Is TPO Banned in Cosmetics? Gel Nails & The 2026 Rules

If you make or sell gel nail products, you have probably heard that TPO is being banned and it is, in both the EU and the UK, but on different dates. TPO is a common photoinitiator in UV-cured gels, so this change affects a lot of nail brands and technicians. This guide explains what TPO is, why it is banned, and what you need to do.

This is one of the most practically important 2026 changes; for the full set, see our pillar guide to cosmetic regulation changes in 2026.

What is TPO?

TPO chemically diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide is a photoinitiator: an ingredient that starts the curing (hardening) reaction when a gel product is exposed to UV or LED light. It has been widely used in UV-cured gel polishes, builder gels and similar nail products, where it helps the product set quickly and firmly under a lamp. Its effectiveness made it a common choice across the gel-nail sector.

Because it is used specifically to make light-cured products work, TPO turns up across many gel formulations rather than in skincare or general cosmetics. That concentration in one product category is why its ban lands so heavily on nail brands in particular.

Why is TPO being banned?

TPO has been classified as a CMR substance specifically as toxic for reproduction under the chemicals classification system. Under both EU and UK cosmetic law, once a substance carries such a CMR classification, it is generally prohibited in cosmetics unless a specific exemption is granted. No such exemption kept TPO on the market, so it moved to the banned list in both jurisdictions.

It is worth being clear that this is a hazard classification-driven ban, following the standard rule that CMR classified substances come out of cosmetics. It is not a comment on any single brand's product but a blanket regulatory change affecting every product that uses the substance.

The EU ban date

In the EU, TPO was prohibited from 1 September 2025, as part of an earlier CMR-driven amendment (Omnibus VII). From that date, gel products containing TPO could no longer be placed on the EU market. EU and Northern Ireland nail brands therefore needed to move to TPO free formulations earlier than their GB counterparts.

This makes TPO a clear example of the EU and UK diverging on timing: the same substance, banned for the same reason, but with the EU acting roughly a year ahead of Great Britain.

The UK ban date

In Great Britain, TPO is among the CMR substances banned under SI 2026/23, with placing on the market prohibited from 15 August 2026 and a sell through period for compliant existing stock to 15 February 2027. So GB nail brands had until mid-August 2026 to stop placing TPO products on the market, with a window into early 2027 to clear stock already out there.

As always, Northern Ireland follows the EU position rather than the GB one. A brand selling across the UK and EU therefore had to manage the earlier EU date and the later GB date together see our UK 2026 changes guide for the surrounding deadlines.

What nail brands and technicians should do

The core action is to move to TPO-free formulations. Many suppliers have reformulated gel products using alternative photoinitiators, so the practical step is to confirm with your supplier that the products you sell or use are TPO-free, and to obtain updated documentation proving it. If you manufacture your own gels, you need to reformulate and have the new formula assessed.

Technicians and salons should check their existing stock and their suppliers' status, mindful of the relevant sell-through dates. Selling or using up old TPO containing stock beyond the permitted date is not compliant, so it is worth confirming where each product stands rather than assuming a familiar product is still allowed.

Reformulation and your CPSR

Switching out TPO is a formulation change, and like any such change it ripples through your compliance. A new photoinitiator means the product's safety has to be re-evaluated, the CPSR and PIF updated, the ingredient list and any warnings revised, and the notification refreshed. A gel that is TPO-free but still documented under its old formula is not properly compliant.

Nail products also carry their own safety considerations around curing, skin contact and sensitisation, so the reassessment is not a formality. Getting the updated formula properly assessed protects both your customers and your compliance, and is exactly the kind of work your safety assessor handles for your CPSR.

What 'TPO-free' really means

As the ban approached, “TPO-free” became a common label on gel products but it is worth understanding what it should mean. A genuinely TPO free product has replaced TPO with an alternative photoinitiator that is itself permitted, and has been reassessed as a new formulation. It is not enough for a product to simply drop TPO from its marketing while the underlying formula or documentation is unclear; the replacement has to be compliant and the safety paperwork has to reflect the actual recipe.

For brands buying in gel bases or finished products, this means asking suppliers for more than a reassuring word. Request updated ingredient documentation showing the new photoinitiator and confirming the absence of TPO, and make sure your own CPSR and labelling match what you are actually selling. “Trust me, it's TPO free” is not evidence; a current specification is.

It is also worth remembering that swapping one photoinitiator for another can subtly change how a product cures and behaves, so the reassessment is not just a paperwork exercise. Nail products involve real safety considerations around curing, skin contact and sensitisation, and a reformulated gel deserves the same careful safety assessment as a new product because, in compliance terms, that is what it is.

TPO ban checklist

• Confirm whether your gel products contain TPO.

• Note the EU date (1 Sep 2025) and GB date (15 Aug 2026).

• Move to TPO-free formulations with your supplier.

• Obtain updated documentation proving TPO-free status.

• Check existing stock against sell-through deadlines.

• Update your CPSR, PIF, labelling and notification after reformulation.

Frequently asked questions

Is TPO banned in cosmetics?

Yes. TPO is classified as a CMR substance and is banned in cosmetics in the EU from 1 September 2025 and in Great Britain from 15 August 2026, with a GB sell-through period to 15 February 2027.

What is TPO used for?

It is a photoinitiator that triggers curing when UV cured gel nail products are exposed to a lamp. It has been widely used in gel polishes, builder gels and similar products.

Why is TPO banned?

It has been classified as toxic for reproduction (a CMR substance). Under EU and UK cosmetic law, CMR-classified substances are generally prohibited in cosmetics unless specifically exempted.

What should nail brands do about the TPO ban?

Move to TPO-free formulations, confirm and document this with suppliers, check existing stock against the sell-through dates, and update the CPSR, PIF, labelling and notification for any reformulated product.

Do the EU and UK have the same TPO deadline?

No. The EU banned TPO from 1 September 2025, while Great Britain bans it from 15 August 2026. Northern Ireland follows the EU date under the Windsor Framework.

How do I know if my gel products are TPO-free?

Ask your supplier for updated ingredient documentation showing the replacement photoinitiator and confirming no TPO, and make sure your own CPSR and labelling match the actual formula. A current specification is the evidence not a verbal assurance.

Does switching from TPO need a new safety assessment?

Yes. Replacing the photoinitiator changes the formulation and can alter how the product cures, so the reformulated gel should be reassessed and its CPSR, PIF, labelling and notification updated.

References: Commission Regulation (EU) 2025/877 (Omnibus VII); The Cosmetic Products (Restriction of Chemical Substances) Regulations 2026 (SI 2026/23); GB CLP Regulation; CTPA guidance on TPO. General information only, not legal advice; verify current requirements for your products.