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EVERYTHING YOU NEED TO KNOW ABOUT TPO IN NAIL PRODUCTS


UPDATE – 01/09/2025

As previously announced, today – 1 September 2025 – the formal ban on the use of TPO (Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide) in cosmetic products has officially entered into force across the EU.

However, that does not automatically mean that everything is legally watertight.

Although the ban has been formally adopted into EU legislation, there are still serious questions about whether the process by which it was introduced was handled correctly.


Many professionals, legal experts and industry stakeholders are raising valid concerns regarding:

– The sudden reclassification of TPO

– The lack of clear and timely communication from EU and Belgian authorities

– The absence of official guidelines regarding existing stock already in circulation

– The complete lack of a transitional period or reasonable deadline to phase out products


➡️ A regulation only has real legal weight when it is properly drafted, introduced, and communicated. That was clearly not the case here.

➡️ Both procedural and substantive mistakes have been made, and it remains to be seen whether this ban will ultimately hold up legally.


That said: for anyone who wishes to avoid risk, it is safest to comply with what is currently being treated as “the law.”

That’s why we are adapting our operations accordingly.


🛒 What does this mean for our webshop?

As of 1 September 2025, the following changes apply:

✅ Our entire webshop is now 100% TPO-free: All products you buy from us comply with current EU legislation.

🚫 The labels “TPO-free” or “Contains (still) TPO” will no longer be used: Since TPO is now banned, such claims are no longer legally allowed as marketing terms.All products must now be TPO-free – full stop.

🤔 So if you don’t see this label anymore, it’s not a mistake – it’s because EU law no longer allows us to use it.


1. What is TPO?

TPO stands for Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide, a chemical compound used as a photoinitiator in nail products such as gel polish and builder gels.

A photoinitiator, as the name suggests, initiates the curing process under UV light. Without it, the product would remain liquid. It’s logical that TPO is only found in products that cure under a lamp.

TPO can therefore be present in: Top coats, Base coats, Builder gels, Gel polish, Paint gel, 3D gel, Chrome gel etc. (this list is not exhaustive). TPO cannot be present in: Nail polish, Prep, Primer, Bonder, Cleanser, Glitters etc. (this list is not exhaustive).

Important technical info

Official name: Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide

CAS number: 75980-60-8 (commonly referenced in regulations and databases like ECHA).

TPO may appear on labels under more than 100 synonyms, about 40 of which are commonly used in nail products. Examples include:

  • (diphenylphosphoryl)(2,4,6-trimethylphenyl)methanone
  • (diphenylphosphoroso)(2,4,6-trimethylphenyl)methanone
  • Phosphinoxid, diphenyl-, (2,4,6-trimethylbenzoyl)-
  • (diphenylphosphorus)(2,4,6-trimethylphenylmethanone)
  • Phosphine oxide, diphenyl(2,4,6-trimethylbenzoyl)- (9CI)
  • Diphenylphosphoryl-(2,4,6-trimethylphenyl)methanone
  • 2,4,6-Trimethylbenzoyldiphenylphosphine oxide

You can find the full list and more info here (EN version): https://chem.echa.europa.eu/100.071.211/overview?searchText=Trimethylbenzoyl%20Diphenylphosphine%20Oxide

There are also other substances with similar names that are not the same TPO being restricted. Be mindful of this. For example:

  • Phenyl bis(2,4,6-trimethylbenzoyl)-phosphine oxide
  • Ethyl phenyl(2,4,6-trimethylbenzoyl)phosphinate
  • Methyl phenyl(2,4,6-trimethylbenzoyl)phosphinate
  • Bis(2,4,6-trimethylbenzoyl) octyl phosphine oxide
  • Lithium phenyl-(2,4,6-trimethylbenzoyl)phosphinate
  • Acetic acid, 2-[bis(2,4,6-trimethylbenzoyl)phosphinyl]-, methyl ester

If any of the above appear on your label: this is not TPO with CAS number 75980-60-8 and is not banned. Not sure? Feel free to ask, or compare with the ECHA list.


2. What has changed in the law?

In Regulation (EC) No 1272/2008 on classification and labelling of substances, TPO was classified until 19 October 2023 as Repr. 2 ("Suspected of damaging fertility", code H361f).

But since Delegated Regulation (EU) 2024/197 of 5 January 2024, this has changed to Repr. 1B ("May damage fertility. Suspected of harming the unborn child", code H360Fd) and Skin Sens. 1B ("May cause an allergic skin reaction", code H317). See link, Annex II, Table 2, Line 3.

Does this mean TPO is harmful? Legally, yes. In my personal opinion: not necessarily, if used correctly and professionally. That means: not on damaged or overly thin natural nails, not in contact with skin, and always cured properly under adequate lamps. But I am not a scientist.


3. What are the consequences from a legal point of view?

Due to this reclassification from Repr. 2 to Repr. 1B, TPO now falls under the list of banned substances in cosmetics, as laid down in Regulation (EC) No 1223/2009. Article 15 states: "The use in cosmetic products of substances classified as CMR category 1A or 1B in part 3 of Annex VI to Regulation (EC) No 1272/2008 shall be prohibited."  See link, Article 15, point 2.

Indeed, according to Delegated Regulation (EU) 2024/197 of 5 January 2024, TPO is now classified as category 1B in part 3 of Annex VI to Regulation (EC) No 1272/2008.

Now that it has been reclassified to Repr. 1B, it may no longer be used in cosmetics – not even for professional use. (Previously, under Repr. 2, it was also prohibited, but exceptionally allowed if the concentration was below 5% and the SCCS had been consulted.)


4. What does this mean in practice?

From 1 September 2025, products containing TPO may no longer be sold within the EU. So from that date, you will no longer find TPO-containing products from any distributor in the European Union.

Until then, distributors are still allowed to sell these products.


5. What does this mean for you as a nail professional?

Since 1 September 2025, the use and sale of TPO in cosmetics is officially banned.

However, serious legal doubts remain about how this ban was introduced. The process and communication from both the EU and Belgium have raised significant concerns.

What are your options?

1. You follow what is currently considered ‘the law’: You only work with products that are confirmed to be TPO-free. No risk, fully in line with current rules – even if the legal basis remains questionable.

2. You continue using your older stock: You decide to keep using products purchased before 1 September. You are formally breaking the current regulation, but you do so based on serious doubts about its legal validity. The risk is yours.

3. You wait it out: You remove the products from your salon but don’t throw them away. If clarification or a change comes later, you’ll be prepared.


6. What can you do?

Just starting to check your stock now? Don’t panic. Many products in your collection are likely already TPO-free – even if you didn’t realise it.

Go through your products one by one: Check the ingredients list or MSDS. If you see CAS number 75980-60-8, the product contains banned TPO.

Don’t throw everything out immediately. Not sure? Set it aside. If clearer rules or an exception period is announced, you won’t have wasted anything. 

If you prefer to discard it all out of caution, that’s perfectly fine too.


SUMMARY

  • TPO is a photoinitiator found in products that cure under UV light
  • TPO has been reclassified as Reprotoxic 1B and is therefore banned in cosmetics
  • Sale and use are prohibited as of 1 September 2025
  • The legal basis of the ban remains questionable due to poor communication and lack of clear guidance


The overview below helps you quickly see which products in our range are guaranteed to be TPO-free before 01/09/2025

The GelBottle
– BIAB™ Sheer Collection
– BIAB™Pastel Collection
– All-in-One BIAB™
– HEMA-vrije BIAB™– Rubber Base
– Alle top coats (with exception of Extreme Shine)
– Gel Polish (all colours)

MIDA

– Gel Polish (all colours)
– Alle Top Coats (except Milky, Pink and Expert Pro)
– Soft Gel
– Hard Gel
– Candy Gel
– Fluffy Gel
– Gres Gel

DNKa'

– Gel Polish (all colours)
– Cover Bases (all colours)
– Bases (except Low Acid)

NeoNail

– Gel Polish from Blooming Dreams Collection on (Spring 2025)