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EVERYTHING YOU NEED TO KNOW ABOUT TPO IN NAIL PRODUCTS


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?

Until 01/09/2025, you can 100% still use your products.

What happens to your existing stock after this date has not yet been formally defined, because the regulations don’t clearly state what should happen after a reclassification. According to Article 31 of Regulation (EC) No 1223/2009 (Amendments to the Annexes), the European Commission may amend the annexes if there is a public health risk, but it does not specify what must happen to products already on the market at the time of such a change. This creates legal room for interpretation and uncertainty about existing stock. Hence the cautious wording in official communications about usage after 1 September 2025.

There are two possible scenarios:

  • Use-up allowed: Similar to other bans (e.g. medicines containing pseudoephedrine, which are no longer freely available and now require a prescription in Belgium and other EU countries), sales were banned but home use was not. No recall was required. Most people just used up what they had. In the same way, it is assumed that nail techs may still use products purchased before 1/9. Please note: this is only an interpretation – there is no official confirmation yet.
  • Use banned: It is possible that you, as a professional, will no longer be allowed to use TPO-containing products after 01/09/2025. In that case, you would need to remove them from your salon. Whether this will actually be enforced depends on how strictly national inspectors interpret the ban. As soon as there is official clarity, we will communicate this immediately.


6. What can you do?

First of all: don’t panic. We understand it can be a shock to suddenly think you have to throw everything away. But rest assured: many of the products in your cabinet may already be TPO-free without you knowing it.

If you want to prepare for scenario 2 – a full ban on use by nail technicians – it’s best to start by taking inventory.

Check your products one by one, and use the list of synonyms to identify which ingredients indicate the presence of TPO. Mark what contains TPO so you can use those up first. Do you have a favourite base coat that’s TPO-free and five bottles of another base that does contain TPO? Use up the five first, and save your favourite for after 1/9. Is your go-to colour running low and not yet TPO-free? Then feel free to buy a new bottle, as long as you’re sure you’ll finish it before 1 September.

Not comfortable with that, because safety is your top priority? Then it’s perfectly okay to decide now to discard all products that still contain TPO.

But again: if you work safely and plan usage wisely as outlined above, we believe there is no immediate danger.


7. What is Nagelcentrum Marjolijn doing?


  • On product level: If a product may contain TPO, we manually verify it and indicate this clearly below the product image using one of the following labels: “Contains (still) TPO” or “TPO-free”. 

Does your favourite product still mention that it contains TPO? Don’t worry – in 99% of cases, it will return in a TPO-free version without any loss of quality. All brands are actively working on replacements.

If there’s no label yet and the product cures under UV light: that’s possible. We’re still in the process of checking our full range. The presence of TPO depends on the production date, so ingredient labels may differ.

Not sure about a specific product? Feel free to email us – we’ll look it up for you right away.

  • On page level: You can now filter TPO-free products on each catalogue page. We’re gradually adding this information at individual product level as well.



8. Why only now?

Many people might be wondering why this is only becoming an issue now, just three months before the ban takes effect. The answer is: manufacturers and distributors have been working on this for quite some time. They have been gradually adjusting their formulas as older batches ran out.

That may sound simple, but in reality, it’s not. It required finding alternative ingredients that deliver the exact same performance without compromising on quality. And although some names might look similar on paper, the actual substance can have a significant impact on product performance and stability.

Nobody wants to notice a change in their favourite rubber base or that one go-to colour clients keep asking for. Multiply that by a range of 300 to 800 products, and you’ll understand why 18 months is actually not that long.

Moreover, many producers and distributors assumed – based on earlier regulations (such as the pseudoephedrine case mentioned above) – that products sold before 1/9/2025 could still be used up by the end user, i.e. the nail technician. That’s why the past few months were also used to deliberately put remaining stock on sale – not to mislead, but for financial reasons and to avoid waste.

But since May, unexpected inspections have started at salons by the Belgian FPS Public Health. During these visits, it was communicated that the ban would also apply to the end user. That changes everything.

At the moment, manufacturers and distributors are: 

  • Working to obtain an official and clear statement from the government or EU authorities 
  • Proactively requesting a 6-month grace period, should the ban also apply to professionals, to allow nail techs time to use up their stock 

On the recommendation of Unizo, we’ve launched a petition with one clear demand: allow for a minimum 6-month transition period for the use of nail products containing TPO. This would give the sector time to adapt to the new rules, helping to reduce both waste and financial loss.  

📎 TPO in nail products: 1/09 is too soon! Join the call for a fair transition – online petition


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
  • Sales ban effective from 1 September 2025
  • Use after that date remains unclear – using up existing stock may be allowed, but not officially confirmed


The overview below helps you quickly see which products in our range are guaranteed to be TPO-free (based on the most recent data from manufacturers and batch analyses).

The GelBottle

BIAB™:
– Sheer Collection
– Pastel Collection
– All-in-One BIAB™
– HEMA-vrije BIAB™

Overige:
– 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)


We are gradually adding this information at individual product level as well. (based on the most recent data from manufacturers and batch analyses).