The European Union has adopted Commission Regulation (EU) 2025/877, which bans the use of Trimethylbenzoyl Diphenylphosphine Oxide (TPO) in cosmetic products starting September 1, 2025.
TPO is a photoinitiator, meaning it helps nail products cure and harden when exposed to UV or LED light. You'll typically find it in gel polishes, builder gels and hard gels, base and top coats, and also hybrid formulas.
What does this mean for US-based nail professionals?
Many brands already make TPO-free formulas. It's hard to say definitively what changes might be coming, but some formulas may need to be updated to comply with EU standards so that they can be sold inside the EU going forward. And some may be phased out or become harder to access.
Want to answer questions from your clients (if any stay on top of this kind of news)?
Here is an A.I.-generated script that nail professionals might want to keep handy:
Client:“I heard Europe banned something in gel polish—is it still safe to get a manicure here?”
You:
“Yes, your manicure is safe. What Europe banned is one specific ingredient called TPO, which helps gel polish cure under light. Some studies linked it to possible health risks, so Europe is requiring brands to reformulate.
The good news is that gel manicures themselves are not banned—and many brands already make TPO-free formulas. In the U.S., products are still legal, but since most nail brands sell worldwide, you’ll start seeing more TPO-free options here too.
I always keep an eye on ingredient safety and industry changes, so you can feel confident about the products I use on you.”
From the European Commission Q&A
The decision has prompted questions from industry and regulators about how the ban will be applied, especially given the lack of a transition period for existing stock. To address the confusion, the European Commission released a Q&A to provide clear guidance for businesses, enforcement agencies, and member states. Here is an excerpt with guidance for EU-based nail and salon professionals:
How does the prohibition apply to professional users?
Professional users, such as nail technicians, use cosmetic products in the course of providing a paid service, as part of a commercial activity.
Therefore, a professional user (e.g. nail technician, salon) cannot use such a product on clients from 1 September 2025 onwards, because this constitutes “making available on the market” in the course of a commercial activity.
This applies regardless of whether the product was purchased before the cut-off date.
What should companies and professionals do now?
Discontinue sale, supply, and professional use of TPO-containing products by 1 September 2025.
Withdraw remaining stock from professional premises.
Seek compliant alternatives from suppliers.
For future substances of concern, monitor regulatory developments early — discussions on TPO started at Working Group level in March 2024.