Ban of TPO in artificial nail products
Topic: TPO prohibited in cosmetic products

Date of ban application: 1 September 2025

The European Commission has published comprehensive Q&A guidance addressing industry concerns about the prohibition of Trimethylbenzoyl Diphenylphosphine Oxide (TPO) in cosmetic products, clarifying enforcement requirements and providing actionable guidance for manufacturers, distributors, and nail professionals following the 1 September 2025 ban.

Background

The prohibition of Trimethylbenzoyl Diphenylphosphine Oxide (TPO) stems from TPO’s mandatory inclusion in Annex II (prohibited substances) of the Cosmetics Regulation after its classification as a CMR category 1B reproductive toxicant under Commission Delegated Regulation (EU) 2024/197. This classification, effective from 1 September 2025, automatically triggered the cosmetic prohibition under Article 15 of Regulation (EC) No 1223/2009, with 25 EU Member States voting in favour, 1 against, and 1 abstaining.

What’s new?

Following significant industry queries regarding Commission Regulation (EU) 2025/877 prohibiting TPO in cosmetic products from 1 September 2025, the European Commission has released detailed Q&A guidance to ensure consistent enforcement across all EU Member States.

What now?

  • From 1 September 2025 – Complete ban on placing on the market and making available TPO-containing cosmetic products
  • No transitional period – Both new products and existing stock cannot be sold or supplied commercially. All TPO-containing inventory must be removed from commercial premises
  • Manufacturers – Cannot place new TPO-containing products on EU market
  • Distributors and retailers – Cannot sell or supply TPO products regardless of inventory purchase date
  • Professional use prohibition – Nail technicians and salons cannot use TPO products on clients, regardless of purchase date. Must immediately discontinue use of all TPO-containing products in commercial services.

References

European Commission. (2025, August 7). TPO in Nail Products – Questions & Answers.

Commission Regulation (EU) 2025/877 of 13 May 2025 amending Annexes II, III and VI to Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products. Official Journal of the European Union, L 2025/877.

Commission Delegated Regulation (EU) 2024/197 under Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures.

other REGULATORY UPDATES

Italy and France – Environmental Labelling of Cosmetic Products

PACKAGING WASTE MANAGEMENT

Date of application:01/01/2023

Although the European Cosmetics Regulation is applicable to every cosmetic product made available in the European Union market, some national legislations may also apply. Environmental regulations in Italy and France specify mandatory labelling requirements applicable to packaged products marketed in these countries.

Read More »

Regulation (EU) 2022/692 – OMNIBUS ACT VI – New and Updated Classification of Cosmetic Ingredients

Ingredients: BENZOPHENONE, TEOPHYLLINE, MELAMINE, AZADIRACHTA EXTRACTS, TRIMETHYLOLPROPANE TRIACRYLATE, PENTETIC ACID, PENTASODIUM PENTETATE

Date of publication: 03/05/2022

Date of application: 01/12/2023

The Commission Delegated Regulation (EU) 2022/692 includes new or updated classification for 12 chemicals that may be used as cosmetic ingredients. Seven out of these 12 are now classified as carcinogenic, mutagenic or toxic to reproduction (CMR) and are banned from cosmetic products marketed in the EU.

Read More »
Any REGULATORY QUESTION?