TPO has been banned in cosmetics across the EU since September 1, 2025 – why this decision raises questions
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Introduction
Since September 1, 2025, the photo initiator
Trimethylbenzoyl Diphenylphosphine Oxide (TPO, CAS No. 75980-60-8)
in all cosmetic products after the
EU Cosmetics Regulation (EC) No 1223/2009
It is forbidden. Its manufacture, sale, and use have been prohibited ever since.
The European Commission's goal was to strengthen consumer protection.
However, the decision has drawn considerable criticism from the professional nail and cosmetics industry.
Why TPO was banned
The basis for the ban is the
Delegated Regulation (EU) 2024/197 ,
with TPO as a category 2 CMR substance (possibly harmful to reproduction)
was included in Annex II of the Cosmetics Regulation .
Criticisms from experts:
- Short adjustment period : Manufacturers and studios had to convert their products and inventories with virtually no transition time.
- Uncertain data basis : Several toxicological assessments are interpreted as incomplete or ambiguous.
- Double standards : While cosmetics face a strict ban, TPO remains permitted in other industries.
Where TPO is still permitted
The ban applies exclusively to cosmetic products .
Other industries fall under different EU legal frameworks , in particular
the REACH Regulation (EC) No 1907/2006 for chemicals
or the Medical Devices Regulation (EU) 2017/745 .
They call for a risk assessment and safety evidence , but not a blanket ban on TPO .
Typical areas of application where TPO is still permissible:
| Industry / Product | Function of TPO | Legal basis |
|---|---|---|
| Industrial Paints & Coatings | Photoinitiator for UV-curing lacquers on wood, metal, and plastics | REACH: Registration & workplace protection, no general ban |
| 3D printing / SLA-DLP resins | Safe, deep UV curing of synthetic resins | REACH: Exposure and emission control instead of cosmetics law |
| UV-curing adhesives & coatings | In the packaging, automotive and electronics industries | REACH: Workplace protective measures |
| Electronics & Printed Circuit Boards | Photoinitiator in solder resists and potting compounds | REACH/RoHS, no TPO ban |
| Dental materials (dentistry) | Photoinitiator in light-curing composite dental fillings, fissure sealants and dental adhesives | Medical Device Regulation (EU) 2017/745: Benefit-risk assessment, no blanket ban |
The EU's explanation for these differences is as follows:
In these areas, TPO is encapsulated or used in closed industrial processes .
The exposure for consumers and the environment is therefore considered to be significantly lower than with cosmetic products applied directly to the skin and nails.
Impact on the industry (H2)
For manufacturers and nail salons, the ban means:
- Financial losses due to inventory that has become worthless.
- Production stoppages and short-term new developments .
-
Uncertainty among customers who wonder why the same fabric
is still permitted in 3D printing resins or dental fillings.
Many experts consider the EU's approach to be excessively bureaucratic.
and criticize the fact that the scientific discourse was not given sufficient consideration.
Our point of view
We at Studio Amelie / AM Professional naturally stand for
Legally compliant, safe products and can clearly confirm:
All our gels and top coats are TPO-free .
At the same time, we view the blanket ban critically .
We are committed to an open scientific dialogue and
realistic transition periods ,
so that innovation and consumer protection can be better balanced.
Conclusion
TPO has been banned in cosmetic products since September 1, 2025 .
But in industry, 3D printing, electronics, adhesives and even in dental fillings
It remains permissible – under stricter, but risk-based conditions .
This unequal treatment raises questions:
Does a blanket ban really offer better protection?
Or would a differentiated, scientifically based regulation have brought more benefits and less collateral damage?