First of all, what is TPO?
In short, TPO is a photoinitiator—an ingredient whose main function is to ensure that nail gels and gel polishes harden under UV/LED light. While there are other photoinitiators available, manufacturers prefer using TPO because it ensures perfect polymerization under both UV and LED light while also causing significantly less yellowing compared to other alternatives.
Why is TPO being phased out of nail cosmetics?
Not because it’s an allergen! Anyone spreading this misinformation has no idea what they’re talking about. Of course, some people may develop an allergic reaction to it—just as there is practically no chemical compound on Earth that someone isn’t allergic to—but that is not the reason. The real reason is that the European Commission has classified TPO as a substance that can harm fertility, leading to its ban. If you’re interested in the full details, you can read more about it here.
Is the TPO-free regulation just marketing hype?
NO! This regulation is very real. Some skeptics have questioned whether it’s just another marketing gimmick and have demanded to see the law that enforces it. Well, there is no law—but there is a regulation, and we won’t dive into the legal technicalities here.
What’s important to know is that on January 5, 2024, the European Commission adopted Delegated Regulation (EU) 2024/197, which was drafted on October 19, 2023. This regulation amends Regulation (EC) No 1272/2008, which concerns the harmonized classification and labeling of certain substances.
The amendment classifies TPO (2,4,6-Trimethylbenzoyl-diphenyl phosphine oxide) as a CMR 1B substance (meaning it is toxic to reproduction), and this classification will become legally binding on September 1, 2025.
As a result, TPO will be added to the list of banned substances for cosmetic products, which can be found in Annex II of the EU Cosmetics Regulation (Regulation (EC) No 1223/2009).
From this date onward, any cosmetic product containing TPO can no longer be marketed or sold within the EU.
What is actually a marketing gimmick when it comes to TPO-free claims?
The term TPO-free only makes sense for products that require curing under UV or LED lamps. Claiming that a cleanser, disinfectant, or primer is TPO-free is absolute nonsense, because TPO has never been an ingredient in those products. It simply doesn’t belong there in the first place.
That said, you’ll still find plenty of brands using misleading TPO-free claims in their marketing. Now, you’ll know how to assess such claims correctly.