Silver in Nail Products under EU Omnibus VIII: What Nail Professionals Need to Know

Applies from 1 May 2026 — EU Cosmetics Regulation (EC) No 1223/2009

In recent years, the European Union has significantly tightened the rules around certain cosmetic ingredients that raise health concerns. One of the most important updates for the nail industry is Omnibus VIII, formally known as Commission Regulation (EU) 2026/78. This regulation updates several annexes of the EU Cosmetics Regulation and directly affects how silver may (or may not) be used in cosmetic products.

This article explains, in a clear and practical way, what Omnibus VIII means for nail gels and nail products. It is written for nail technicians, nail professionals, and informed nail enthusiasts who want to understand the science and the rules — without needing a chemistry degree.

Short answer: from 1 May 2026, silver is effectively not allowed in nail gel products placed on the EU market. The reason is not marketing, not trends, and not opinion — it is the way silver is regulated across the EU Cosmetics Regulation annexes.

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1. First things first: “silver” in a product name does NOT mean silver in the formula

Before discussing the regulation, an important clarification is needed. A product can perfectly have the word “silver” in its commercial name, shade name, or collection name without containing the substance silver at all.

Examples include names such as:

• Silver Flash
• Moonlight Silver
• Silver Chrome
• Silver Cat Eye

In these cases, the word “silver” usually refers to the visual effect or colour impression, not to the actual chemical ingredient. Many silver-looking effects are created using other pigments (for example mica-based pearlescents or aluminium pigments).

This is crucial: regulatory compliance is never based on the product name. It is based on the ingredients — specifically their INCI names, CAS numbers, and (where relevant) CI numbers.

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2. What is Omnibus VIII?

Omnibus VIII is an EU regulation that updates the annexes of the EU Cosmetics Regulation (Regulation (EC) No 1223/2009). These annexes determine:

• Which substances are prohibited (Annex II)
• Which substances are restricted (Annex III)
• Which colorants are allowed and under which conditions (Annex IV)

Omnibus VIII mainly exists to align cosmetic rules with updated hazard classifications (such as CMR — carcinogenic, mutagenic, or toxic for reproduction). Silver has been affected by this process.

The key concept introduced for silver is that particle size matters. The law does not treat all “silver” the same.

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3. Silver is now regulated by particle size

Under Omnibus VIII, silver is divided into different forms based on the size of its particles:

• Silver (nano): particles between 1 and 100 nanometres
• Silver (powder): particles larger than 100 nanometres but smaller than 1 millimetre
• Silver (massive): particles equal to or larger than 1 millimetre

This distinction is not academic — it directly determines whether a cosmetic product is allowed or not.

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4. Annex II: which forms of silver are prohibited

Under Annex II of the EU Cosmetics Regulation (the list of prohibited substances), Omnibus VIII confirms that certain forms of silver are not allowed in cosmetic products:

• Silver (nano)
• Silver (massive)

If a cosmetic product contains silver in one of these forms, it may not be placed on the EU market. This applies regardless of whether the product is a nail gel, a cream, or any other cosmetic category.

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5. Annex III: very limited restricted use of silver powder

Omnibus VIII does introduce a restricted use for one specific form: silver powder. This is done via Annex III, which allows substances only under strict conditions.

For silver powder, Annex III allows use only in:

• Toothpaste
• Mouthwash

Even in those products, the maximum concentration is strictly limited.

Important for nail professionals: nail gels and nail products are not included in this Annex III permission. This route does not make silver acceptable for nail use.

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6. Annex IV and CI 77820: silver as a colorant

Silver can also appear in cosmetics as a colorant. Colorants are listed in Annex IV and are identified by a CI number (Colour Index number).

For silver, the relevant entry is:

• CI 77820 — Silver

Under Omnibus VIII, CI 77820 (silver powder) is allowed only in:

• Lip products
• Eye shadow

And only up to a maximum concentration.

This is a common misunderstanding: the presence of a CI number does not mean the ingredient is allowed in all cosmetics. Annex IV permissions are product-type specific.

Because nail gels are not listed, CI 77820 cannot be used to justify silver in nail gel products.

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7. What does this mean in practice for nail gels?

Putting the annexes together:

• Some forms of silver are prohibited (Annex II)
• One form is restricted to oral care only (Annex III)
• One form is allowed as a colorant only for lips and eyes (Annex IV)

Nail gels are not included in any of the permitted categories.

This means that, from a practical compliance perspective, silver should not be present in nail gel products placed on the EU market from 1 May 2026.

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8. What is silver used for in nail gel polishes?

When silver is present in cosmetic products, it is usually added for one of three technical reasons. Understanding these uses helps explain why silver occasionally appears in discussions about nail gels — even though its use is now effectively excluded under EU rules.

8.1 Antimicrobial or antibacterial function

Silver is well known for its antimicrobial properties. In some cosmetic applications, it has historically been used to limit the growth of microorganisms by releasing silver ions. This is sometimes described using terms such as “silver ions”, “antibacterial silver”, or “antimicrobial silver”.

In the context of nail gels, such claims are sometimes linked to hygiene, odour control, or extended product stability. However, antimicrobial activity is directly linked to the presence of silver as a substance, which is precisely why it falls under strict regulatory scrutiny.

8.2 Metallic or reflective visual effects

Silver can also be used as a metallic pigment to create highly reflective, chrome-like, or mirror effects. In this case, silver appears as particulate material and may be referenced as a colorant (using a CI number).

It is important to note that many “silver” visual effects in nail gels are achieved without elemental silver, using alternative pigments and coated materials. A silver appearance does not automatically mean silver is present as an ingredient.

8.3 Effect materials such as flakes or glitters

Some complex effect materials (for example flakes or glitters) may contain metallic components, which can include silver depending on the composition. These materials often consist of multiple layers and substrates, making ingredient identification less obvious without proper documentation.

From a regulatory perspective, what matters is not the visual effect, but whether silver as a substance (identified by INCI, CAS, or CI number) is actually present.

Key regulatory point: regardless of whether silver is used for antimicrobial purposes or for visual effects, nail gel products are not included in the limited Annex III and Annex IV exceptions introduced under Omnibus VIII. As a result, silver does not have a permitted use pathway for nail gel products in the EU.

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9. How can you check whether a product actually contains silver?

If you want to understand whether a nail product contains silver as a substance, you should look at technical ingredient information, not the product name.

Step 1 — Check the ingredient identifiers

Silver is usually identified by:

• INCI name: Silver
• CAS number: 7440-22-4
• EC number: 231-131-3
• CI number (if used as colorant): CI 77820

If none of these identifiers appear in the available ingredient information, the product most likely does not contain silver as a substance, even if the word “silver” appears in the product name. However, it should be noted that not all cosmetic products on the market are correctly or fully labelled. In cases of incomplete or non-compliant labelling under the EU Cosmetics Regulation, the presence or absence of silver may not always be immediately clear from the information provided.

Step 2 — Be aware of nanomaterial labelling

In the EU, nanomaterials must be labelled with “(nano)” after the ingredient name. If silver were present as a nanomaterial, it would be declared accordingly. Silver in nano form is prohibited under Annex II.

Step 3 — Understand effect materials

Some nail gels use complex effect materials such as glitters or flakes. These materials can have layered compositions. When in doubt, the decisive factor is always the declared substance identity (INCI/CAS/CI), not the visual effect.

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10. Why this matters for nail professionals

Regulatory changes like Omnibus VIII are not about trends or marketing — they are about aligning cosmetic products with updated safety assessments.

For nail professionals, understanding these rules helps you:

• Better understand why certain products may disappear or be reformulated
• Answer client questions about ingredient safety with confidence
• Recognise the difference between a product name and actual ingredients
• Stay informed about the direction of EU cosmetic regulation

Knowledge is becoming an increasingly important part of professionalism in the nail industry.

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11. Key takeaways

• The word “silver” in a product name does not mean silver is present
• Omnibus VIII updates how silver is regulated in EU cosmetics
• Some forms of silver are prohibited (Annex II)
• Silver powder is allowed only under very narrow exceptions (Annex III and Annex IV)
• Nail gels are not included in those exceptions
• From 1 May 2026, silver is effectively not permitted in nail gel products
• You can check silver via INCI “Silver”, CAS 7440-22-4, EC 231-131-3, and CI 77820

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Sources and further reading

1. Commission Regulation (EU) 2026/78 (Omnibus VIII) — EUR-Lex official text
2. EU Cosmetics Regulation (EC) No 1223/2009 — Consolidated regulation
3. SCCS Opinion on Silver (background scientific assessment) — SCCS document (PDF)
4. CosIng database — Silver (INCI / CAS / CI references) — EU CosIng entry
5. European Commission overview — cosmetics legislation and ingredient rules — Official EU cosmetics legislation page

At Pretty Yeppuda, we label all our products in compliance with the EU Cosmetic Product Regulation (EC) No. 1223/2009. Every label on our bottles contains essential information, including:

• The Responsible Person in the EU

• A complete INCI ingredient list

• Applicable warnings and usage instructions

• Additional mandatory product details

These labels are not just a formality—they serve an important purpose. We strongly recommend that you do not remove the labels, even if it’s tempting for aesthetic reasons. Here’s why:

• 💡 For your own safety: You may need to check the ingredients or instructions later.

• 📋 For regulatory compliance: If you’re ever inspected, having the label on the bottle is direct proof that your product is legally compliant.

• 👩🔬 To show professionalism: It demonstrates to your clients that you take both their health and your responsibilities seriously.

We understand that some customers prefer a cleaner look. If you absolutely want to remove the label, please consider one of the following options:

• 📸 Take a clear photo of the label before removing it

• 🗂 Stick the label into a dedicated product logbook

To help you stay organized, we’ve created a simple Product Purchase Log Template. It includes space for:

• Purchase date

• Supplier/store

• Product name and shade

• Space to attach or paste the label

➡️ Download the template [here] and print it for your salon or workspace.

Remember: Keeping proper records and labels is part of working safely and professionally in the nail industry.

 

If you have lots of products in stock, collected carefully over the years, and you find they all lookalike and they read like gibberish - we thought the below blog article might help.

As the September 2025 EU ban on TPO (Trimethylbenzoyl Diphenylphosphine Oxide) approaches, now is the time to inspect your current stock of gel polish, builder gels, and bases. Even if the product was imported legally in the past, it may no longer be compliant for use or resale under EU law.

🔍 What to Look For on the Ingredient List

Under EU cosmetics regulation, every product label must list its ingredients using official INCI names. For TPO, that INCI name is:

Trimethylbenzoyl Diphenylphosphine Oxide

However, sometimes older or non-compliant products list TPO using informal or incorrect names, including:

• Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide
• (2,4,6-trimethylbenzoyl)diphenylphosphine oxide
• 2,4,6-Trimethyl benzoyldiphenyl phosphine oxide
• Biphenyl(2,4,6-trimethyl-benzoyl)phosphine oxide
• Diphenyl phosphineoxide
• TPO
  

But there are many different names being used.  You might want to look here for an extensive list.

🛑 If you find any of these on your label, the product contains TPO and will be prohibited in the EU as of 1 September 2025, regardless of how small the percentage is.

What Are Legal Alternatives to TPO?

Several photoinitiators are already used in EU-compliant Korean gels. These offer similar performance while complying with EU safety and classification rules.  Some of these might sounds like TPO so hence we listed them below.

1. TPO-L (Ethyl Trimethylbenzoyl Phenylphosphinate)

• INCI: Ethyl Trimethylbenzoyl Phenylphosphinate (CAS number not completed in COSING at the time of writing this blog)
• CAS: 84434-11-7
  

Again several other names exist - which you can find here.

2. TMO (Trimethylbenzoyl Ditolylphosphine Oxide)

• INCI: Trimethylbenzoyl Ditolylphosphine Oxide
• CAS: 270586-78-2
• Also known as bis(4-methylphenyl)phosphoroso](2,4,6-trimethylphenyl)methanone - see ECHA

3. BAPO (BIS-TRIMETHYLBENZOYL PHENYLPHOSPHINE OXIDE)

• INCI: BIS-TRIMETHYLBENZOYL PHENYLPHOSPHINE OXIDE
• CAS: 162881-26-7
  

• Suitable for LED lamps operating at 365 nm and 405 nm

4. Hydroxycyclohexyl Phenyl Ketone

• INCI: Hydroxycyclohexyl Phenyl Ketone
• CAS: 947-19-3
  
• Long-standing photoinitiator used in both cosmetic and dental UV/LED applications.  Note that your lamp should preferably be 365nm (and 405nm)
  
• Often written as 1-Hydroxycyclohexyl Phenyl Ketone - which is the IUPAC name.

We hope this little overview helps you in identifying what products you can keep.  If you have questions regarding products on the site - do not hesitate to reach out.

 

At Pretty Yeppuda, we specialize in bringing the best Korean nail products to customers all over Europe. But before a product ever reaches your salon or your home, there’s a lot happening behind the scenes. Because nail gels, bases, tops, and other products are considered cosmetics under EU law, they must meet strict safety and compliance rules before they can be sold.

In this blog post, we’ll explain, in simple terms, what happens from the moment we discover a great Korean nail product to the moment it is ready for you to buy — and why this process takes months, effort, and significant investment.

We wrote this blog because we often encounter customers or potential customers who believe that cosmetic products are automatically safety tested and controlled at the EU borders by the authorities. That is not the case.

In reality, it is the Responsible Person — usually the importer — who is legally responsible for ensuring the product’s safety and compliance with EU regulations.

At the border, customs authorities work hard to verify that products meet basic import requirements, but they do not perform stability testing nor toxicological safety assessments Their role is to check whether the importer complies with the necessary obligations, not to assess the safety of the product itself.

This also means that when you purchase cosmetic products directly from outside the EU, they have not been subjected to the required EU safety assessments. As a result, these products may contain substances that are restricted or banned under EU regulations, may have incomplete or incorrect ingredient labeling, and may not meet the strict safety and stability standards required for products legally sold within the EU.

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Step 1: Finding the Right Products

Our journey starts with selecting high-quality nail products from trusted Korean brands. We look for innovative products, beautiful colors, and safe, salon-proven formulations. But simply liking a product is not enough: we can only import and sell products that meet the European Cosmetic Product Regulation (EC) No 1223/2009.

This regulation lays out strict safety, labeling, and notification rules for any cosmetic sold in the EU.

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Step 2: Becoming the “Responsible Person”

When we import a nail product into Europe, we don’t just act as the seller. By law, we become the “Responsible Person” for that product in the EU.

This means we must ensure:

• The product safety is assessed by a cosmetic safety assessor

• It complies with all EU cosmetic laws.

• All necessary paperwork and tests are properly done.

The process starts for us with an initial scan of the manufacturer and the product formulations to see if there are no forbidden or restricted substances as that allows to eliminate the products immediately

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Step 3: Safety Assessment and Stability Testing

Before a product can be sold, it must be thoroughly assessed for safety. This involves two important steps:

1. Cosmetic Safety Assessment

A qualified safety assessor examines the product’s full formula, including each ingredient’s concentration, safety profile, and any potential risks.  That assessment is documented in a so called Cosmetic Product Safety Report (CPSR) Without this formal safety assessment, we cannot legally sell the product.

2. Stability Testing

We must also prove that the product remains safe and stable over time. For example, if a gel polish separates, hardens, or changes color after a few months, it could be ineffective.  Stability tests are performed for each product line and take approximately two months.

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Step 4: Building the Product Information File (PIF)

For each product, we must create and maintain a Product Information File (PIF). This file contains all important documents, including:

• Full product formulation

• Manufacturing information

• Cosmetic Product Safety Report (CPSR)

• Labels and claims

• Test reports

The PIF must be kept available for 10 years after the last batch of the product is sold. If authorities ask for it, we must be able to provide it immediately.

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Step 5: Notification in the CPNP

Before a product can legally be sold in the EU, it must be registered in the Cosmetic Product Notification Portal (CPNP), a secure online system managed by the European Commission.

When we submit a product to the CPNP, we provide:

• Product name and category

• Responsible Person’s contact details

• Full ingredient list

• Label information
  

Only after successful CPNP notification is the product officially allowed on the EU market.

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Step 6: Labeling

Labeling Compliance means:

• Ensuring the label has all mandatory information (e.g., Responsible Person, country of origin, ingredient list, warnings, batch number, PAO symbol, etc.)

• Mandatory warnings are included in the label

• Language requirements stipulate that the labels must be translated into the language(s) of the target EU market

 

Why It’s a Big Job (and Investment)

Importing one product line is already a lot of work — but Korean brands often have many different types of gels and finishes:

• Base gels

• Top gels

• Color gels

• Syrup gels

• Magnetic gels
  

• ...

Each different formulation requires its own safety assessment, testing, and CPNP notification.  Costs for a safety assessment and stability testing range between €500 and €1000 per product line.  Guess you can do the math...

If a product line (for example, a color gel collection) is based on one consistent formula, but simply offered in many shades (colors), we can register them all under a single notification — which saves time and money.  However, some brands create different formulations for different shades, meaning we must treat them as separate products. This significantly increases the cost and workload.

Korean products are also constantly evolving  seen their ongoing search for better products - the ongoing innovation is one strengths.  But this also means that safety assessments need to be done again, CPNP needs to be redone,...

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How Long Does It Take?

From the moment we decide to bring in a new product, the full compliance process typically takes 2-3 months:

• Gathering all technical documents from the manufacturer
  

• Performing safety assessments and stability tests

• Building the Product Information File

• Registering the product on the CPNP

Only after completing all these steps can we legally launch the product in our webshop.

Final Thoughts

At Pretty Yeppuda, we love introducing amazing Korean nail products to Europe — but it’s not as simple as picking a few nice colors.

Behind every bottle of gel polish, base coat, or nail art product you see on our website is months of work to ensure it meets the EU safety and compliance standards.

We think this is important for you and your clients' safety.