Upcoming TPO Ban – Practical Information

TPO has been banned since 1 September 2025 — what nail professionals should do now

Since 1 September 2025, TPO (Trimethylbenzoyl Diphenylphosphine Oxide) is prohibited in cosmetic products on the EU market — and there was no “sell-through” or “use-up” period for existing stock. If you are a nail professional, the practical message today is simple: identify any remaining TPO-containing products, remove them from service, and ensure your purchasing and records demonstrate you work with compliant products.

Key point: This is not a voluntary “clean” claim. It is a legal prohibition under EU cosmetics law, and it applies to professional use as well as retail sales. Operationally, treat any TPO-containing nail cosmetic as non-compliant stock after 1 September 2025.

1) Why TPO was banned

TPO is a photoinitiator used in UV/LED-curable systems (including nail gels) to initiate polymerisation during curing. It has historically been used because it can support fast curing, including in more heavily pigmented products.

The regulatory trigger is the legal classification of the substance. Under EU cosmetics rules, substances classified as CMR Category 1A or 1B (carcinogenic, mutagenic, or toxic to reproduction) are generally prohibited in cosmetics unless a specific derogation is requested and granted under strict conditions. TPO received a harmonised classification as a Reproductive Toxicant Category 1B, which led to it being prohibited in cosmetic products.

Practical takeaway: once the harmonised CMR classification applied, TPO had to be treated as prohibited in cosmetics from the regulatory application date — unless a derogation existed. No derogation was put in place for TPO prior to the prohibition taking effect.

2) What changed after 1 September 2025

From 1 September 2025, cosmetic nail products containing TPO became non-compliant on the EU market. A key point (often misunderstood in salons) is that there was no general “sell-through” or “use-up” period for existing stock after the prohibition date.

In practice, that means:

  • Manufacture/import/placing on the market of TPO-containing cosmetic nail products is not permitted after the application date.
  • Professional use of a non-compliant cosmetic is also not a safe assumption after the prohibition date.
  • The main enforcement risks concentrate around old stock, grey-market imports, and products with unclear or incomplete ingredient lists.

Six to seven months later, the market has largely stabilised for EU-focused brands (reformulated lines, clearer “TPO-free” portfolios). The remaining risk is mainly operational: what is still sitting in drawers, what was bought informally, and what cannot be documented.

3) What to do now (6–7 months later)

If you have not already done a “TPO clean-out”, do it once, properly, and document it. The goal is not bureaucracy — it is a simple, defensible workflow that prevents accidental use of non-compliant product.

  • Audit your shelf: check the ingredient list for “Trimethylbenzoyl Diphenylphosphine Oxide”. If present, quarantine the item immediately.

  • Stop using non-compliant products: do not use on clients, do not resell, do not gift, and do not “finish the jar”.

  • Dispose responsibly: treat leftover gel/solvent residues as chemical waste according to local rules; do not pour into drains. If in doubt, ask your local waste service for “hazardous waste” guidance.

  • Replace with verified alternatives: choose lines with clear, complete INCI lists and a supplier who can confirm EU compliance.

  • Update your curing SOP: changing photoinitiator packages can change curing behaviour. Re-validate curing times and thin-layer technique (see section 5).

Quick self-check: If you cannot confidently answer “Where did I buy this?” and “Can I show the ingredient list?” for a product used on clients, it should not be in your active professional kit.

Nail technician checking the ingredients of a nail gel bottle

4) Stock control and documentation for inspections

Post-ban compliance is mostly about having an inspection-ready story: you can show you buy from reputable sources, you can show ingredient lists, and you have removed legacy non-compliant stock. Keep it lightweight but systematic:

  • Supplier invoices / purchase records: keep invoices and order confirmations that show your supply chain.

  • Ingredient information: keep product photos (label/INCI) or supplier product pages saved as PDF showing the complete INCI list.

  • Batch/lot traceability (where available): batch codes help demonstrate professional stock control.

  • Non-compliant stock log (optional but helpful): date identified, product name, quantity, and disposal route.

High-risk behaviour to avoid: importing cosmetic nail gels from outside the EU where compliance is unclear. If a product contains TPO after 1 September 2025, treat it as non-compliant for EU professional use and EU market placement.

5) Life after TPO: product selection and curing expectations

The main practical issue after reformulation is not “does it work?” but “does it work the same in my lamp and workflow?”. Different photoinitiator packages can behave differently under different lamp spectra, irradiance and application thickness. Standardise your process and you reduce almost all “post-TPO” frustration.

What to check when switching to a new (TPO-free) system

  • Lamp compatibility: curing depends on wavelength peaks, irradiance and uniformity. A compliant formula can still under-cure in a weak or mismatched lamp.

  • Layer thickness discipline: many soft-cure problems come from applying colour too thick, especially with highly pigmented shades.

  • Re-test timings: do not assume curing times transfer brand-to-brand. Validate base/colour/top/builder separately.

  • Thumb positioning and shadow zones: under-curing often happens at thumbs and sidewalls. Standardise hand placement and cure duration.

  • Keep a simple SOP: write down curing times per gel family and per lamp model, especially if you work with staff or teach.

If you want a robust professional approach: choose a compliant system, validate it with your lamp(s), and standardise your curing workflow. That reduces variability more than mixing many brands.

References & official sources

Disclaimer: This article is general regulatory information for nail professionals and distributors. It is not legal advice. For enforcement questions, follow your national competent authority and the European Commission Q&A.

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