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Ban on TPO in cosmetic products: what the regulations say

Sofia Labarsouque

3 min

This ban follows the publication, in May 2025, of Regulation (EU) No 2025/877, known as "Omnibus VII," amending Regulation (EC) No 1223/2009 on cosmetic products, with regard to the use of certain substances classified as carcinogenic, mutagenic, or toxic to reproduction (CMR). Within this framework, several substances are regularly subject to bans or restrictions to take into account new available scientific data.

Since September 1, 2025, the European Union has officially banned the use of Trimethylbenzoyl Diphenylphosphine Oxide (TPO) in all cosmetic products, including semi-permanent nail polishes and UV gels.

What is TPO?

TPO, or trimethylbenzoyl phosphine oxide (INCI: Trimethylbenzoyl Diphenylphosphine Oxide, CAS 75980-60-8), is a photoinitiator used in certain cosmetic products, particularly:

• Gel polishes and semi-permanent nail polishes,

• Builder or top coat gels for nails.

This substance allows for the rapid polymerization of gels under UV or LED lamps, ensuring effective hardening and a glossy finish.


Why this ban?

The decision to ban TPO is based on a European toxicological classification:

• TPO has been classified as a CMR substance, category 1B (toxic to reproduction).

• According to European Cosmetics Regulation (EC) No. 1223/2009, any substance classified as CMR (carcinogenic, mutagenic, or reprotoxic) category 1A or 1B is automatically prohibited in cosmetic products, except in exceptional circumstances – but none has been granted for TPO.


Since when?

As of September 1, 2025, the use of TPO in all cosmetic products is strictly prohibited in all European Union countries, without any grace period or stock depletion period.

This means that:

• The marketing and sale of products containing TPO are prohibited,

• Their professional use (salons, nail salons, beauty institutes) is also prohibited; even products already in stock can no longer be made available or used.


Consequences for manufacturers and distributors

Brands must:

• Immediately withdraw all products containing TPO from the market,

• Ensure that future formulas no longer include this substance,

• Update technical data sheets and INCI lists.


In conclusion

TPO has been banned in all cosmetic products in the EU since September 1, 2025.

This stems from its classification as a CMR 1B substance (toxic to reproduction), which results in its inclusion on the list of prohibited substances in the cosmetics regulation.

No transition period has been granted: even existing stocks can no longer be used or sold in the cosmetics industry.

Given the numerous questions raised by this ban, the European Commission has published a series of answers to frequently asked questions on its website (TPO in Nail Products – Questions & Answers – Internal Market, Industry, Entrepreneurship and SMEs).