What is TPO & why is it being banned from nail products?

By Helena Biggs | 02 September 2024 | Movers & Shakers, News, Products & Treatments

Hand In Gel Lamp Tpo Article

You may have noticed a social media frenzy surrounding Trimethylbenzoyl Diphenylphosphine Oxide (TPO), but why is it important for the nail industry to take note?

TPO is a photo initiator that helps gel products to cure quickly under UV light. It can be found in concentrations of up to 5% in artificial nail systems and can also be used to maintain colour stability – but the European Commission is banning its use from 1 September 2025 (EU) and late 2026 (Great Britain).

It’s the European Commission’s duty to ensure that cosmetics and personal care products sold in the EU are safe for use, and companies (as well as national and European regulatory authorities) have a responsibility to adhere to its rules.

So why is the ban being introduced?

Francesca Rapolla Ctpa

Francesca Rapolla, scientific affairs manager at The CTPA

Francesca Rapolla, scientific affairs manager at The Cosmetic, Toiletry & Perfumery Association (CTPA), comments: “TPO received a harmonised classification as a Carcinogen, Mutagen, Reprotoxic (CMR) category 1B, under the EU Classification, Labelling and Packaging (CLP) Regulation. Article 15 of the EU Cosmetics Regulation prohibits the use of CMR substances in cosmetic products unless specific exemption criteria are met.

“An industry can voluntarily defend continued use of cosmetic ingredients that receive a harmonised classification as a CMR under EU CLP, by submitting thorough safety dossiers that meet the specific exemption criteria of Article 15 of the EU Cosmetics Regulation.

“In the case of TPO, the industry did not, and could not, defend the continued use of this ingredient in nail products, mainly because it could not demonstrate that there are no alternative ingredients to this one. Therefore, TPO is going to be prohibited for use in cosmetics.”

The EU ban commences on 1 September 2025, and in Great Britain, which received the same mandatory classification, the ban is expected to follow in 2026.

What does this mean for nail products and manufacturers?

Doug 20201

Doug Schoon, a leading scientist & advisor to the nail industry

“The removal of TPO from nail products doesn’t necessarily impact their performance, but they will require reformulation,” shares Doug Schoon, a scientific expert in the nail industry and founder of Schoon Scientific. “When used improperly and skin contact is not avoided, TPO can cause skin sensitisation or allergic reactions in some individuals. However, adverse effects are rare when products are applied correctly by trained professionals.

“Most of the concern over this ingredient involves using TPO in other applications that are not related to nail coatings, such as workers in factories that manufacture printing inks and industrial adhesives.

“Removing TPO from nail coatings is not in response to problems with nail products containing this ingredient, but rather as precautionary approach to consumer safety.”

Francesca comments: “Products containing TPO must be off shelf by 1 September 2025 in the EU and approximately Q4 2026 in GB.  The responsible person placing on the market the nail products will have to ensure compliance – meaning that no products containing TPO are supplied by these dates, as well as provide products which are reformulated not to contain TPO.”
Doug adds: “Brands can support this transition by reformulating products with safer photo initiators, providing education on proper application techniques for new formulas, and by clearly labelling TPO-free options.”
It is likely that nail brands will be working, or have already launched, products with alternative ingredients to TPO that replicate its function, but it is the responsibility of the nail professional to ask questions to their product supplier. These answers may be required if clients ask for clarification, or if there are any different methods of application for reformulated products.

Action points for nail professionals

Nail professionals can check the SDS or labels of their products to identify whether they include Trimethylbenzoyl Diphenylphosphine Oxide. Francesca comments: “Suppliers may be able to offer advice on how to manage any left-over stock if applicable, or any orders of new stock in preparation of the deadlines,” she shares. “Nail professionals may also wish to liaise with their product suppliers to understand if or how the reformulated products may perform differently from those containing TPO.

“It is important to highlight that nail products containing TPO do not suddenly become unsafe for use on consumers.”

“The CMR classification of TPO and the ban in the EU, and expected in Great Britain, is based on the hazardous properties that a substance might have under a ‘worst case’ situation, and does not take account of whether there is any risk associated with specific uses or exposures.”

Francesca continues: “Nail professionals and consumers who have used nail products that contain TPO, can be reassured that these products are still safe to use until the end of the transition period, when they will no longer be available. These products will have undergone a rigorous safety assessment by an expert safety assessor to ensure their safe use.”

Notes from nail brands

A number of nail brands have taken to social media to reassure clients prior to the impending bans. Here’s what they have to say:

Tgb Ifra Siddique

Ifra Siddique, compliance director at The GelBottle Inc

“I believe the regulatory changes surrounding TPO are a positive step for the cosmetics industry,” shares Ifra Siddique, compliance director at The GelBottle Inc. “These updates reflect our ongoing commitment to maintaining the highest safety standards and ensuring consumer wellbeing. Regulatory updates like these are becoming more common and are now standard procedure, helping to keep the industry safe and trustworthy for everyone.

“At The GelBottle Inc, we are in regular contact with these governing bodies and expect these changes, embracing them as opportunities to educate our customers transparently. We have been working on exciting new and improved formulas without TPO, which are already showing extremely positive test results.”

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Michael Henson, founder/director at HONA

HONA has anticipated these regulatory changes and has already excluded TPO from its formulations,” comments Michael Henson, founder/director at Home Of Nail Art (HONA). “When the ban comes in to place, review the Safety Data Sheets (SDS) of the products you use to identify any presence of TPO and ensure you no longer are using products with the ingredient included. With the ban approaching, transitioning to products that comply with the regulations will be essential, but by then I assume most affected nail products will be reformulated.”

Dave Partridge Nailchemy

Dave Partridge, director at Nailchemy

“There is no risk to using products that still contain TPO, as the health concern was linked to ingesting the pure chemical,” shares Dave Partridge, director at Nailchemy. “It’s already limited to <5% in all cosmetics, so poses no real risk. All of the Nailchemy HEMA-free products are already TPO-free, and we are reformulating all remaining products to make them TPO free well ahead of the changes, so you can use your existing products without loss.”

Do you have any more questions about the TPO ban? Contact us at editorial@scratchmagazine.co.uk