TPO – What’s it All About?

I am sure you have heard that a TPO ban in cosmetics is imminent in the European Union – however not yet in the UK, so here is everything you need to know about this.

What is TPO ?

Trimethylbenzoyl Diphenylphosphine Oxide is a photo initiator meaning it is a substance that initiates a chemical reaction when exposed to UV and LED light.

The reaction is polymerisation which transforms liquid gel polish, builders and hard gels into a solid, durable nail enhancement.  

Why has TPO been used in the past?

TPO has been considered a good photo initiator because it leads to faster curing times and more complete polymerisation, it is low-yellowing in comparison to some other photo initiators,  it is effective in curing thicker layers of material because it can penetrate deeper into the material due to its absorption characteristics and finally it helps to ensure an even and more complete cure.  This is why it has been used in gel products (and many other industries) for many years.

Why is it being banned – and when?

A great explanation from Doug Schoon (an internationally-recognized scientist, author and educator with over 30 years experience in the beauty industry and a leading industry authority, known for his technical and regulatory work):

“I’ve been asked why the widely used photo initiator called “TPO” is no longer allowed in the EU. Here are the facts, TPO was found to be an issue when used in UV-cured food packaging, where there was concern it could migrate into food. Therefore the “risk” is related only to its potential as reproductive toxicant when ingested. 

To be clear, the concern was NOT about its use in cosmetics, which was considered safe. However, EU regulations automatically prohibit substances classified as reproductive toxicant from use in cosmetics, even if proven safe for that use. 

In short, TPO is not allowed in cosmetics within the EU for regulatory reasons, not because it was found to be unsafe when used in ways that do not involve ingestion.”

Previously the European Commission deemed TPO to be safe for use in cosmetics (including nail products) at concentrations up to 5%. However, the decision has now been made for the EU only, that from 1^st September 2025 it will be banned from being manufactured or sold – either by manufacturers or distributors.  There has been no specific date confirmed for the UK market, but as we are expected to follow suit, we understand that this is likely to be in the final quarter of 2026 when a ban will take into effect in the UK.

This will mean that potentially from Autumn 2026 – there will be a restriction and most probably a ban on TPO in the UK.  

What are Cuccio doing about this?

We have already been working behind the scenes to reformulate any products that contain TPO for some time now, and any new products that are being launched have been formulated without this ingredient.  For example, our last three Veneer collections (Summer 2024 – Wildflower Collection, Autumn/Winter 2024 – Vintage Chic Collection and Spring/Summer 2025 – Italian Garden Collection) are already TPO free as we prepare for this change.  And our Our latest batch of coloured brush on Builder Gels (Pretty in Pinks Collection, and the Dark Shades Collection) are all TPO free too.  Our Clear Builder Gel in all sizes is also TPO free.

We already have 62 of our existing best-selling Veneer gel polishes reformulated to TPO free and the remaining shades being worked through, along with our Hard Gels.  A full list of these will be made available to you.  

Our Universal Base Coat is already TPO free, and we have a TPO & HEMA free Base & Top in our 9ml gel polish range, launched with the Wildflower collection.  

Our Clear Flex Gel is also TPO free; the coloured Flex Gels have less than 1% of TPO in them so are also being re-formulated to have this removed.  Our Controlled Levelling & Self Levelling LED gels have between 0.1% and 1% of TPO in them currently, but again, these are already being re-formulated.  

All of our UV Hard Gels (T3 UV, UV Sculpting and all shades of UV, along with our UV Gel Seal and Universal Soak off Top Coat) – are already TPO free.

What about my current stock?

Because the regulation gave no explicit directive on products already on the market, and no official recall is imposed currently, we understand that you will not have to dispose of your TPO products even after the ban is enforced.  As the manufacturer, we will of course not be able to make or sell them after Autumn 2026 – but there is nothing yet set in stone to say that any stock you have as a customer will have to be disposed of.  However, if this changes, we will keep you advised.  

We’ll keep you informed  

We will work through our website and change the descriptions of the products that are already TPO free to enable you to have a choice and so that you are fully aware of which products you can choose if you already want to make that change and plan for the potential ban in just over 12 months time.

Maria x