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TPO Ban 2025/2026 - Full Compliance Requirements for EU & UK | Annel Ltd

TPO Ban in the EU from 2025 and in the UK from 2026: Critical Compliance Requirements

Executive Summary

The European Union has introduced a full ban on Trimethylbenzoyl Diphenylphosphine Oxide (TPO), a widely used photoinitiator in UV/LED-cured nail products. Following its re-classification as a CMR category 1B substance, TPO has now been added to Annex II of the EU Cosmetics Regulation (Regulation (EC) No 1223/2009); this results in a complete prohibition in the EU from 1 September 2025.

The United Kingdom is also preparing to ban TPO but with later proposed dates (2026–2027). These UK dates remain subject to change until the legislation is finalised.

This article explains the scientific reasoning behind the ban, key regulatory timelines, compliance obligations, reformulation strategies and practical steps for manufacturers, importers and distributors.

Why Has TPO Been Banned? CMR 1B Reclassification

TPO has long been used in UV/LED nail systems including hybrid gels, builders, top coats and base coats. Updated toxicological evaluations were carried out by:

  • the Risk Assessment Committee (RAC) of ECHA
  • the Scientific Committee on Consumer Safety (SCCS)

Key safety concerns:

  • Carcinogenicity
  • Mutagenicity
  • Reproductive toxicity
  • Potential hepatotoxicity
  • Strong skin-sensitising potential

As a result, TPO was moved from Annex III (restricted) to Annex II (prohibited) of Regulation (EC) No 1223/2009.

EU Omnibus VII: Enforcement Timeline

The TPO prohibition forms part of Commission Regulation (EU) 2025/877 (Omnibus VII).

EU TPO Ban; Effective 1 September 2025

  • No manufacture of TPO-containing cosmetics for the EU
  • No placing on the EU market
  • No making available along the supply chain
  • No transitional period; remaining stock must be withdrawn

For help preparing your EU compliance documentation, see our EU regulatory service.

Regulatory Divergence: European Union vs United Kingdom

In November 2025, the UK notified the WTO about the draft statutory instrument: The Cosmetic Products (Restriction of Chemical Substances) Regulations 2026.

Although the UK is moving towards alignment with the EU, the implementation timeline differs significantly.

Updated UK Timeline for the TPO Ban (Planned / Proposed Only)

  • 15 July 2026 - proposed UK market placement ban
  • 15 January 2027 - proposed end of UK sell-through

These UK dates are:

  • proposed
  • based on the WTO-notified draft
  • supported by CTPA
  • but not yet legally binding

Implications for Businesses Operating Across Both Markets

Dual compliance timeline:

  • EU: full ban and no sell-through from 1 September 2025
  • UK: proposed ban starting 15 July 2026, sell-through until 15 January 2027

Risk management:

  • Businesses should build flexibility into planning due to possible UK timeline changes

Strategic recommendation:

  • To avoid complexity, many companies will reformulate globally based on the EU deadline

For UK/EU Responsible Person guidance, visit our Responsible Person service.

TPO-Free Alternatives and Reformulation Strategies

Suitable alternatives include:

  • TPO-L (Ethyl phenyl(2,4,6-trimethylbenzoyl)phosphinate)
  • BAPO (Bis(2,4,6-trimethylbenzoyl)-phenylphosphine oxide)
  • Ethyl Trimethylbenzoyl Phenylphosphinate

Reformulation requirements:

  • UV/LED curing validation
  • Accelerated and real-time stability testing
  • Packaging compatibility studies
  • Full CPSR re-evaluation
  • Updated PIF
  • New CPNP (EU) and SCPN (UK) notifications
  • Revised INCI and labelling

Compliance Checklist for Manufacturers, Importers and Distributors

Product Audit

  • Identify all SKUs containing TPO
  • Check raw material specifications and INCI listings

Reformulation

  • Develop TPO-free prototypes
  • Test curing performance
  • Conduct functional and stability tests

Documentation

  • Update PIF
  • Issue new CPSR
  • Update SDS
  • Adjust labels and INCI
  • Re-notify via CPNP and SCPN

Supply Chain Actions

  • Communicate changes to distributors
  • Prepare withdrawal plan for existing stock
  • Set internal EU cut-off: 31 August 2025
  • Plan for UK transition

Risk Management

  • Maintain full traceability
  • Ensure readiness for EU/UK enforcement inspections

TPO ban 2025 compliance infographic

Download the checklist (PDF)

FAQ

  • Can TPO products be sold after 1 September 2025 in the EU?
    No.
  • Are UK dates final?
    No; they remain proposed.
  • Can the UK dates change?
    Yes; timelines may shift during final adoption.
  • Should manufacturers reformulate now?
    Yes; for both the EU and UK markets.

Conclusion

The ban on TPO marks a major regulatory shift for UV/LED nail products. Early reformulation aligned with the EU deadline will minimise operational risk and ensure continuity across both the EU and UK markets.

For regulatory support, reformulation guidance or PIF/CPSR updates, visit annelltd.com.

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