Tattoo pigment EU REACH testing process

Date：2025-07-22 10:51:30 Classification ：【question】 Visits：635

The complete process and key points of REACH testing for tattoo pigments exported to the EU are summarized in combination with EU regulatory requirements and practical guidelines for testing agencies:

I. Core testing process

1. Demand confirmation and agency selection

- Confirm whether the tattoo pigment contains substances restricted by EU REACH Annex XVII (such as polycyclic aromatic hydrocarbons, heavy metals, and specific azo dyes).

- Select a testing agency with EU accreditation qualifications (such as Dezewei Testing).

2. Submit application and prepare samples

- Fill in the application form: provide a pigment composition table (including CAS number), production process, and instructions for use.

- Send samples:

- 2-3 individually packaged pigment samples (≥50g each) are required;

- If it contains multiple components (such as pigment + solvent), they must be marked and submitted separately.

3. Laboratory testing stage

- Mandatory inspection items:

| Inspection category

| Heavy metals

| Polycyclic aromatic hydrocarbons (PAHs)

| Specific azo dyes

| SVHC substances of high concern

- Cycle: Routine testing takes 5-7 working days, and complex components or urgent needs may be extended.

4. Report generation and compliance rectification

- The testing agency issues a REACH test report in Chinese and English, including:

- Sample information, test methods, limit standards, and result comparison;

- If it fails: mark the excessive substances and recommend alternatives (such as replacing harmless pigments).

2. Key operation suggestions

1. Pre-examination of materials to reduce risks

- Require raw material suppliers to provide REACH compliance statements and third-party test reports;

- Avoid using formulas containing phthalates (plasticizers) and hexavalent chromium (stabilizers).

2. Key points for document preparation

- Must provide:

- Color MSDS safety data sheet (including first aid measures, leakage treatment);

- Production process flow chart and quality control records;

- Packaging identification diagram (must include ingredient percentage).

3. Cost and cycle optimization

- Basic package fee: ￥1000~2000 yuan (single color/simple ingredient);

- Expedited service: pay an additional 30%~50% fee, which can be shortened to 3 working days.

III. Violation risk warning

1. EU market supervision measures

- Exceeding products will be forced to be removed from the shelves/destroyed and face a fine of 4% of sales;

- Included in the RAPEX early warning system, resulting in EU-wide notification.

2. Special requirements for tattoo pigments

- Products that come into direct contact with the human body need to undergo additional skin sensitization testing (EN 71-10/11 standard);

- Organic solvent components need to provide data on volatile organic compounds (VOCs) release.

IV. Successful case reference

- Correction plan for a certain color pigment company:

1. Cadmium exceeding the standard (0.03%) was detected → replaced with iron oxide pigments;

2. Supplementary SVHC substance screening (two new tests);

3. After re-inspection, the ECHA compliance certificate was obtained, and the export volume increased by 40%.

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