Do tattoo artists need to record ink lot numbers and how to track them

Lot number, catalogue number and color are different things

A color name tells you what the ink looks like. A catalogue or identification number tells you which product and shade it is, and it is the same on every bottle of that shade. A lot number, also called a batch number, tells you which production run a bottle came from. Two bottles of the same black from the same maker can carry different lot numbers, and only one of them may have a problem.

Recalls and warnings are often issued by lot. In May 2025 the FDA posted an advisory telling consumers, tattoo artists and retailers to avoid two tattoo ink products contaminated with microorganisms, and it identified each product by a single lot number and a best-before date. No other lots of those shades were named. An artist whose record says only the color cannot tell whether a client tattooed months earlier received an affected bottle.

This is not a rare event. According to the FDA, firms conducted 18 voluntary recalls of tattoo inks contaminated with microorganisms between 2003 and 2024, the most recent issued on August 23, 2024. A 2023 study by FDA researchers in Frontiers in Public Health counted 15 US recalls between 2003 and 2021, covering more than 200 inks from 13 manufacturers and one distributor, and found that 14 of the 15 were for microbial contamination.

What US state rules ask for

There is no single US rule. The Network for Public Health Law notes that the federal government does not regulate tattoo businesses and artists directly, that tattooing can be regulated by state law, local law or both, and that local rules can be stricter than the state's. The record requirements differ as a result, and a few examples show the range.

Louisiana requires an individual written record for each client that includes the color, manufacturer and lot number of each pigment used for each tattoo, and the records must be kept for a minimum of three years (Louisiana Administrative Code, Title 51, Part XXVIII, section 107). Missouri requires licensed tattooists to retain records of the dyes used in their tattoos, including the lot number of each pigment used for each patron (20 CSR 2267-5.010).

Texas and Virginia word it differently. Both ask for the specific colors used and, when available, the manufacturer's catalogue or identification number of each color, along with the location on the body and the artist's name. Both require records to be kept for at least two years following the date of the last entry (25 Texas Administrative Code 229.406 and 18VAC41-50-410). A catalogue number meets that wording, but it does not tell you which lot went into the client.

This is general information, not legal or medical advice. Rules change and differ by state, county, city and country. Check the current requirements with your state or local health department or licensing board.

Why the lot matters where no rule asks for it

Sealed does not mean clean. The FDA states that scientists at the agency and elsewhere have found that even unopened and sealed tattoo inks can harbor bacteria and other microorganisms that can cause infections. In a study published in Applied and Environmental Microbiology in July 2024, FDA researchers tested 75 tattoo inks from 14 manufacturers and found around 35 percent contaminated with bacteria. The lead researcher, Seong-Jae Kim, said there was no clear link between a label claiming sterility and the actual absence of contamination.

The question will come to you. The FDA's consumer page on tattoo safety tells anyone who develops a problem after a tattoo to contact their health care professional, to notify the tattoo artist so they can identify the ink and avoid using it again, and to ask for the brand, color, and any lot or batch number of the ink or diluent. If your record holds that answer, you can give it the same day. If it does not, nobody can.

In the EU, the label does part of the work. Since 4 January 2022, the REACH restriction on substances in tattoo inks (Commission Regulation (EU) 2020/2081, entry 75 of Annex XVII) has required suppliers to mark each tattoo ink with a reference number that uniquely identifies the batch, and before using an ink the tattooist must give the person being tattooed the information marked on the package or in the instructions for use. The German Federal Institute for Risk Assessment (BfR) adds that inks containing substances harmful to health are reported to Safety Gate, the EU's rapid alert system, where an ink can be checked before use.

How to record lot numbers without slowing a session down

1. Read the labels at setup, before you pour caps. Write brand, color and lot for every bottle you will use. Labels are easiest to read while the bottles are clean and closed, and a photo of each label is a useful backup for digits that are easy to mistype.
2. Give the diluent its own line. The FDA's advice names the diluent alongside the ink, so a mixing or shading solution belongs in the record with its own lot, just like a pigment.
3. Log the second bottle. If a bottle runs out mid-session and you open another of the same color, record both lots. They may not match, and the record should show both.
4. Record per session, not once per client. Louisiana's wording is each pigment used for each tattoo. A touch-up a year later will usually be done from a different bottle, so each session needs its own ink list.

Common lot number mistakes

Stopping at the color. "Black" or a shade name cannot be matched against a notice that names lots. Even a catalogue number, which satisfies Texas and Virginia, does not separate one production run from another.

Copying the last session forward. Touch-ups often use the same shades as the first session, so reusing the old ink list is tempting, but the bottle on your tray today is probably not the one you used then. In InkCarte, for example, each ink is its own line with a brand, a color and a short note, and the lot number fits in that note. A new touch-up session there starts with the previous session's inks already filled in, notes included, which saves typing but also carries the old lot along, so compare it with the bottle before you save.

Throwing the bottle away first. Once an empty bottle is in the bin, its lot number goes with it. Record it when you open the bottle, not when you clean up.

Keeping records you cannot search by lot. When a lot is named in a warning, the useful question is which clients received it. Paper cards sorted by name make that a long afternoon, so whatever you use, make sure you can get from a lot number back to the sessions it appears in.

Frequently asked questions