Filenews 29 October 2025 - by Michalis Hatzivasilis
"The prolonged inaction due to the inability to implement the existing legislation on tattooists and piercings, even to the extent possible, puts customers, staff and public health at risk." This is what the Commissioner for Administration and Protection of Human Rights emphasizes in her report on the occasion of the uproar with the tattoo and piercing workshops.
The most paradoxical thing highlighted in Commissioner Maria Stylianou Lottides' report is that on the basis of the legislation, in order for someone to be a tattooist or body penetrator legal, he must present to the Ministry of Health a certificate of start of exercise in an approved tattoo laboratory. However, this cannot be done, since there is no approved/licensed laboratory to date. As a result, the professionals of the genre are all exposed.
The reason for the preparation of the report was a complaint submitted by a professional dermatologist, who, while requesting to be registered in the register of practicing tattooists and body piercers, his application was rejected and, in fact, orally. As the Commissioner points out, the complainant's application was examined almost a year after it was submitted by the Board for the Registration of Dermatologists and Body Piercers. Furthermore, it is stated in the report that, although the request was examined, on the one hand as a request for registration in the Register of Registered Leathermakers, on the basis of the transitional provisions of the Law (Article 41), and on the other hand as a request for registration in the Register of Trainees (Article 20), the Council omitted and/or neglected in both cases to notify in writing its will to the complainant, which, in essence, consists of refusing to register in the Registers.
This handling on the part of the Council, according to the Commissioner for Administration, is clearly contrary to the general principles of Administrative Law and in particular, to Article 26, where on the one hand the decision as an oral decision remains unjustified and cannot be reviewed, and on the other hand to the violation of Article 5 of the General Principles of Administrative Law Law, since the complainant was not informed of the legal remedies available to him to challenge the decision. It should be noted, it is stated, that the written notification of the decision of the administrative body to the applicant, as well as its justification, are safeguards of transparency and guarantees of legal certainty and good administration.
The most important thing pointed out in the report is that "even if the certificate submitted by the complainant was a diploma or certificate or other equivalent educational qualification within the meaning of the Law, his request for registration in the Register of Dermatologists would still be rejected, since he would not meet the condition regarding the presentation of a certificate starting the exercise in an approved tattoo laboratory, since there is no approved/licensed laboratory to date.
The non-fulfilment of this condition is clearly not due to the fault of the complainant, since as explained by the Ministry of Health, currently, no space used as a tattoo and/or body piercing laboratory is approved by the Council, as no relevant application was submitted to it, except for one." In addition, it is pointed out that in the absence of a licensed laboratory, which is legitimized under the relevant law to provide a certificate of practice, no professional tattoo maker and/or body piercer can currently legally practice his profession, since there is no approved laboratory to carry out his internship, as a prerequisite under relevant legislation. At the same time, it is emphasized, it appears that, at this stage, premises are operating as tattooing and/or body piercing workshops, without a permit if they have not received relevant approval from the Council and without being able to check whether or not the general principles of operation provided for by law are met, in order to protect public health.
And all this at the expense of public health, since no control is exercised and, fortunately, all those involved in the profession, take all the measures themselves, so as not to cause issues related to safety and health.
Maria Stylianou Lottides calls for new legislation as soon as possible
The Commissioner further blames the Ministry of Health for failing to effectively implement the provisions of the current legislation and to take the necessary preventive and repressive measures contained in the Law, so that, on the one hand, public health is protected and, on the other hand, the specific laboratories and professionals can legally practice their profession.
The Commissioner notes the will of the Ministry of Health to amend the law, including the change of the conditions for practicing the profession of leathermaker or body piercer, but also the simplification of the procedures for licensing laboratories directly related to the license to practice the profession. Although the proposed amendments go in the right direction and a detailed record of the provisions that need to be extended or revised, notes Ms. Lottides, however, the prolonged inaction due to the inability to implement the existing legislation even to the extent possible, puts customers, staff and public health at risk.
«Because without the application of the law, there is no licensed person to perform tattooing and/or body piercing, if there is no licensed laboratory for this purpose. And if there is an absence of a preliminary permit, the absence of a systematic check by the inspectors of the Ministry of Health to determine at regular intervals if there are health deficiencies follows as a chain consequence, omissions or circumstances that could endanger the health of contracting parties and non-contracting parties," says the Commissioner.
As a result of the above findings, a recommendation is submitted that the competent authorities take all the necessary actions for the observance and implementation of the provisions of the Law in question, in order to fulfil its purpose, which is none other than the protection of the health of the contracting persons, staff and public health during the provision of tattooing and body piercing services and on the other hand the legislative consolidation of the profession of tattoo artist and body penetrator.
Furthermore, because the rights and obligations of a large number of people are affected, it is expected that the stakeholders will quickly take the necessary steps to complete the amendment of the legislation as soon as possible.
