An EU-wide ban on the vital pigments Blue 15 & Green 7 would have a lasting negative impact on the economic competitiveness of European tattoo artists and pigmenters vis-à-vis suppliers outside the EU and would seriously endanger the ability of this profession to work independently.
Consumers will not give up the high-quality tattoos and cosmetic tattoos currently available and will buy their tattoos from a ban, instead of from their local European suppliers from suppliers from neighbouring EU countries.
Such a ban will also encourage the revival of so-called backyard tattooists, i.e. illegal suppliers and the practice of commercial undeclared practices.
As an example, Austria should be mentioned.
In Austria, the practice of tattooing/pigmenting is subject to one of the strictest guidelines in Europe:
All these directives will lose their effect if consumers migrate to third countries or to unregistered/illegal tattoo artists/pigmentators, as it is well known that these buy their tattoos from unsupervised online shops and that compliance with the directives can generally not be verified for unregistered suppliers.
Furthermore, this regulation poses a threat to the welfare of the consumer. Since a ban on the above-mentioned pigments will only lead to circumvention of the ban.
A known and not uncommon practice in this respect is an incorrect declaration in the use of the prohibited product. In this case the product is declared and advertised as an artist's colour. This would have the consequence that the misdeclared product could circumvent the legal restrictions and in the end be processed at the consumer.
As a result, the legal minimum requirements regarding sterility or the compliance with the limit values regarding organic and inorganic impurities no longer need to be checked, because the question of liability moves away from the manufacturer importer/ distributor to the processing tattoo artist / pigmentation artist and consumers are even worse protected than before the ban.
This regulation cannot be in line with the European Community approach, as it does not protect its independent operators or consumers. The diversion of consumers to third countries encourages undeclared work and reduces tax revenue equally.
Furthermore, tattooing is a very old form of culture and art. With this planned ban on the above-mentioned pigments, the practice of this art would also be endangered, or even threatened to disappear.