By the Universal Nail Supplies pro team | Published 5 October 2026 | Updated 5 October 2026

TPO in gel polish is a photoinitiator, the ingredient that makes gel harden under a lamp. Its full name is diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide. The European Union prohibited it in cosmetics from 1 September 2025, and Great Britain followed in August 2026. TPO is still legal in the United States.

What is TPO in gel polish?

TPO is a photoinitiator used in gel nail products. When UV or LED light hits it, TPO splits apart and starts the chain reaction that turns liquid gel into a hard coating. Its INCI name on a label is Trimethylbenzoyl Diphenylphosphine Oxide, and its CAS number is 75980-60-8, as listed in Commission Regulation (EU) 2025/877.

Formulators liked TPO because it cures fast and barely tints the product, so pale shades stay pale. You will find it in base coats, color gels, top coats, builder gels and some acrylic and polygel systems. It is not a color, a monomer or an adhesion promoter, which is why swapping it out changes cure behavior rather than wear.

The US Cosmetic Ingredient Review panel recorded TPO in 2,330 reported nail product uses, at concentrations up to 5 percent, in its draft report on phosphine oxide photoinitiators (February 2026).

Is TPO banned in the United States?

No. TPO is legal in the United States and there is no federal restriction on it. Nail products are regulated as cosmetics under the Federal Food, Drug, and Cosmetic Act, as amended by the Modernization of Cosmetics Regulation Act of 2022. TPO does not appear on the FDA's prohibited and restricted list.

As of October 2026 the FDA has published no guidance, no safety communication and no ingredient page on TPO in nail products. You can check the list yourself on the FDA's prohibited and restricted ingredients page.

That matters commercially. A US salon using a TPO gel today is not breaking any rule, and a US retailer selling one is not selling a banned product. The pressure to reformulate in America is coming from brands and from clients who read European headlines, not from American law.

Why did the EU ban TPO on 1 September 2025?

The EU prohibited TPO because of a chemical hazard classification, not because of a problem seen in salons. In 2023 the EU gave TPO a harmonized classification as a reproductive toxicant. Under EU cosmetics law that classification triggers an automatic prohibition, with no separate safety review of nail products.

The prohibition came through Commission Regulation (EU) 2025/877, published on 13 May 2025 and applying from 1 September 2025. It added TPO to Annex II of the EU Cosmetics Regulation as entry 1731. It also deleted the old Annex III entry that had allowed TPO at up to 5 percent in professional artificial nail systems.

What does a reproductive toxicity 1B classification actually mean?

Reproductive toxicity category 1B means a substance is presumed to harm human reproduction, based on animal evidence rather than human cases. TPO carries that classification, coded H360Fd, under Commission Delegated Regulation (EU) 2024/197, the 21st update to the EU's classification rules. The same entry also lists TPO as a skin sensitizer.

This is a hazard-based decision, not an exposure-based one. EU cosmetics law bans category 1A and 1B substances automatically, whatever the dose in the finished product. That is why the ban can be real and the everyday risk from a manicure can still be small. Both things are true at once, and most coverage picks one and drops the other.

Can EU salons use up TPO stock they already bought?

No. The European Commission addressed this directly. In its TPO questions and answers published on 7 August 2025, it states that the Cosmetics Regulation contains no sell-through or use-up provision for substances in this category.

The Commission goes further and says that a professional using such a product on a client counts as making it available on the market. That applies whether or not the bottle was bought before the cut-off. So an EU tech with half a shelf of old base coat has no legal route to finish it on clients.

Is TPO banned in the UK?

Yes, but on a different timetable from the EU, and with a use-up window the EU never gave. Great Britain banned TPO under SI 2026/23, made on 12 January 2026, which adds TPO to the GB prohibited list as entry 1745.

Two dates matter. TPO products could no longer be placed on the GB market from 15 August 2026. Stock already placed on the market may be sold through until the end of 14 February 2027. The UK trade body CTPA confirms both dates in its note on the TPO ban in the EU and GB.

One detail almost every article misses: SI 2026/23 extends to England, Wales and Scotland only. Northern Ireland follows the EU rules, so the EU date of 1 September 2025 applied there. If you ship to a Belfast salon, the EU rule is the one that applies.

TPO rules by market, at a glance

TPO rules now differ by market, so the honest answer to "is TPO banned" is "where?". The table below sets out the four positions that matter to a US supplier and the instrument behind each one. Northern Ireland is listed separately because it follows EU rules rather than Great Britain's.

Market	Status	Key date	Use-up period	Instrument
United States	Legal, no restriction	None	Not applicable	FD&C Act as amended by MoCRA 2022
European Union	Prohibited	1 September 2025	None	Regulation (EU) 2025/877, Annex II entry 1731
Northern Ireland	Prohibited	1 September 2025	None	EU rules apply
Great Britain	Prohibited	15 August 2026 for placing on the market	Sell-through to 14 February 2027	SI 2026/23, GB Annex 2 entry 1745

This table is the reason the question "is TPO banned" has no single answer. It depends entirely on where the product is being sold or used.

Has gel polish been banned?

No. Gel polish has not been banned anywhere. One ingredient was prohibited in the EU and Great Britain, and most brands reformulated around it. Gel manicures continue in Europe using gels that cure with different photoinitiators.

The confusion is understandable. Headlines in late 2025 and 2026 ran close to "Europe bans gel nail polish", and that version reached clients through mainstream news, Instagram and TikTok. Nail techs then spent months correcting it at the desk. If a client asks whether gel is banned, the short answer is that one curing ingredient was removed in Europe and American products were never affected.

Which gel polishes contain TPO, and which are TPO-free?

There is no public master list, because reformulation happened brand by brand and often line by line. The reliable answer for any specific bottle comes from the ingredient panel or the safety data sheet, not from a blog table. Below are the brand statements we can point to with a source, each one checked on 6 October 2026.

Does OPI gel polish have TPO?

OPI states that its GelColor with Intelli-Gel Technology shades and its Powder Perfection dip powders are HEMA-free and do not use TPO. That wording appears on OPI's own Color Without Compromise page, which is the primary source for the claim.

The more useful detail sits with Wella, OPI's parent company. Its professional store page for OPI GelColor Intelli-Gel states that the Intelli-Gel Super Base, the Intelli-Gel shades, all Intelli-Gel top coats and all GELevate 4-in-1 Builder shades are HEMA and TPO free, and names one base coat in the gel portfolio that still contains TPO.

Two cautions before you repeat this to a client. OPI's US page and Wella's store page use different base coat names, so confirm the exact SKU in front of you rather than the line. And "Intelli-Gel is TPO-free" is accurate for shades and top coats, not for every product OPI sells. You can browse the range on our OPI GelColor Intelli-Gel and OPI GELevate collections.

Is DND gel polish TPO-free?

DND runs a dedicated HEMA-free and TPO-free line rather than having reformulated its whole catalog. That means the answer depends on which DND product you are holding. The separate line is the one carrying the claim, and we stock it as DND HEMA/TPO Free. For any other DND product, check the panel.

Is Kiara Sky TPO-free?

Kiara Sky also sells a specific HEMA-free and TPO-free range, Gel Pro, rather than applying the claim across the brand. We carry it as Kiara Sky Gel Pro HEMA-Free and TPO-Free. The rest of the Kiara Sky gel catalog is not covered by that claim.

Does builder gel, hard gel or polygel contain TPO?

Some do and some do not, and the product type tells you nothing on its own. Formulators used TPO across gel chemistries, so a builder gel is no more or less likely to contain it than a color gel. The EU prohibition applies to all of them equally, so EU brands reformulated builder and hard gel lines alongside their polish lines.

Does regular nail polish have TPO?

No. Traditional lacquer dries by solvent evaporation and does not cure under a lamp, so it has no photoinitiator and no TPO. If a client wants to avoid TPO entirely and is not attached to gel wear, regular lacquer is the simple answer.

How do you check whether your gel polish contains TPO?

Read the ingredient panel and look for the INCI name, Trimethylbenzoyl Diphenylphosphine Oxide. If the panel is too small or worn, request the safety data sheet from your supplier and look at section 3, which lists composition by CAS number. TPO is CAS 75980-60-8 (Regulation (EU) 2025/877, Annex entry 1731).

1. Check the bottle's INCI list first. The INCI name is what appears on the label, not "TPO".
2. If the label is unreadable, ask your distributor for the current SDS for that exact SKU.
3. Match on the CAS number rather than the name, because similar-sounding compounds exist. Triphenylphosphine oxide is a different substance and is not the one that was prohibited.
4. Check the date on any statement you are given. Brands reformulated at different times, so a 2024 SDS may not describe a 2026 bottle.
5. Treat brand-level claims with care. A brand saying it is TPO-free rarely means every SKU it has ever sold.

What replaced TPO in reformulated gels?

Three photoinitiators are doing most of the work in reformulated gels: TPO-L, BAPO and TMO. They perform the same job as TPO but absorb light slightly differently, which is why some reformulated products behave differently in an older lamp.

Replacement	INCI or chemical name	CAS	Regulatory standing	Source
TPO-L	Ethyl Trimethylbenzoyl Phenylphosphinate	84434-11-7	No SCCS opinion. Under CIR review in the US, no conclusion published	CIR draft report, Feb 2026
BAPO	Bis-Trimethylbenzoyl Phenylphosphine Oxide	162881-26-7	No SCCS opinion. Under CIR review in the US, no conclusion published	CIR draft report, Feb 2026
TMO	[bis(4-methylphenyl)phosphinyl](2,4,6-trimethylphenyl)methanone	270586-78-2	No SCCS opinion	Gong et al., J Chromatogr, 2025

Source for the CAS numbers and US use data: the CIR draft report on phosphine oxide photoinitiators, February 2026, which records TPO-L in 1,792 nail product uses at up to 6.2 percent.

Be careful with the word "approved". None of these three has an SCCS opinion behind it.

The only SCCS opinion in this chemical family covers TPO itself. The 2014 SCCS opinion on TPO found 5.0 percent safe in nail modeling products and called TPO a moderate skin sensitizer. That 5 percent figure is where the old EU limit came from, and it is now historical.

The practical consequence for a salon is cure behavior. If a reformulated base feels tacky or lifts in a lamp that handled the old version fine, treat the lamp as a suspect before you blame the gel. Our professional nail lamps list wavelength ranges so you can match a lamp to a product.

What is HEMA in nail polish?

HEMA is 2-hydroxyethyl methacrylate, CAS 868-77-9. It is a small monomer used in gel systems mainly for adhesion, and it is the most frequently identified cause of allergic reactions to gel nails. It is a completely different ingredient from TPO and it does a completely different job.

HEMA is small and mobile. That is exactly why it grips the nail plate well, and also why it crosses skin easily when uncured product touches the cuticle or sidewall. That trade-off is the whole story of HEMA. Remove it and you usually lose some adhesion, so HEMA-free systems often need different prep.

Is HEMA banned?

No. HEMA is not banned in the EU, the UK or the US. In the EU it is restricted to professional use, which is a different thing. That restriction came in through Commission Regulation (EU) 2020/1682, long before the TPO story.

Under that regulation, nail products containing HEMA or Di-HEMA Trimethylhexyl Dicarbamate must carry two warnings: "For professional use only" and "Can cause an allergic reaction". Brands could no longer place non-compliant product on the EU market from 3 June 2021, and could not supply it at all from 3 September 2021.

Two myths are worth killing here. The first says the EU banned HEMA and TPO together in September 2025. It did not. That date covers TPO only.

The second says EU law caps HEMA at 35 percent. It does not. Annex III of Regulation (EU) 2020/1682 sets no numeric limit on HEMA at all.

The 35 percent figure comes from the 2018 SCCS opinion on HEMA and Di-HEMA Trimethylhexyl Dicarbamate, where it marks the upper end of the use levels the committee assessed in gel systems. The committee made that finding conditional on the product touching only the nail plate and never the surrounding skin. It is an assessed use level, not a legal ceiling.

Writing in Scratch magazine in March 2026, nail scientist Doug Schoon put it plainly: "Claims that HEMA is banned (or about to be banned) are not supported." The CTPA's science director said in the same piece that she is not aware of any plans to change how HEMA is regulated.

In the United States, HEMA carries no restriction at all. A US consumer can legally buy the same HEMA gel that an EU consumer cannot, with no professional-use limit and no mandatory allergy warning on the label.

Does HEMA-free mean TPO-free?

No. HEMA-free and TPO-free are two unrelated claims and a product can carry one without the other. HEMA is a monomer restricted on allergy grounds. TPO is a photoinitiator prohibited on reproductive toxicity grounds. Removing one does nothing to the other.

This is the single most common mix-up in the whole topic, partly because some brands reformulated for both at the same time. OPI's Intelli-Gel shades happen to be both, which makes it easy to assume the two go together. They do not. If a client needs to avoid HEMA, a TPO-free label tells you nothing useful, and the reverse is also true.

Can you still react to a HEMA-free gel polish?

Yes. HEMA-free does not mean hypoallergenic. HEMA-free gels still contain other acrylates and methacrylates, and several of those are documented skin sensitizers in their own right. The most common substitute, HPMA, is one of them.

HPMA is hydroxypropyl methacrylate, CAS 27813-02-1. It is not restricted in the EU or the US, and the British Society of Cutaneous Allergy lists it among the acrylate allergens in its acrylates patient leaflet. So a reformulated HEMA-free product can swap one sensitiser for another that nobody is tracking.

The dermatology literature has caught up with this. A 2024 case report in Contact Dermatitis by Dendooven and colleagues describes allergic contact dermatitis, presenting as swelling of the lips and eyelids, traced to a vegan HEMA-free gel polish containing other acrylates (PubMed 39054905). OPI's own HEMA-free claim carries a footnote making the same point, that reactions to other acrylates may still occur.

What a methacrylate allergy looks like, and who actually gets it

A methacrylate allergy from gel usually shows up as itching, redness and swelling around the nail folds and fingertips, sometimes with blistering, peeling skin or the nail plate lifting away from the bed. Symptoms often start days after a service rather than during it, so people rarely connect the two.

Now the part most articles get backwards. Plenty of them claim nail technicians are the main victims. The published case series say otherwise.

An eight-year Amsterdam study of 67 patients found 97 percent reacted to HEMA, and consumers made up 73 percent of them (Steunebrink et al., Contact Dermatitis, 2024). A 2025 Italian study tracked prevalence rising from 1.6 percent in 2019 to 2.7 percent in 2023, and named artificial nails as the leading cause in roughly three quarters of cases (Caroppo et al., Contact Dermatitis, 2025).

Techs still have the heavier daily exposure, which is why gloves and clean application matter. But the client in your chair is statistically more likely to be the one who develops this, and that changes how you talk about it.

Sensitization is usually permanent. DermNet states that sensitization is generally life long. The consequence reaches past nails: the British Association of Dermatologists warns that an allergy to these chemicals can affect future dental treatment and surgery, because dental materials and bone cements use related methacrylates (British Association of Dermatologists).

If you or a client suspects this, the route is a dermatology referral and patch testing with an acrylate series. Nothing on this page is medical advice, and no ingredient swap substitutes for a diagnosis.

Why under-curing causes more reactions than the ingredient list

A gel that is only partly cured still contains free monomer, and free monomer is what sensitizes skin. The problem is that a partly cured gel feels finished. In The Complexity of UV Curing, nail scientist Doug Schoon writes that a UV coating hardens once it passes roughly 50 percent cure, while the target for a properly cured coating is around 90 percent.

That gap is where most avoidable reactions live. A gel can pass the fingernail test, look glossy and wear for two weeks, while still leaving reactive monomer against the skin every time the client washes their hands.

The fixes are unglamorous and they work. Keep product off the skin, apply thin layers, and use the lamp the manufacturer specifies for that product.

Replace bulbs or lamps on schedule, and never shorten cure times to speed up a service.

There is a sobering piece of evidence behind all this. A 2025 multi-country audit by the European Environmental Contact Dermatitis Research Group found that the EU's professional-use restriction on HEMA did not reduce case numbers (Wilkinson et al., Contact Dermatitis, 2025). Regulation alone did not fix this. Application technique is doing more of the work than the label is.

What should a US salon do with TPO stock right now?

Nothing is legally required of a US salon. TPO is permitted here, so stock you already own can be used and sold. The decision in front of you is commercial and reputational, not regulatory.

1. Check what you actually hold. Most of a typical shelf was never affected, and panic-replacing everything is expensive and unnecessary.
2. Decide a position and write it down, so every tech in the salon answers clients the same way.
3. If you serve clients who read the European coverage, stocking a TPO-free line is a service decision worth making, not a compliance one.
4. Do not describe TPO products as recalled or unsafe. There has been no US recall and no FDA finding.
5. If you ship product to the EU, Northern Ireland or Great Britain, or you work a guest spot or competition there, their rules apply to you and not yours.

That last point catches people out. A US tech selling gel to a customer in Europe is placing product on a market where TPO is prohibited.

What to tell a client who read that gel polish is banned

Keep it short, accurate and unalarmed. Something close to this works at the desk: "Europe banned one curing ingredient called TPO as a precaution. It was never banned here, nothing was recalled, and most brands have already reformulated. If you would rather avoid it, I stock lines that are TPO-free."

Three things to avoid. Do not say the product was found to be unsafe, because the EU decision was a hazard classification rather than a finding about manicures. Do not say gel polish was banned. And do not promise a product is HEMA-free or TPO-free unless you have checked that specific SKU.

If a client has had a reaction before, the honest answer is that avoiding one named ingredient is not a guarantee, and a dermatologist can patch test to find out what is actually causing it.

Frequently asked questions

Is TPO still legal in the United States?

Yes. TPO is legal in the United States with no federal restriction. It is not on the FDA's prohibited and restricted cosmetic ingredients list, and the FDA has issued no guidance on TPO in nail products as of October 2026.

Why was TPO banned in Europe?

In 2023 the EU gave TPO a harmonized classification as a presumed reproductive toxicant. Cosmetics law then prohibits substances in that category automatically, regardless of how much the finished product contains. The EU based the decision on chemical hazard, not on reported harm from manicures.

What gel polish does not contain TPO?

Any gel reformulated for the EU or GB market since 2025 should be TPO-free, along with dedicated TPO-free lines such as DND HEMA/TPO Free and Kiara Sky Gel Pro. Regular lacquer never contained TPO. For any individual bottle, check the INCI panel or the safety data sheet.

How do you know if your gel polish has TPO?

Look for Trimethylbenzoyl Diphenylphosphine Oxide on the ingredient panel, or check section 3 of the safety data sheet for CAS 75980-60-8, the identifier used in Regulation (EU) 2025/877. Do not rely on a brand-level claim, because brands reformulated line by line and older stock can still be in circulation.

Is HEMA banned in the US?

No. HEMA carries no restriction in the United States. It can be sold to consumers with no professional-use limit and no mandatory allergy warning, which is different from the EU, where nail products containing HEMA are professional-use only and must carry two label warnings.

Is HEMA-free gel polish as durable as regular gel polish?

Modern HEMA-free gels wear comparably, but they often behave differently on application. HEMA is an adhesion promoter, so HEMA-free systems can be less forgiving about prep. If a HEMA-free product lifts, review dehydration, primer and how close you are working to the cuticle before changing brands.

Can you be allergic to TPO?

Yes, though it is not the usual culprit. TPO carries a skin sensitizer classification alongside its reproductive toxicity classification, and the 2014 EU scientific opinion called it a moderate skin sensitizer. Most diagnosed gel allergies trace to methacrylates such as HEMA rather than to the photoinitiator.

Does dip powder contain HEMA or TPO?

Dip systems cure chemically rather than under a lamp, so they do not need a photoinitiator and generally contain no TPO. HEMA content varies by brand. OPI states its Powder Perfection dip powders are HEMA-free. Check the panel for any other brand.

Will a TPO-free gel cure in my existing lamp?

Usually, but not always. Replacement photoinitiators absorb light at slightly different wavelengths, so an older or narrow-spectrum lamp can under-cure a reformulated product that the previous version cured fine. If you see tackiness or lifting after a reformulation, test the lamp before blaming the gel.

Sources

• Commission Regulation (EU) 2025/877, Official Journal, 13 May 2025
• Commission Delegated Regulation (EU) 2024/197, Official Journal, 5 January 2024
• European Commission, TPO in Nail Products: Questions and Answers, 7 August 2025
• SI 2026/23, Cosmetic Products (Restriction of Chemical Substances) Regulations 2026, UK
• CTPA, Ban of TPO in the EU and GB, updated 13 August 2026
• Commission Regulation (EU) 2020/1682, HEMA restriction, 12 November 2020
• FDA, Prohibited and Restricted Ingredients in Cosmetics
• Cosmetic Ingredient Review, draft report on phosphine oxide photoinitiators, February 2026
• OPI, Color Without Compromise
• Steunebrink et al., Contact allergy to acrylate-containing nail cosmetics, Contact Dermatitis, 2024
• Caroppo et al., The Italian trend of contact allergy to 2-HEMA, Contact Dermatitis, 2025
• Wilkinson et al., Contact allergy to methacrylate containing nail products, Contact Dermatitis, 2025
• Dendooven et al., Allergic contact dermatitis from a HEMA-free gel nail polish, Contact Dermatitis, 2024
• Doug Schoon, The Complexity of UV Curing, Schoon Scientific, 2014
• Scratch, HEMA in nail products: what is it and is it banned, March 2026

If you want to offer clients a TPO-free or HEMA-free option, start with our DND HEMA/TPO Free and Kiara Sky Gel Pro HEMA-Free and TPO-Free ranges, or ask us to pull the current safety data sheet for anything you already stock.