Tattoo and Piercing Material Traceability: Navigating Legal Obligations and Digitalization
By Emmanuel (MedTattoo), professional tattoo artist and trainer · Reviewed by Maxime, MedMax SARL · Published · Updated
The Critical Importance of Traceability in Body Art
For tattoo artists, piercers, and permanent makeup (PMU) technicians, professional excellence is defined by more than just artistic skill. It is equally defined by a commitment to public health and safety. Tattoo material tracking is not merely a bureaucratic hurdle; it is a fundamental safety barrier that ensures the integrity of every procedure performed in a studio.
This guide sets out what the texts actually require in the European Union and in France, and how to organise your records so you can prove it.
Understanding Legal Obligations for Material Tracking
Informing every client about the inks used (EU, REACH)
Since 4 January 2022, Regulation (EU) 2020/2081 amending REACH (Annex XVII, entry 75, paragraph 7) has applied throughout the European Union. Before each tattoo, the person tattooing must give the client the information on the label of the inks used, including the batch number, the list of ingredients and the safety instructions.
ECHA (European Chemicals Agency) confirms that the batch number is part of the information to pass on and mentions the "ink passport" as a way to do it. A written form is not required, but it is recommended.
Tattoo artists must also refuse inks that are clearly non-compliant. In France, the label must be in French and carry a unique batch number (DGCCRF).
Sterile and reusable equipment (France)
In France, the Order of 11 March 2009 requires sterile single-use needles for each client and each session (Annex I). For reusable equipment, a traceability sheet must be filled in for each disinfection: type of equipment, date, products used, contact time and operator (Annex III, Légifrance).
Other obligations in France
- An agreement with a collector of infectious healthcare waste (DASRI), with collection slips kept for 3 years.
- For a minor, written authorisation from the holder of parental authority, kept for 3 years.
- Written information for clients on risks and aftercare, displayed in the studio and handed over in writing.
- Serious adverse effects reported to ANSES (tattoo vigilance).
Source for these points: DGCCRF. Outside the EU, check your local regulations.
How long should batch numbers be kept?
No text sets a retention period. Keep this information for a long time, because a reaction to an ink can appear long after the tattoo.
The Risks of Control: What Happens During an Inspection?
During an inspection, you need to show that you meet these obligations. Without a record per client, you cannot:
- prove that you gave each client the batch numbers and composition of the inks used;
- find the clients concerned quickly in case of a reaction, a batch recall or a report to the authorities;
- show your disinfection traceability sheets to an inspector.
A management tool like Tattoomorrow lets you centralise this data, so you find it in seconds instead of searching through boxes of paperwork.
Transitioning from Paper to Digital Traceability
The traditional method of cutting out batch numbers from ink bottles and taping them to consent forms is prone to loss, damage, and human error. No text imposes the format of a "batch register": it is simply your way of proving that you meet the REACH obligation.
What Tattoomorrow records
Tattoomorrow records batches per client and per project, with a photo of the bottle. That means you can:
- keep a dated record for each session;
- store it securely in the cloud;
- find the clients concerned by a given batch in seconds.
The app helps you meet your obligations; giving the information to the client before the tattoo remains your responsibility.
Integrating Traceability into the Workflow
Log the inks and equipment during the setup phase of your session, before the client sits in the chair, and give the client the label information before you start. With Tattoomorrow, recording the batches in the client's project becomes a natural step in the tattooing or piercing process.
Maintaining Tattoo Hygiene Standards beyond the Ink
Traceability isn't just about what stays in the skin. In France, it also covers studio equipment:
- Reusable equipment: a traceability sheet for each disinfection (Order of 11 March 2009, Annex III).
- Needles: sterile and single-use for each client and each session.
- Healthcare waste: DASRI collection slips kept for 3 years.
Digital systems allow these documents to be stored in one place, accessible from your phone or tablet.
Conclusion: Peace of Mind for You and Your Clients
Legal compliance should not be viewed as a burden, but as a professional shield. By recording batches for every client, you can prove that you informed them and react quickly if a problem occurs.
Ready to simplify your traceability? Tester gratuitement Tattoomorrow today and see how easy it is to record batches per client.
Official sources
Training
EvoTattoo is MedMax SARL's tattoo school, the company that publishes Tattoomorrow. Its training courses are in French and take place in France.
FAQ
How long should I keep traceability records for tattoo inks?
No text sets a retention period. Keep this information for a long time, because a reaction to an ink can appear long after the tattoo.
What is the most important info to track for tattoo needles?
Needles must be sterile and single-use for each client and each session (in France, Order of 11 March 2009). Recording the brand, configuration, batch number and sterile expiry date helps you prove it and find the clients concerned if a problem occurs.
Can I simply take photos of my ink bottles instead of using software?
A photo is useful, but loose photos are hard to search. Tattoomorrow attaches the photo of the bottle and the batch to the client's project, so you can find the clients concerned by a batch in seconds.
Are permanent makeup (PMU) artists subject to the same traceability rules?
Yes. In the EU, Regulation (EU) 2020/2081 also covers permanent makeup: before the procedure, you must give the client the label information of the pigments used, including the batch number.