Starting from September 1, 2025, the European Union will ban the use of TPO in cosmetics, particularly in semi-permanent polishes. This new regulation marks a step forward in the fight for more responsible beauty and a victory for Manucurist, which has always excluded risky components from its formulas.
Key points to remember:
- From September 1, 2025, the European Union bans TPO in all cosmetic products (Regulation (EC) No 1223/2009).
- TPO (Trimethylbenzoyl Diphenylphosphine Oxide) is the photo-initiator that ensures the polymerization of semi-permanent polishes under UV/LED lamps.
- In May 2025, TPO is reclassified as CMR 1B — proven toxic for reproduction — by Regulation No. 2025/977 (“Omnibus VII”).
- Manucurist excluded TPO from its formulas from the very conception of the Green Flash™ polish, well before its ban.
- The chosen alternative, TPO-L, is an effective, non-toxic photo-initiator not classified as CMR.
What is TPO and why is it so controversial?
A key component of semi-permanent polishes
TPO, or Trimethylbenzoyl Diphenylphosphine Oxide, is a widely used photo-initiator in cosmetics, especially in the composition of semi-permanent polishes. It is thanks to it that the polymerization of the polish occurs when exposed to UV or LED lamps. A magical ingredient that allows for fast drying and that famous hard, resistant film on the nail which made the semi-permanent polish so successful.

TPO, an effective ingredient but not without risks.
A substance classified as CMR for several years
While its chemical properties delight the cosmetic industry, TPO also has a much less glorious side. Since 2019, it has been classified at the European level among CMR substances, meaning chemical agents that have, in the medium or long term, carcinogenic, mutagenic, or toxic effects on reproduction. Until 2025, it was in the CMR 2 category, meaning it was “only” suspected of being toxic for human reproduction. Its use under conditions (maximum concentration of 5%) was therefore allowed.
Towards a European ban in 2025
In May 2025, the European Union decided to reclassify TPO as CMR 1B. It is now considered proven toxic for reproduction (Regulation No. 2025/977 known as “Omnibus VII”). The consequences were immediate: European authorities decided to permanently ban TPO in cosmetics starting September 1, 2025 (Regulation (EC) No 1223/2009). From that date, it will no longer be possible to:
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market cosmetic products containing TPO,
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make these products available, including to professionals,
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use these products, especially in professional services (polish application, manicure, etc.)
While not a surprise, this ban is nevertheless a great victory in the eyes of Gaëlle Lebrat-Personnaz, founder of Manucurist, who has long fought to offer non-toxic polish formulas: “It shows that this fight for more responsible beauty that respects women’s health is worthwhile and that we are right to pursue it.” Because yes, polish without TPO exists and Manucurist is one of the pioneering brands in this field.

Gaëlle Lebrat-Personnaz, CEO and founder of Manucurist.
Polish without TPO: more responsible formulas
How to replace TPO in semi-permanent polish?
The search for alternatives to replace risky ingredients is a true credo at Manucurist. From the design phase of what would become the LED Green Flash™ polish, TPO was excluded from the formula, as were other CMR-classified substances (toluene, DBP, formaldehyde, hydroquinone, etc.) and HEMA and di-HEMA. And this was even before these substances were banned or strictly regulated by European authorities.
To replace TPO, our laboratory chose a high-performance and safe alternative: TPO-L, another effective photo-initiator, non-toxic and not classified as CMR, fully compliant with European regulations. It allows optimal polymerization of the Green Flash™ polish under LED lamp, ensuring both quality results and user safety.
In summary:
- TPO is a widely used photo-initiator in semi-permanent polishes: it enables fast drying under lamp and the formation of the hard film characteristic of semi-permanent polish.
- Classified as CMR 2 since 2019, it was tolerated up to a maximum concentration of 5%.
- In May 2025, the EU reclassified it as CMR 1B (proven toxic for reproduction), via Regulation No. 2025/977.
- The ban, effective September 1, 2025, covers three uses: marketing, making available (including to professionals), and use in services (application, manicure).

In the laboratory where Manucurist polish formulas are crafted.
Green Flash™, the semi-permanent polish without compromise
By choosing Green Flash™, you opt for a next-generation nail polish that guarantees a manicure without risk to your nails and no compromise on performance. This is achieved through several commitments:
🌿 A bio-sourced polish formula up to 84%: this approach aims to replace as much as possible synthetic chemical ingredients with plant-based alternatives to offer a biodegradable product and a composition more respectful of the nail.
🐶 A vegan polish: like all Manucurist products, Green Flash™ contains no animal-derived ingredients and is certified by The Vegan Society.
💅 Fast and safe application and removal: Green Flash™ perfectly demonstrates that a bio-sourced polish retains fluidity, plasticity, and can dry quickly under LED lamp. The same goes for removal which, thanks to the Green Flash Gentle Remover ™, is done in 1 minute without damaging the nails.
⏳ Impeccable tenue up to 12 days thanks to the patented KeraHCE+ technology contained in the Vitamin Base Coat which strengthens nails with each application and extends the tenue of the polish.
At Manucurist, we continuously innovate to offer quality products that respect the health of those who use them. Transparency in our formulas is fundamental to maintaining the trust of the many consumers and professionals worldwide. And we want that to last for a long time!!
In summary:
- Manucurist is among the pioneering brands of semi-permanent polish without TPO, having also excluded from the start toluene, DBP, formaldehyde, hydroquinone, HEMA, and di-HEMA.
- TPO is replaced by TPO-L, which guarantees optimal polymerization of Green Flash™ under LED lamp, without risk to the user.
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Green Flash™ polish is based on four commitments: bio-sourced formula up to 84%, vegan certification, fast and safe application and removal (removal in 1 minute with the Gentle Remover), and tenue up to 12 days or 21 days with the Top Coat Xtrem Flash™.












