Why Tattoo Ink Needs Better Testing
We used to mix pigment in a sandwich bag.
You ordered pigment powder from major companies like National Tattoo Supply, put it in the bag with vodka, witch hazel and glycerin, and then you squished and squeezed until the paste went even and there were no chunks left in it. From there the paste went into a cup, got diluted to whatever consistency you liked, and sat in the ultrasonic to break down further. That was it. Some guys used Listerine instead of vodka. Some used isopropyl. That was the old school way and it worked well enough that nobody questioned it.
I learned a lot after those early batches, including things I wish I'd understood before selling recipes. That experience is why I want finished lots tested, rather than judged by the recipe alone.
What changed how I thought about it
A friend of mine did emulsions and homogenization for personal-use products, lubricants and gels. He described the equipment they used and pointed out that commercial ink companies were almost certainly running the same class of machinery. That was the moment the sandwich bag stopped looking like a method and started looking like a workaround.
Dispersion means breaking pigment clusters apart and keeping them separated. Hand pressure through a bag can break some clumps. A homogenizer gives you more control over the result from batch to batch.
So I started asking questions. When I was younger, I tried to learn what I could about how guys like Phil Fairweather and Adam Everett made ink. They weren't freely sharing that information. I had to work around the edges, talk to people who knew them, and piece together whatever bits I could pick up. From what I understood, Phil was already upset because he felt much of his knowledge had been stolen.
Later I took a liking to Mario Barth, because he educated people about ink in a way almost nobody else was doing. I remember him talking about different types of blacks with a set of color cards, showing the sheen on each and separating the cool-temperature blacks from the warm ones. That sent me down the PBk rabbit hole, and I have been in it ever since. Carbon black, lamp black, bone black, iron oxide black: same word on the label, different pigments, different undertones, different behavior in skin. I wrote that up separately in black tattoo ink explained.
Why I never built an ink company
I formulated my own inks and friends' inks in small batches for years, but never pushed it into a full business. Chemistry became a second love, and tattooing was still the first one. Building a manufacturing operation would have meant less time with a machine in my hand, and I wasn't willing to trade that.
What I did do was sell recipes to artists who wanted to start ink companies.
My view.
Looking back, I wish I hadn't.
Not because I wanted to keep anything to myself. I have never worked that way, and every artist I have taught keeps access to whatever I learn. I regret it because I found out later that the raw material supply wasn't pure enough to be putting into anybody's body, and by then other people were building businesses on formulas I handed them.
The recipe had issues too, but I wasn't aware of them at the time. Further research helped me understand those problems. The raw materials had issues of their own, and likely still do.
Problems with the raw materials
Here is the part most artists never see. Pigment arrives at an ink maker having already passed through several hands, and the paperwork that comes with it reflects what somebody upstream said rather than what anybody measured. When a facility actually tests those pigments, they find things that were never on the list.
The published analyses give us something more concrete than suspicions about a supplier.
A 2021 European survey of 73 inks found that of all pigments actually detected, only 37.7% appeared on the label, and 93% of open-market inks violated EU labeling requirements. A 2024 US analysis of 54 inks found only 6 matched their stated composition completely, with 45 carrying unlisted pigments or additives. Undeclared polyethylene glycol showed up in both studies, and it is not something any formulator I know adds to a carrier. It comes in attached to the pigment as a binder or dispersant, from further up the chain.
Microbiology is no better. A 2024 study tested 75 tattoo and permanent makeup inks and found aerobic and anaerobic bacteria in unopened, sealed bottles, including products labeled sterile.
Those surveys leave an artist with a problem: neither an ingredient label nor a sterility claim tells us everything that testing might find in the bottle.
And some of us are still using drawing ink
Artists still discuss using Talens, Pelikan and Rotring drawing inks for tattooing, despite warnings that they aren't suitable for it. That history shouldn't be treated as evidence that a product made for paper belongs under skin.
There is history behind that. Kuro Sumi takes its name from sumi, the traditional Japanese carbon-black ink used for calligraphy and brush painting. Suppliers have described the company as a sumi ink maker that adapted its formula for tattooing, and it was sold as dual-use for a long stretch. Spaulding & Rogers' catalog listing described it as suitable for calligraphy and mechanical pen applications as well as tattoo work. It is marketed solely as tattoo ink today.
A drawing ink was formulated to sit on paper. Whether it belongs in the dermis is a separate question that nobody asked at the time, and in many shops still nobody asks.
What I think should happen
This section is my proposal. It describes the testing and public-health oversight I believe should be required.
I think every lot of tattoo ink should be analyzed by the health department before it reaches artists and clients. At the very least, testing should be performed by an accredited laboratory and monitored by the appropriate health department alongside the FDA. That oversight should include how samples are collected, what gets tested, and how the results are verified.
Every lot that ships should carry a verified certificate of analysis, available to the artist and to the client. The goal should be to check that the ink meets defined safety standards, catch contamination, and prevent failing lots from being sold. A passing result would not settle every question about long-term safety, but it would provide more accountability than a manufacturer's assurance alone.
The peptide industry already works this way. Buyers there expect a COA by batch, and a seller who cannot produce one is treated accordingly. Tattoo ink goes into the dermis and stays for life, which is a harder exposure to argue with than most of what peptide buyers are testing for.
But I want to be straight about the comparison, because it cuts both ways. COAs in that industry get forged. Lab quality varies enormously. And "third party" usually means a lab the seller picked and paid, which is not independence in any meaningful sense. If tattoo ink copies peptides badly, we end up with a certificate culture that reassures everybody and verifies nothing.
A certificate needs enough detail for an artist to check the batch rather than simply trust the heading.
It should name the laboratory and its accreditation. I would want the appropriate health department, alongside the FDA, involved in either analysis or oversight, with independently collected samples and results that can be verified.
The tests should identify pigments by CI number, distinguish chemical forms of metals, and check PAHs in blacks, aromatic amines in azo colors, residual solvents and microbial counts. The results should be searchable by lot number on the manufacturer's site, available to the client as well as the artist.
That would let me look up the bottle on my station, and let the client check the same result.
Why this matters more than a label rule
Better labeling laws would help, but a label describes a formula. A certificate of analysis describes what was actually in that lot. Those are different claims, and the published surveys show the gap between them is wide.
It also sidesteps the trade secret objection. A manufacturer protecting its dispersion package and grind has a legitimate commercial interest, and I understand it from both sides. A COA reports what is in the product without revealing how it was made. There is no formulation secret in a heavy metals result.
I cover what the law actually requires, and the gap it leaves, in why you can't just read the label.
Where I am now
I still make and safety-test ink formulations. I do not sell ink, because I am not satisfied that what the industry considers normal is good enough, and I will not put a product on the market until I am confident it is genuinely safer.
Until then the most useful thing I can do is tell other artists what to look for. That is what my checklist is for, and it is why I keep writing these up with the sources attached. You should not have to take my word for any of it.
Back then, the sandwich bag worked. But we didn’t really know everything that was in the ink we were bottling. With better equipment and better science available, we should be past that.
Sources
European Chemicals Agency: Tattoo inks and permanent make-up
FDA: Tattoos & Permanent Makeup Fact Sheet
This article combines published research with my own firsthand account. The personal history and the certificate-of-analysis proposal are mine and are labeled as such. Nothing here is medical advice.
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