Nail Products and Gel Nails: Compliance and the TPO Ban

Nail products gel nail polish, gel nail products and artificial nail systems face their own compliance issues, most topically the ban on TPO, a photoinitiator widely used in UV-cured gels, now prohibited in the EU. This guide explains nail products compliance, the TPO ban and what it means, and the wider considerations for this category. Confirm current detail, as the TPO position differs by market and continues to evolve.

Nail products are cosmetics with specific ingredient issues, and TPO is a recent, significant example of the CMR-driven bans reshaping formulations. Here we cover the category.

Nail products are cosmetics

Nail products nail polish, gel polish, artificial nail systems (acrylics, gels), base and top coats, treatments and removers are cosmetics, as the nails are part of the external body. So they are subject to the cosmetics regulation like any other product, with CPSR, PIF, notification and labelling, plus the specific ingredient considerations that arise in nail formulations.

Nail products do, however, involve some distinctive ingredients solvents, resins, and, in UV-cured products, photoinitiators that trigger the curing process under a lamp. These specific ingredients are where much of the nail-product-specific regulatory attention falls, including the TPO issue and the well-known acrylate sensitisation concern.

The (meth)acrylate sensitisation issue

A significant, well-documented issue in gel manicures and acrylic nails is (meth)acrylate sensitisation. The (meth)acrylate monomers used in these systems can cause allergic sensitisation, particularly when uncured or improperly cured product contacts the skin a real route of exposure with poor application or some home kits. Once sensitised, a person can react to these substances, sometimes significantly.

This is a genuine safety concern that has attracted attention, especially with the growth of at-home gel kits. It reinforces the importance of proper formulation, clear instructions, and appropriate use uncured monomer reaching the skin is the core risk. Nail brands should be mindful of this sensitisation issue in how their CPSR addresses formulation and use guidance, whether intended for professional use or home application.

What is TPO, and why is TPO now banned?

The headline recent development is the ban on TPO (Trimethylbenzoyl Diphenylphosphine Oxide, more precisely diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide), a photoinitiator used in many UV-cured gel products to help them cure under ultraviolet (UV) light. TPO was reclassified as a Category 1B reproductive toxicant CMR substance, which under the chemical regulation rule prohibiting CMR substances triggered its prohibition in cosmetics. It has moved from the restricted list to the banned list.

In the EU, this ban applies from 1 September 2025, with no transition period and no exceptions granted from that date products containing TPO cannot be placed on or made available on the market, meaning existing stock must be removed too. It is a hard, immediate ban. Importantly, it does not ban gel polish generally only TPO-containing products, as TPO-free alternative photoinitiators exist.

TPO across markets

The TPO position differs by market. The EU ban (from September 2025) applies across the EU member states, and also Norway and Switzerland. Great Britain has addressed TPO through its own instrument on its own timetable, rather than automatically at the same time as the EU so the GB position and timing should be confirmed specifically. Other markets, such as the US, had not banned TPO federally, though positions can change.

So a brand selling nail products across markets must check TPO's status in each market: banned in the EU from September 2025, addressed in GB via its own measure, and potentially still permitted in some other markets. This is another example of ingredient rules differing across markets and requiring market-by-market attention. Our UK SI 2026/23 guide covers the GB instrument among other changes.

What the TPO ban means for brands

For nail brands, the TPO ban means concrete action: identify any products containing TPO; reformulate them with an alternative, TPO-free photoinitiator for markets where TPO is banned; ensure existing TPO-containing stock is removed from banned markets by the deadline; and update the PIF, CPSR and notifications for reformulated products. This is a real, time-sensitive exercise for affected nail brands.

The TPO ban is a clear illustration of how a Category 1B reproductive toxicant classification can rapidly remove a widely-used ingredient from the market, requiring reformulation this specific ban was introduced through Commission Regulation (EU) 2025/877, part of the EU's periodic "Omnibus" update to Annex II. Nail brands using TPO must act, and the episode underscores the value of monitoring ingredient classifications to anticipate such changes.

The professional-consumer divide in nails

Nail products span a professional-consumer divide that matters for safety and compliance. Some products are designed for professional use by trained nail technicians in salons, with proper equipment and technique, while others are consumer products for home use, including home kits. The (meth)acrylate sensitisation risk in particular is affected by how well products are applied and cured under a lamp, which differs between these contexts.

The rise of at-home gel kits has brought professional-style products to consumers, which raises the importance of clear instructions and appropriate formulation. A consumer curing gels at home without professional technique may be more exposed to uncured monomer the core sensitisation route of exposure so products for home use need particularly clear guidance on proper application and curing under UV light.

Brands should be clear about intended use and ensure products, instructions and warnings suit that context. A product intended for professional use carries different assumptions than one for untrained consumers, and formulating and instructing accordingly is part of responsible nail product design. Matching the product and its guidance to the real user is important in this category.

The TPO ban cuts across both professional and consumer nail products any TPO containing gel, whether salon or home, must be reformulated for markets where TPO is banned. So the reformulation task applies across the divide, and brands serving both professional and consumer nail markets must address TPO in all affected products. The ban does not distinguish by user context.

Overall, nail products reward brands that understand the professional-consumer divide, manage the sensitisation risk through good formulation and clear guidance, respond properly to the TPO ban, and match products to their intended users. It is a category with real, specific safety considerations sensitisation and, now, the CMR-driven TPO ban that a diligent brand can navigate to produce safe, compliant nail products across both professional and consumer contexts.

Nail products at a glance

Frequently asked questions

References: Regulation (EC) No 1223/2009 (Article 15; Annexes II and III); Commission Regulation (EU) 2025/877 (TPO added to Annex II, applying 1 September 2025); UK Cosmetics Regulation as retained. Verified July 2026; TPO status differs by market — confirm current detail. General information only, not legal advice.