In my opinion the Kruger publication quoted above, Industrial Organic Pigments, and the CPMA are informative.

But, we cannot argue about the existence of unwanted contents citing "expert" "scientific" arguments. That would be fighting with their rules. We should not even consider debating so-called "scientific findings." It would be insane to hire our own chemists to find what their chemists find.

It would seem better to argue that colorants synthetic organic pigments should continue as a “carve-out,” as an exception from MoCRA-2022.

On Permanent Cosmetics
Tattoo had in the early 1900s, especially the nine years between the two great wars (George Burchett, Memoirs of a Tattooist) - and continue to have - a purely cosmetic application of blush on the cheeks, lip and eyebrow using Tattoo methods, copying tattooist techniques, the tools and the inks (but wearing a white jacket in a salon and never using the word tattoo).

I can't be more enthusiastic for George Burchett's Memoirs which fill the gap from late 189s to WWII.  Order today from UnimaxShop.com.

For the past 80 years the FDA side-stepped Tattoo to avoid the dilemma that Tattoo does not fit into a cosmetic meaning.

Tattoo has one argument that should win the day: Tattoo has the right to use customary and normally used pigments that are proven safe and effective over time.

To wit, the Tattoo argument is:

Tattoo’s current customary and normal ink and practices have merit,
proven over a span of the last 80 years, by
consistent safe and effective usage over time,
In hundreds of millions of tattoos
by hundreds of thousands of tattooists.

USA FDA does not need animal testing to prove the safety of our pigments as recommended by the so-called EU "experts" in the book Dermatologic Complications with Body Art.
 

Our argument to allow usage is recognized around the world
by all Standards Making Bodies, such as ASTM, WHO and WTO,
accepted as the sine qua non of proof: safe and effective use
over time.

Tattoo cannot be consider cosmetic though some can use it so.

Tattooists have sympathy for those who have psychological dissatisfaction and buyer’s regret but they "knew what they were doing" and will have to deal with their problems.  Their problem, should not be made into our problem but it is precisely this that is driving the effort to ban all pigments that makes Tattoo permanent. If MoCA 2022 paplies to tattooists inks then we are temporary tattooists and reduce our art to meaningless butterflies, easily removed.

MoCRA 022 is the result of 20 years lobbying to ban pigments that cannot be removed easily by lasers, in fact, to ban all synthetic organic pigments because lasers turn them into unknown substances.
No discussion is possible on these issues.
 

Tattoo does not enter into debate about these principles.

And in my opinion we should Raise Our Voice.

Respectfully submitted,

Westley Wood
August 16, 2023