromium VI BELOW the Appendix 13 limit, the entry requires a mandatory allergen warning statement on the label ("Contains nickel. Can cause allergic reactions." or the equivalent chromium VI wording). A compliant ink can still carry an allergen warning.

The practical effect for a working artist: the inks you buy from a UK REACH-compliant supplier should already meet these limits. The compliance burden is on the supplier and importer. Your job is verification.

UK is stricter than EU

UK REACH does not simply mirror EU REACH Entry 75. Defra chose RO3 over the Agency's preferred RO2a, giving stricter concentration limits across multiple substance categories. Defra also rejected the Agency's recommendation to derogate 19 pigments (including Pigment Blue 15:3 and Pigment Green 7) that the EU had considered for staged transition. Those pigments are fully restricted in GB from the outset of the use ban at the 0.1% Appendix 13 limit.

The practical consequence: an EU REACH 2020/2081 compliance declaration is not sufficient for GB. Suppliers selling into the GB market must evidence UK REACH compliance specifically against Appendix 13.

Northern Ireland under the Windsor Framework

Northern Ireland sits in a different regulatory position from the rest of the UK. Under the Windsor Framework, NI continues to apply EU REACH (specifically Commission Regulation 2020/2081), not UK REACH.

What that means in practice:

NI artists buy under EU REACH compliance, not UK REACH. The compliance declaration you ask your supplier for is the EU 2020/2081 declaration, not the UK REACH declaration.
The pigment restrictions on Blue 15:3 and Green 7 in NI have been in force since 4 January 2023, ahead of GB.
Cross-jurisdiction supply: a GB supplier selling into NI must meet EU REACH for the NI portion of their stock. A NI supplier selling into GB must meet UK REACH for the GB portion. Larger UK wholesalers handle both regimes.
EU/GB divergence will grow over time. UK REACH and EU REACH are separate regimes with separate update cycles. Future restriction additions may diverge. The EU's "REACH compliant" is not interchangeable with the UK's after 15 January 2026.

If you work across the GB/NI border (guest spots, conventions, mobile work), maintain documentation for both regimes for any ink that crosses with you.

The transition period

The draft Annex 17 entry sets two transition triggers, both measured from the entry-into-force date of the eventual SI:

2 years after SI entry-into-force, the placing-on-the-market ban starts. Suppliers cannot lawfully place non-compliant ink on the GB market.
3 years after SI entry-into-force, the use ban starts. Professional artists cannot lawfully use non-compliant ink in a tattoo procedure.

The gap between the two dates is a 1-year window where suppliers can no longer sell non-compliant stock but artists can still use stock that was lawfully placed on the market before the placing ban. Both Pigment Blue 15:3 and Pigment Green 7 are in scope of these transition dates with no derogation (the Agency had recommended a longer transition for these pigments; the minister rejected the recommendation).

The SI entry-into-force date is not yet known publicly, so the calendar dates for the placing ban and use ban cannot yet be stated.

There is no special legacy clause for stock placed on the market before the 30 December 2025 decision. Compliance turns on whether the mixture is placed on the market or used after the respective transition dates, not on when it was purchased. The purchase date is not a defence.

Do not stockpile pre-restriction inks in anticipation of the changeover. Lab testing has flagged that some pre-restriction inks fail compliance verification anyway, and the inspector/insurer expectation will increasingly be "show me the SDS and CoA for every ink in your kit." A stockpile of non-compliant ink is a regulatory liability, not a saving.

What this means for the artist's COSHH file

Whether or not a specific ink is restricted under UK REACH, your duties under the Control of Substances Hazardous to Health Regulations 2002 apply. For every ink in your kit you should have:

Safety Data Sheet (SDS) in 16-section UK CLP / GB CLP format. Every supplier must provide this. If they cannot or will not, do not buy.
Certificate of Analysis (CoA), manufacturer's certificate proving the specific batch meets the relevant standard (UK REACH for GB, EU REACH 2020/2081 for NI).
Batch number and expiry date recorded against every client's session in your records, for traceability if a recall is issued.
COSHH risk assessment, written assessment of hazards (skin sensitisation, ingestion, eye contact, storage), control measures (PPE, ventilation, storage rules), and emergency procedures.

Verifying suppliers

The major UK tattoo wholesalers have largely been stocking EU REACH-compliant ranges since 2022 because of NI-GB trade implications and because EU REACH was the only operative restriction in the UK market for that window. Most are now adapting to UK REACH explicitly.

Ready-to-send supplier email

Copy, paste, send. Substitute your supplier's name and your premises country.

Subject: UK REACH / EU REACH compliance documentation request

Hi [supplier name],

I am a working tattoo artist operating in [Great Britain / Northern Ireland]. Following the UK REACH restriction decision on substances in tattoo inks and PMU published 30 December 2025 (draft Annex 17 amendment released 15 January 2026; final SI not yet on legislation.gov.uk), and EU REACH 2020/2081 applying in NI under the Windsor Framework, I need to confirm the compliance position of the inks I buy from you. Please can you provide the following:

A current UK REACH compliance declaration for the inks I buy (for GB premises), or EU REACH 2020/2081 declaration (for NI premises). Ideally both if you supply across jurisdictions.

The current Safety Data Sheet (SDS) in UK/GB CLP 16-section format for every product I might purchase.

A Certificate of Analysis (CoA) for the specific batch supplied when I place an order, naming the pigments and confirming concentration limits against the relevant restriction list (UK REACH Annex 17 for GB, EU 2020/2081 for NI).

Your batch traceability and recall procedure, including how I will be notified if a batch in my kit is later subject to a recall.

Confirmation of who is the importer of record for these inks into the UK. The importer carries the UK REACH compliance duty and I need this on file for my COSHH assessment.

Please reply in writing so I can keep the response on file alongside the SDS and CoA documents.

Thanks, [Your name]

A supplier who hedges on any of these is not the supplier to buy from. A supplier who provides all of them in writing is your first-choice supplier. Keep the responses with your COSHH file.

The independent-testing reality check

The lab evidence on this is unflattering. Independent testing by EU member-state market surveillance authorities and academic groups has consistently found that a significant minority of inks sold as "REACH-compliant" fail verification testing, most often on heavy metals, aromatic amines, or preservative content. The pattern is well-documented in the EU since 2022 and there is no reason to expect UK REACH compliance to be perfect either.

Independent lab evidence summarised by Nordic Tattoo Supplies and tested via the r/TattooArtists community indicated that approximately 9 out of 10 sampled "REACH-compliant" blue and green inks failed verification in one 2024 study (small sample, specific market segment, generalise with caution).

What this means: documented compliance from the supplier is necessary but not sufficient. Treat the SDS+CoA package as a starting point, not proof of safety. The equipment-inks section has more on independent verification and the supplier-audit framework. InkKiln publishes the framework for artists to challenge their own supplier; InkKiln does not publish brand-level verdicts.

What this guide cannot do

The UK REACH restriction text is detailed and substance-specific. Specific transition dates, concentration limits per substance, and exact SDS content requirements live in the published amendment.

Information, not advice. For your situation, verify with the published UK REACH restriction text linked above, your ink supplier's regulatory affairs team, and (for COSHH compliance specifically) the HSE COSHH essentials guidance.