As of September 1, 2025, the European Union bans the use of TPO in cosmetics, particularly in gel polishes. This new standard marks a step forward in the movement for more responsible beauty and a victory for Manucurist, which has always excluded risky ingredients from its formulas.
Key takeaways:
- As of 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 curing of gel polishes under UV/LED lamps.
- In May 2025, TPO is reclassified as CMR 1B — proven toxic for reproduction — under Regulation No. 2025/977 ("Omnibus VII").
- Manucurist excluded TPO from its formulas right from the development of Green Flash™ polish, well before the ban.
- The chosen alternative, TPO-L, is an effective, non-toxic, non-CMR-classified photo-initiator.
What is TPO and why is it so controversial
A key component of gel polishes
TPO, or Trimethylbenzoyl Diphenylphosphine Oxide, is a photo-initiator widely used in cosmetics, especially in gel polish formulations. It is responsible for the curing of the polish when cured under a UV or LED lamp. A magic ingredient that delivers fast drying and that signature hard, durable layer on the nail that made gel polish so popular.
TPO: an effective ingredient, but not without risks.
A substance classified as CMR for several years
While its chemical properties delight the cosmetics industry, TPO also has a far less glamorous dark side. Since 2019, it has been classified at the European level as a CMR substance—in other words, a chemical agent with medium- or long-term carcinogenic, mutagenic, or reprotoxic effects. Until 2025, it was listed in CMR Category 2, meaning it was "only" suspected of being toxic to human reproduction. Its conditional use (maximum concentration of 5%) was therefore permitted.
Towards a European ban in 2025
In May 2025, the European Union decided to move TPO to CMR Category 1B. It is now officially recognized as a proven reproductive toxin (Regulation No. 2025/977, known as "Omnibus VII"). The consequences followed swiftly: European authorities decided to permanently ban TPO in cosmetics starting September 1, 2025 (Regulation (EC) No. 1223/2009). From that date on, it will no longer be permitted:
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to place cosmetic products containing TPO on the market,
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to make these products available, including to professionals,
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to use these products, particularly when providing professional services (polish application, manicure, etc.)
While not unexpected, this ban is nonetheless a major victory for Gaëlle Lebrat-Personnaz, founder of Manucurist, who has long campaigned for non-toxic nail polish formulas: "This proves that our fight for cleaner beauty that respects women's health is meaningful and worth pursuing." Because yes, TPO-free polish exists, and Manucurist is one of the pioneer brands in this space.
Gaëlle Lebrat-Personnaz, CEO and founder of Manucurist.
TPO-free polish: more responsible formulas
How to replace TPO in gel polish?
Finding alternatives to replace risky ingredients is a core philosophy at Manucurist. Right from the formulation stage of what would become the Green Flash™ LED polish, TPO was excluded from the formula, along with other CMR-classified substances (toluene, DBP, formaldehyde, hydroquinone, etc.) as well as HEMA and di-HEMA. And that was well before these substances were banned or strictly regulated by European authorities.
To replace TPO, our lab selected an effective, safe alternative: TPO-L, another effective photo-initiator, non-toxic and not classified as CMR, fully compliant with European regulatory requirements. It ensures optimal curing of Green Flash™ polish under LED lamps, guaranteeing both high-quality results and user safety.
To sum up:
- TPO is a photo-initiator widely used in gel polishes: it enables fast curing under a lamp and the creation of the durable, hard finish typical of gel 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: placing on the market, making available (including to professionals), and use in salon services (application, manicures).
Inside the lab where Manucurist polish formulas are developed.
Green Flash™, the gel polish without compromise
By choosing Green Flash™, you are opting for a next-generation nail polish that delivers a safe manicure for your nails with zero compromise on performance. This comes with several commitments:
🌿 A nail polish formula up to 84% plant-based: this approach aims to replace synthetic chemical ingredients with plant-derived alternatives as much as possible to offer a biodegradable product and a gentler formula for your nails.
🐶 A vegan polish: like all Manucurist products, Green Flash™ contains no animal-derived ingredients and is certified by The Vegan Society.
💅 Quick, safe application and removal: Green Flash™ is proof that a plant-based polish retains fluidity and flexibility while curing quickly under an LED lamp. The same goes for removal, which, thanks to the Green Flash Gentle Remover ™, takes just 1 minute without damaging nails.
⏳ Flawless wear for up to 12 days thanks to patented KeraHCE+ technology in the Vitamin Base Coat that strengthens nails with every application and extends nail polish wear.
At Manucurist, we never stop innovating to create high-quality products that care for the health of those who use them. Formula transparency is essential to maintaining the trust of our many customers and professionals worldwide. And we intend to keep it that way for a long time to come!!
To sum up:
- Manucurist is one of the pioneer brands of TPO-free gel polish, having also banned toluene, DBP, formaldehyde, hydroquinone, HEMA, and di-HEMA from the very beginning.
- TPO is replaced by TPO-L, which ensures optimal curing of Green Flash™ under LED lamps, with no risk for the user.
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Green Flash™ polish is built on four commitments: up to 84% plant-based formula, vegan certification, quick and safe application and removal (removes in 1 minute with the Gentle Polish Remover), and wear time up to 12 days or 21 days with the Xtrem Flash™ Top Coat.
