1. Why Is TPO Being Banned?
As of September 1st, 2025, the European Union will prohibit the use of TPO (Trimethylbenzoyl Diphenylphosphine Oxide) in cosmetic products, including nail gels. TPO is a photoinitiator used in UV-curable systems that ensures fast and even curing of gel products. However, under EU Regulation (EC) No 1223/2009, substances classified as Carcinogenic, Mutagenic, or Reprotoxic (CMR) are not allowed in cosmetics unless specifically exempted. TPO has recently been classified as a Category 1B CMR substance (¹) due to concerns regarding its long-term health effects, leading to its inclusion in the ban. While the actual risk during proper use may be low, the EU applies a precautionary approach, and this classification mandates its removal from the cosmetics market.
2. Impact on the Nail Industry
The upcoming ban has led to a significant shift in the professional nail products market. Some manufacturers—both large and niche—have proactively reformulated their products to remove TPO. Others, including some well-known US,UK,European, and Korean brands, have decided not to reformulate, as the EU market may represent only a small part of their global sales. As a result, certain popular gel lines are being discontinued in the EU. Additionally, some brands are still in the process of reformulating, meaning product availability remains uncertain in the months leading up to the ban. The market is undergoing a shake-up, and nail professionals may find that some long-trusted products are no longer available or are being replaced by new formulations.
3. Understanding the Key Dates and Scenarios
From a regulatory perspective, there are three main cases nail technicians should be aware of:
• Products manufactured before 01/09/2025 can still be sold up to that date and may be used afterward. These are considered legally placed on the market before the ban takes effect.
• Products manufactured before 01/09/2025 but not sold before that date can no longer be legally sold or distributed within the EU after 01/09/2025. However, if you bought them before the deadline, you may still use them.
• Products manufactured after 01/09/2025 that contain TPO are strictly prohibited. These products may not be sold nor used within the EU under any circumstances.
Correct documentation, batch tracking, and awareness of manufacture dates will be essential to determine what is still allowed post-ban.
4. What This Means in Practice
For our customers, this regulation means that any TPO-containing products will no longer be restocked after April 2025, in anticipation of the September deadline. If you rely on specific TPO-based gels, we recommend stocking up before summer. After 01/09/2025, you may continue using these products only if they were purchased and manufactured before the cutoff.
We strongly advise against attempting to circumvent the ban by purchasing TPO-containing products from non-EU sellers after the deadline. Importing and using such products would be illegal under EU law. Should you be inspected or reported, you may be required to justify your product’s compliance, including manufacture date, purchase documentation, and batch traceability.
For a detailed explanation of your legal responsibilities as a nail technician, we recommend reading our related blog post: “Why Nail Technicians Should Order Korean Nail Products from an EU-Based Webshop.”
5. Transition Support and the Road Ahead
If your favorite brand is no longer available, reach out to us. We are currently preparing an overview of TPO-free alternatives, where we’ll list commonly used products alongside recommended substitutes, so you can make an informed switch with minimal disruption.
For the rest, we ask for a bit of patience, as a number of Korean brands are still finalizing reformulations, and others are likely to follow in the future—especially as the TPO ban is expected to expand to other regions beyond the EU.
In fact, several Korean manufacturers are now actively promoting TPO-free formulations, clearly marking them as “TPO-Free” to demonstrate compliance and awareness. This is a strong signal that TPO-free is the future, and the industry is moving in the right direction.
(¹) Trimethylbenzoyl Diphenylphosphine Oxide (TPO) has been officially reclassified by the European Chemicals Agency (ECHA) from a Category 2 reproductive toxicant (Repr. 2; substances suspected of impairing fertility) to a Category 1B reproductive toxicant (Repr. 1B; substances presumed to have adverse effects on fertility or reproduction based on animal studies). This upgrade in classification reflects stronger toxicological evidence obtained from animal studies, indicating that TPO may damage fertility and is also suspected of potentially harming the unborn child at higher exposure levels. Consequently, under EU Regulation (EC) No 1223/2009, substances classified as Carcinogenic, Mutagenic, or Reprotoxic (CMR Category 1A or 1B) are strictly prohibited from use in cosmetic products unless explicitly exempted. Although acute toxicity studies have indicated relatively low immediate health risks (oral and dermal toxicity), repeated-dose and reproductive toxicity studies demonstrated significant adverse effects, particularly reproductive harm at higher dosages. This has led the EU to adopt a precautionary approach and mandate TPO’s removal from cosmetic products, including UV-curable nail gels.
References:
• Cosmetic Ingredient Review (CIR), Safety Assessment of Trimethylbenzoyl Diphenylphosphine Oxide.
