Is TPO Still Hiding in Your Label?

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.