1. Introduction

1.1 The Nordic Enforcement Group

Nordic enforcement projects are run by the Nordic Enforcement Group, a subgroup of the Nordic Chemicals Group, under the Nordic Council of Ministers. The main purpose of the Nordic Enforcement Group is to exchange experience on control, discussing common challenges as well as enforcing the European chemical legislations through joint enforcement projects.

The Joint Control of Tattoo Inks project was launched in 2023 and completed in 2024. The Norwegian Environment Agency leaded the project (through project managers Alexander Kristiansen and Bjørg Bergheim). Participants from other Nordic countries included Anna Vuori and Petteri Talasniemi from the Finnish Safety and Chemicals Agency, Elmira Tavoosi and Charlotte Björkbäck from the Swedish Medical Products Agency and Ida Lundstein Scharff, Anna Magdalene Brun Hansen and Mette Arnecke from the Danish Environmental Protection Agency.

The project was funded by Nordic Council of Ministers, as part of the program for Nordic co-operation on the Environment and Climate 2019–2024 and the Nordic working group for chemicals, environment and health (NKE) 2023.

1.2 Objectives of the project

The overall objective of this project has been to control compliance of tattoo inks with the requirements of the new Reach restriction (in Annex XVII, entry 75), to raise awareness about the restriction, to identify non-compliant products in the Nordic market and to follow up with enforcement actions.

In addition, a goal of the project was to ensure close cooperation between Nordic enforcement authorities to increase the efficiency of enforcement and ensuring a uniform interpretation of the applicable restriction between the Nordic countries and to harmonize enforcement.

Regarding the enforcement, the project had focus on the following sub-objectives:

the new regulation is known by economic operators in the supply chain
the language requirements are followed
the mandatory statements are correctly applied
the reference/batch number is applied
the list of substances of tattoo inks is including in the marking
the tattoo artists (professional user) fulfil the requirement to provide information to consumers
the tattoo inks do not contain selected restricted substances

Furthermore, we wanted to:

compare the legal differences between each country in the follow-up of non-compliant companies;
investigate if there are differences in non-compliance-rate between the different participating countries; and
investigate if there are differences in the type and/or frequency of non-compliances due to country of origin.