On September 1, 2025, the European Union enacted a sweeping ban on the use of Trimethylbenzoyl Diphenylphosphine Oxide (TPO), a widely used photoinitiator in gel nail polish formulations, marking a significant shift in cosmetic regulation.
by 
On September 1, 2025, the European Union enacted a sweeping ban on the use of Trimethylbenzoyl Diphenylphosphine Oxide (TPO), a widely used photoinitiator in gel nail polish formulations, marking a significant shift in cosmetic regulation. This decisive move prohibits not only the sale and marketing of TPO-containing products across EU markets but also their use by professionals, with no grace period or exception allowed.
Why TPO?
TPO is responsible for delivering gel polish’s characteristic ultra-glossy finish and its ability to cure rapidly under LED or UV light. However, recent scientific assessments have raised red flags: TPO is now classified by EU regulators as a CMR category 1B substance, meaning it’s potentially carcinogenic, mutagenic, or toxic to reproductive health.
What Changed and Why?
This regulatory leap stems from TPO’s harm classification, established under the CLP Regulation (EC) No 1272/2008. Once substances are identified as CMR category 1B, the Cosmetics Regulation (EC) No 1223/2009 automatically mandates their inclusion in Annex II, effectively banning their use in cosmetic products, unless a formal derogation is granted and none was for TPO.
The decision reflects a precautionary principle: while most evidence of harm comes from animal studies, the potential risks, regarding fertility and reproductive health, are deemed sufficient to warrant action.
Immediate Impact on Industry
The ban applies broadly: manufacturers cannot place new TPO-containing products on the EU market, and professionals, including nail technicians, are prohibited from using existing stock, even if purchased before September 1. The EU’s stringent approach has caught many in the beauty industry off guard, with some professionals warning that the timeline allowed insufficient preparation time.
Regulators across member states are empowered to impose enforcement actions, including substantial fines, for violations, some reports cite penalties up to €22,000 per infringement.
Broader Implications and Reactions
Critics argue that the ban is precautionary rather than evidence-based, pointing to the lack of definitive human studies proving harm at typical exposure levels. However, EU officials defend the decision as aligned with public health priorities and chemical safety frameworks designed to err on the side of caution.
Interestingly, TPO remains in use, or legally permitted, in sectors outside cosmetics, including industrial applications, printing, electronic coatings, and even dental materials. The ban applies only to cosmetics due to differing regulatory rules across industries.
Alternatives and Industry Adaptation
The response across the beauty sector has been swift. Many companies are reformulating their products using safer photoinitiator alternatives such as TPO-L, BAPO, and hydroxycyclohexyl phenyl ketone. These substitutes are designed to provide similar curing performance and color stability while meeting EU compliance standards.
One professional brand, ProNails, had already transitioned to 100% TPO-free products prior to the ban and offers guidance to nail technicians navigating the transition.
Health and Safety – Beyond TPO
Experts continue to highlight other risks associated with gel manicures, beyond chemical exposure. Dermatologists and podiatrists point to potential issues related to UV exposure from curing lamps, nail thinning, and the risk of bacterial infections such as Pseudomonas aeruginosa, which can turn nails green and pose health risks if left untreated.
Many professionals now recommend spacing out gel appointments, prioritizing well-ventilated salons, and using protective base coats to reduce cumulative exposure.
TPO Ban Does Not Extend to the United States
While Europe has taken a firm regulatory stance, the United States remains unregulated regarding TPO. Gel nail polish products containing TPO continue to be sold and used freely in American salons, though TPO-free brands, such as OPI’s Intelli-Gel, Aprés Nail, Manicurist, Nail Creation, and Aimeili, are available to consumers seeking safer alternatives.
This divergence underscores the broader regulatory philosophy gap between the U.S. and EU: where the EU prioritizes precaution and hazard-based bans, U.S. regulation tends to emphasize established human risk as a threshold for action.
