TPO-free gel polishes are products that do not contain the photoinitiator TPO (INCI: Trimethylbenzoyl Diphenylphosphine Oxide). From 1 September 2025, cosmetic products containing TPO are banned in the European Union, but gel polish itself is not banned: gel polishes with other photoinitiators are perfectly legal. "HEMA free" is a different, voluntary claim: it means the formula contains no HEMA monomer, which is associated with contact allergy.
What is TPO and why was it in gel polishes
TPO is a photoinitiator, i.e. a substance that, when exposed to a UV or LED lamp, starts the curing reaction of the gel. It cures the coating quickly and reliably, which is why it was used for a long time in gel polishes, base coats, top coats and building gels.
Before the ban, the EU Cosmetics Regulation permitted TPO only in professional artificial nail systems, at a concentration of no more than 5%.
What exactly the EU banned from 1 September 2025
TPO was classified as a CMR substance of category 1B, as toxic for reproduction. Such substances are prohibited in cosmetics, so Commission Regulation (EU) 2025/877 moved TPO onto the list of prohibited substances – Annex II of the Cosmetics Regulation. The regulation applies from 1 September 2025.
What this means in practice (based on the questions and answers published by the European Commission):
- There is no transition period. From 1 September, products containing TPO may not be placed on the market or supplied, even if they were already in stock.
- Salons cannot use them on clients. Providing a service counts as supplying a product in the course of a commercial activity, regardless of when the product was bought.
- A "for professional use only" label does not exempt a product from the ban.
- Other gel products remain legal. The ban applies only to products that contain TPO.
The same regulation also added other CMR substances to the list of prohibited substances, including N,N-dimethyl-p-toluidine (CAS 99-97-8), so it is worth reviewing the ingredients not only of gel polishes but of your other nail products too.
What is HEMA and why is it linked to allergies
HEMA (2-hydroxyethyl methacrylate) is a monomer used in base coats, primers and gels because it improves adhesion to the nail. It is not banned, but since 2021 the EU has applied restrictions: nail products containing HEMA and Di-HEMA Trimethylhexyl Dicarbamate are for professional use only, and the packaging must carry warnings that the product is intended for professionals only and may cause an allergic reaction.
Allergy to methacrylates and acrylates usually develops when uncured product repeatedly gets onto the skin – the cuticles, side walls or the technician's fingers. That is why "HEMA free" only means that HEMA is not in the formula. Other acrylates remain and can also cause sensitisation, so clean working – product only on the nail – and full curing always matter. We covered the symptoms and what to do if an allergy has already developed in our article allergy to gel polish.
How to recognise TPO-free gel polishes: the INCI list
The ingredients are listed on the packaging or in the product description under international INCI names. Look for the following entries:
| INCI name | What it is | Status in the EU |
|---|---|---|
| Trimethylbenzoyl Diphenylphosphine Oxide | TPO, photoinitiator | Banned from 2025-09-01 |
| Ethyl Trimethylbenzoyl Phenylphosphinate | TPO-L, another photoinitiator | Not covered by Regulation (EU) 2025/877 |
| HEMA | 2-hydroxyethyl methacrylate, monomer | Permitted for professionals only, with warnings |
| Di-HEMA Trimethylhexyl Dicarbamate | Monomer | Permitted for professionals only, with warnings |
TPO and TPO-L sound similar, but they are different substances. For example, the description of our Strong Shimmer base states "HEMA free", while its ingredients list TPO-L as the photoinitiator. The Primer adhesion product is marked as free from HEMA and TPO. If you can't find the ingredients on a product page, ask us – we'll check for you.
Do TPO-free polishes cure differently – lamp power and time
Different photoinitiators respond to slightly different light wavelengths, so the curing settings are always set by the product manufacturer. Practical tips:
- Follow the curing time and lamp type specified by the manufacturer – especially when switching to a new system.
- The most versatile choice is a hybrid UV/LED lamp that covers both ranges.
- Apply thin layers: the underside of a thick layer may stay uncured.
- If the coating stays soft where it shouldn't, the problem is often the lamp or the technique rather than the polish. We wrote about lamp power in the article UV or LED lamp: which to choose.
Insufficiently cured product doesn't just wear worse – uncured residue that gets onto the skin increases the risk of allergy.
What to do with leftover polishes containing TPO
- Check all your stock – not just colours, but also bases, top coats and gels. Look for the INCI name Trimethylbenzoyl Diphenylphosphine Oxide.
- Set aside products with TPO and do not use them on clients, sell them or give them away.
- Contact your supplier and ask whether they accept such products back.
- Dispose of them properly. Do not pour them down the drain or throw them out with household waste. Businesses hand their waste to a waste handler, while private individuals take it to bulky and hazardous waste collection points. Check the exact procedure with your regional waste management centre.
Whether products you have already bought may be used personally is not addressed separately in the Commission's questions and answers. Our advice is not to use them any more, because TPO was banned over its possible effect on fertility.
How to talk to clients about it
- Explain briefly: gel polish is not banned, one ingredient is, and you don't use it.
- Keep the ingredients to hand. Hygiene Standard HN 117 obliges a beauty service provider to give information about the cosmetic products used when a client asks.
- Don't promise that "HEMA free" means "hypoallergenic". Such a product reduces one risk but does not eliminate it.
- Watch for reactions. If a client's skin around the nails itches, reddens or swells after treatments, advise her to see a dermatologist and not to repeat the treatment until the cause is found.
If you are choosing new bases, compare their types in the article base, rubber base and top coat, and you'll find all our bases and gel polishes in the catalogue.
Frequently asked questions
Is gel polish banned?
No. From 1 September 2025, only cosmetic products containing TPO (Trimethylbenzoyl Diphenylphosphine Oxide) are banned in the EU. Gel polishes with other photoinitiators are legal.
Can I still use gel polishes with TPO?
In a salon, no: from 1 September 2025 they may not be used on clients, sold or given away, even if bought earlier. We also don't recommend using them at home.
What is the difference between TPO-free and HEMA-free polishes?
"TPO-free" means the product lacks the photoinitiator banned in the EU – this is a mandatory requirement for all products sold in the EU. "HEMA free" is a voluntary claim showing that the HEMA monomer, often linked to contact allergy, is not present.
Do TPO-free polishes last as long?
The longevity of the coating depends not only on the photoinitiator but also on product quality, nail preparation and proper curing. Follow the lamp type and curing time specified by the manufacturer.
Where can I take banned nail polishes?
Do not pour them down the drain. Private individuals can take them to bulky and hazardous waste collection points, while businesses should hand them to a waste handler. Check the exact procedure with your regional waste management centre.