TPO in Nail Products | New Data 2026
Written by Amber Mooney. Nail educator and technician with 10 years of professional experience. Amber works with Kohana Professional to develop educational content for nail technicians across Ireland.
TPO was banned in EU cosmetics on 1 September 2025. If you are a nail technician working in Ireland, that ban applies to you right now. No transitional period, no grace period for stock already on your shelf. The rule is in force, and the products it covers can no longer be sold, supplied, or used professionally.
There has been a lot of drama around this online, and honestly most of it has not helped anyone. Headlines screaming that gel polish is "banned" sent clients into a panic that was completely unnecessary, and a lot of commentary from outside the EU made the situation more confusing than it needed to be. So let us be clear about what is actually happening and what it means for your salon.
What Is TPO and What Does It Do?
TPO stands for Trimethylbenzoyl Diphenylphosphine Oxide. It is a photoinitiator — the ingredient inside a gel product that triggers polymerisation when exposed to UV or LED light. No photoinitiator means no cure.
TPO became popular in professional nail products because it works across a wide range of UV wavelengths, making it compatible with most lamps, and it does not cause yellowing in the finished, cured product.
Gel polish is not banned. UV nail products are not banned. TPO specifically is prohibited. Those are not the same thing, and the distinction matters every time a client comes in having read something alarming on social media.
Why Was TPO Prohibited in the EU?
Under EU cosmetics law, any substance classified as CMR category 1A or 1B (carcinogenic, mutagenic, or reprotoxic) is automatically prohibited in cosmetic products unless a specific derogation is applied for and granted.
TPO was reclassified as a CMR category 1B reproductive toxicant under EU Delegated Regulation 2024/197. That classification triggered its inclusion in Annex II of the Cosmetics Regulation — the list of prohibited ingredients — via Regulation EU 2025/877. It came into force on 1 September 2025, with 25 of the 27 EU member states voting in favour.
The science behind this is genuinely contested. The animal studies that drove the reclassification involved feeding rats high doses of TPO orally — nothing to do with how a nail technician encounters it. In a gel manicure, TPO is substantially consumed during polymerisation, so the amount remaining in a fully cured product is negligible. The nail plate itself is far less permeable than skin. Industry scientists, including Doug Schoon, wrote directly to the European Commission arguing the reclassification overstates the actual risk in a cosmetics context.
The EU operates on a hazard-based framework. If a substance carries a hazardous classification, it is prohibited in cosmetics — full stop — regardless of whether the real-world exposure risk is meaningful. For Irish nail technicians, that means TPO-containing products are simply not an option.
What the Ban Means for Your Salon in Ireland
Ireland is an EU member state. The HPRA (Health Products Regulatory Authority) is the body responsible for enforcing cosmetics compliance here. The HPRA confirmed that from 1 September 2025, products containing TPO can no longer be sold, made available on the market, or used professionally. You can read their published position directly at hpra.ie.
The scope is wide: gel polish, BIAB, builder gels, base coats, and any other UV-cured nail product containing TPO is covered. Conventional nail lacquer is not affected because it does not use photoinitiators.
If you had TPO-containing stock still in your kit after 1 September 2025, those products needed to come out of your salon and be disposed of as chemical waste, following your local authority's guidance on chemical disposal.
There was no derogation request submitted for TPO before the regulation was adopted. No mechanism for continued professional use, no exception for stock you already paid for. Any TPO-containing product used professionally in Ireland after 1 September 2025 is non-compliant.
Ireland vs the UK: Why the Rules Are Different
If you source products from UK suppliers, or if your clients are asking questions based on what they have seen in UK trade press, this is worth paying attention to.
Northern Ireland follows EU cosmetics rules, so TPO has not been legal to purchase or use there since 1 September 2025. Great Britain is on a separate timeline. Products containing TPO cannot be newly placed on the GB market from 15 August 2026, and existing stock must be off shelves entirely by 14 February 2027. Continued professional use of stock purchased before that deadline is also permitted after that date, in line with Trading Standards guidance.
For any salon in the Republic of Ireland: you are operating under EU law. Products for professional use here must be TPO-free now, regardless of what a UK supplier is legally selling in Great Britain. A product that is perfectly legal to sell in London today is not compliant for use in a Dublin salon.
TPO and HEMA: Two Different Restrictions, One Checklist
TPO and HEMA come up together a lot in product marketing, but they are different substances with different regulatory histories. A product that is HEMA-free is not automatically TPO-free, and vice versa.
HEMA stands for Hydroxyethyl Methacrylate. It is a monomer, not a photoinitiator. Its restriction under EU law was driven by sensitisation risk: repeated skin contact with uncured HEMA-containing products can cause a (meth)acrylate allergy, which is potentially lifelong. Once that sensitisation happens, a person may no longer be able to receive any gel nail service. TPO was prohibited for a completely different reason — its CMR classification — and the legal basis is entirely separate.
When you are checking products for your salon, you should confirm both are absent from the formulation. Note that HEMA is restricted, not banned, so its presence in a formulation is not automatically non-compliant. For clients with a history of gel nail allergies or sensitivities, look for something confirmed as both HEMA-free and TPO-free. Those products exist, they perform well, and your clients will not notice the difference.
Do TPO-Free Products Perform as Well?
Yes. The two most common replacements are TPO-L (Ethyl Trimethylbenzoyl Phenylphosphinate) and BAPO (Bisacylphosphine Oxide). Both are photoinitiators that trigger the same polymerisation process under UV or LED light. Neither carries the CMR classification that applied to TPO. Both are currently compliant under EU cosmetics law, and responsible manufacturers had already switched well ahead of the September 2025 deadline.
In the salon, the difference is unremarkable. Cure times, adhesion, and finish quality are all comparable. You do not need a new lamp. You do not need to change your application technique. Same result. Different formula. If you have been using the same Kohana products as before, nothing about your service has changed.
How to Check Whether Your Products Are Compliant
Pull out the ingredient list on the product packaging or ask your supplier for the product safety data sheet (SDS). The ingredient to look for is listed under its INCI name: Trimethylbenzoyl Diphenylphosphine Oxide. If that name is there, the product is not compliant for professional use in Ireland.
Some products marketed before September 2025 used the abbreviated name TPO on labels rather than the full INCI name. If you are unsure about anything in your kit, contact the supplier and ask for written confirmation that the product is TPO-free and compliant with EU Regulation 2025/877. Any reputable supplier operating in the Irish or EU market should be able to give you that confirmation immediately. If they cannot, that tells you something important about how seriously they take compliance.
Kohana Products Are TPO-Free and HEMA-Free
Kohana Professional products are TPO-free and HEMA-free across the full range: gel polish, BIAB, Pro Base, and the builder gel systems. All formulations are compliant with EU Regulation 2025/877 and aligned with the current Irish regulatory position.
This was not a last-minute reformulation. Kate Kohana built the commitment to removing sensitising and restricted ingredients into the Kohana range from the start, before the regulation forced anyone's hand. If you have been using Kohana products, you have been using compliant formulations all along.
Knowing what is in the products you apply professionally is not optional. It is part of the job. If you need ingredient documentation for any specific Kohana product, get in touch with the team and they will have it with you straight away.
Disclaimer: This article has been produced by Kohana Professional for informational and marketing purposes. The information provided reflects our best understanding of the regulatory position at the time of publication and is correct to the best of our knowledge. It does not constitute legal or regulatory advice. For guidance specific to your business or compliance obligations, please consult a qualified legal or regulatory professional or refer directly to the HPRA and the relevant EU legislation.
