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 photoinitiator Trimethylbenzoyl Diphenylphosphine Oxide (TPO, CAS no. 75980-60-8) has been banned in all cosmetic products under EU Cosmetics Regulation (EC) No. 1223/2009. Manufacturing, sale, and use have been impermissible since then.
The European Commission's goal was to strengthen consumer protection. However, the decision has drawn significant criticism from the professional nail and cosmetics industry.
Why TPO was banned
The basis for the ban is Delegated Regulation (EU) 2024/197, which added TPO as a CMR substance of category 2 (possibly hazardous to reproduction) to Annex II of the Cosmetics Regulation.
Points of criticism from experts:
- Short adaptation period: Manufacturers and studios had to switch their products and inventories with virtually no transition period.
- Uncertain data basis: Several toxicological assessments are interpreted as incomplete or inconclusive.
- Double standards: While cosmetics face a strict ban, TPO remains permitted in other industries.
Where TPO remains permitted
The ban exclusively affects cosmetic products. Other industrial sectors fall under different EU legal frameworks, particularly REACH Regulation (EC) No. 1907/2006 for chemicals or the Medical Devices Regulation (EU) 2017/745. These require risk assessment and safety evidence, but no blanket TPO ban.
Typical application areas where TPO is still permissible:
| Industry / Product | Function of TPO | Legal basis |
|---|---|---|
| Industrial paints & coatings | Photoinitiator for UV-curable varnishes on wood, metal, plastics | REACH: Registration & workplace protection, no general ban |
| 3D printing / SLA-DLP resins | Safe, deep UV curing of synthetic resins | REACH: Exposure & emission control instead of cosmetics law |
| UV-curing adhesives & coatings | In packaging, automotive, and electronics industries | REACH: workplace-related protective measures |
| Electronics & circuit boards | Photoinitiator in solder masks and potting compounds | REACH/RoHS, no TPO ban |
| Dental materials (dentistry) | Photoinitiator in light-curing composite dental fillings, fissure sealants, and dental adhesives | Medical Devices Regulation (EU) 2017/745: Benefit-risk assessment, no blanket ban |
The EU's justification for these differences is that in these areas, TPO is encapsulated or used in closed industrial processes. Exposure for consumers and the environment is therefore considered significantly lower than for cosmetic products applied directly to skin and nails.
Impact on the industry
For manufacturers and nail salons, the ban means:
- Financial losses due to worthless stock.
- Production stops and short-term new developments.
- Customer uncertainty, as they wonder why the same substance is still permitted in 3D printing resins or dental fillings.
Many experts view the EU's approach as overly bureaucratic and criticize that the scientific discourse was not sufficiently considered.
Our position
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. Discover our complete, TPO-free range of top gels and cover gels.
At the same time, we are critical of the blanket ban. We advocate for open scientific dialogue and realistic transition periods to better balance innovation and consumer protection.
Conclusion
Since September 1, 2025, TPO has been banned in cosmetic products. However, it remains permissible in industry, 3D printing, electronics, adhesives, and even in dental fillings – under stricter, but risk-based conditions.
This differentiated treatment raises questions: Does a blanket ban really offer better protection, or would a differentiated, scientifically sound regulation have brought more benefits and fewer collateral damages?