TPO in nail products in 2026: checking INCI and old salon stock
- 14 min reading time
Since 1 September 2025, cosmetic nail products containing TPO (Trimethylbenzoyl Diphenylphosphine Oxide) may no longer be sold, commercially supplied or used by professionals on clients in the European Union. In October 2026 there is no grace period to sell or finish old salon stock. An unopened bottle bought before that date is not an exception. Read the actual ingredients list, keep any unclear batch away from the working station and obtain a verifiable answer from the supplier before considering its return to service.
For a new purchase, the phrase 'TPO-free' on a website is not enough on its own. Match the exact product, variant, packaging and, if needed, lot number. TPO-free does not automatically mean HEMA-free, hypoallergenic or suitable for every client. Two products available to compare at Prohaar — Claresa Base Power Clear 01 and Claresa Top Bubble Gold Matt No Wipe, both 5 g — provide concrete examples of the identification task. They are not presented here as individually certified batches.
This is a purchasing and stock-check guide for professional salons, not a nail treatment tutorial. The legal position is set out in the European Commission's TPO questions and answers and Regulation (EU) 2025/877. The composition of the particular item in your hand remains a separate factual question that has to be checked.
What changed in September 2025?
TPO is a photoinitiator formerly used in some cosmetic nail products that cure under UV or LED light. The substance was harmonised-classified as toxic to reproduction, category 1B. Commission Regulation (EU) 2025/877 consequently moved it to Annex II of the EU Cosmetics Regulation, which lists prohibited ingredients. This concerns the specific substance with CAS 75980-60-8. It is not an automatic ban on every chemical with a similar-looking segment such as 'phosphinate' in its name.
Applying a cosmetic product in a paid nail service is part of a commercial activity. The Commission clarifies that a professional cannot use a TPO-containing cosmetic on clients from 1 September 2025, even if it was legally purchased earlier. Commercial sale, transfer and giving the product away are also covered. A salon therefore needs a different suitable product, or must decline to provide the particular treatment with the noncompliant material, rather than making an exception for stock already purchased.
An older scientific opinion once examined a maximum of 5% TPO in particular professional UV-cured nail gels under specified conditions. This was not a permission to continue using TPO in 2026. Following the new classification there was no approved derogation. The argument that a product fully polymerises under the lamp does not override the ban either. The relevant legal question is the prohibited ingredient in the cosmetic formulation, not an individual claim about curing or exposure.
Keep this separate from conversations about purely private possession: this guide addresses salon work and commercial supply, not a claim that private storage establishes a professional exemption. The operational rule is straightforward — products containing TPO do not go onto clients, into retail sales or into professional giveaways. For a national explanation alongside the Commission text, the Belgian Federal Public Service for Health explicitly identifies use during a paid service as part of the prohibition.
What exactly should the INCI say?
The principal cosmetic ingredient name to look for is Trimethylbenzoyl Diphenylphosphine Oxide. A technical document may use diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide for the same substance, identifiable by CAS 75980-60-8. Compare the complete ingredient identity. A product's colour, date of purchase, brand, UV/LED symbol or familiar collection name cannot answer the TPO question in isolation.
Find 'Ingredients' on the bottle, carton or a fold-out label. Front-of-pack wording such as 'acid-free', 'no wipe', 'vegan', 'new formula' and 'professional' is not a substitute for the ingredients declaration. Nor does silence in a short online description prove the substance is absent. If the information is obscured, incomplete or illegible, regard the status as unresolved until you obtain a complete declaration relating to the actual variant and, where necessary, batch.
Names can look similar without being chemically identical. Claresa's current online ingredient list for Base Power 01 includes Ethyl Trimethylbenzoyl Phenylphosphinate and HEMA. The former is not the same INCI name as TPO in Regulation 2025/877. Yet a shared word fragment does not prove that any particular delivered batch lacks every prohibited substance. Online formulas may change and the manufacturer's webpage is a useful comparison, not a replacement for the label and batch-specific supplier confirmation if there is a discrepancy.
HEMA is a different substance with its own requirements and allergy considerations. The TPO rule does not turn every HEMA-containing product into a TPO violation, but a 'TPO-free' claim is not evidence of 'HEMA-free', 'allergy-free' or 'hypoallergenic'. Avoid generalising the safety of an entire gel collection from the name of one photoinitiator. Ingredient verification is not a clinical assessment of a skin reaction, and it does not remove the need to observe the particular manufacturer's instructions and warnings.
Check the product actually received
Start with the physical bottle in the salon, not a historic invoice or the image from an advertisement. Record the brand, range, product function (base, colour, builder or top), variant, net quantity, article code and batch or lot identifier. Then read the complete INCI, EU responsible-person details and applicable warnings or instructions. The lot code alone does not reveal the composition, but it lets the manufacturer identify the relevant formula version when answering a question.
When receiving stock, distinguish three questions. Is this exactly the product and variant you ordered? Is the ingredients information on the delivered packaging complete and readable? Do the instructions from the manufacturer or EU responsible person correspond to the exact version supplied? If a product webpage advertises a new formulation while the physical carton carries an older list, keep the evidence and ask for an explanation. Do not silently choose whichever statement happens to support the preferred purchasing decision.
Small bottles often carry ingredients on a side label, outer carton or peel-back sticker. Inspect the rear and bottom and any symbols directing you to an insert. A photograph showing only the front design cannot certify a formula. A gallery image or PDF of the rear label can help, but first match the exact product, size, version and ideally the lot or revision date. Instructions for a similar top with a different effect are not proof of what is in the bottle you intend to use.
For an auditable routine you could store one photograph of the actual label, a readable lot number and the date of the check next to the stock record. This is an editorial suggestion for internal management, not a prescribed EU spreadsheet. The aim is to let a second employee identify the same item without guessing from a generic shade name. Client information is not needed for this stock record. Clear physical storage labels also prevent unresolved variants finding their way back into the active tray.
Two Claresa products as examples
A product type or brand alone does not determine a formula. A clear base and a decorative matte top have different functions, and two formulas from one manufacturer may change independently. Prohaar lists Claresa Base Power Clear 01, 5 g and Claresa Top Bubble Gold Matt No Wipe, 5 g. We use these as examples of matching a bottle to its identity and documentation, not as a statement that any unexamined lot is TPO-free or HEMA-free.
The base is identified by code 148385, EAN 5903819820737, net content 5 g. '01' refers to the clear Base Power variation, while 5 g is product quantity, not an ingredient concentration or recommended dose. The original Claresa Base Power 01 page publishes an online INCI containing HEMA and Ethyl Trimethylbenzoyl Phenylphosphinate. It does not identify the precise bottle in your drawer. Compare that information against the received label and ask for the relevant revision or lot details where they differ.
The top is code 148946, EAN 5903819819144, also 5 g. The complete name matters: Gold Matt No Wipe describes a transparent matte top with golden particles and, according to the description, no dispersion layer requiring a wipe. It is not the same product as a plain Top Mat No Wipe, Bubble Black Matt or a later gold top from another series. The exact 148946 supplier specification supports the identity and size but does not provide a complete, independently verified INCI for a particular delivered batch. Neither TPO-free nor HEMA-free follows from that description alone.
| Checkpoint | Base Power Clear 01 | Bubble Gold Matt No Wipe |
|---|---|---|
| Purpose | Clear hybrid base | Matte top with gold particles |
| Code and amount | 148385 / 5 g | 148946 / 5 g |
| EAN | 5903819820737 | 5903819819144 |
| Available documentation | Manufacturer online INCI | Exact product characteristics |
| Still check on receipt | Physical label and lot | Physical label, lot, full INCI |
This table supports purchasing and product identification; it is not a list of certified TPO-free formulas or a compatibility statement. Any combination of layers and curing parameters must follow instructions for the exact manufacturer system, rather than being inferred from a similar product name or an old online description.
Audit the old salon stock
Review all relevant UV/LED-cured cosmetics, including bases, builders, polygels, coloured products, effects and tops. Do not limit the exercise to this month's best sellers. For each physical item, establish its exact identity, read the ingredients and resolve inconsistencies. Previous lawful purchase, an unopened seal and a familiar shade do not create an exemption for TPO-containing products after the relevant date.
A practical inventory can use three categories: the checked version has adequate evidence that the prohibited TPO is absent; TPO is explicitly identified; or evidence is insufficient. Keep the last two groups out of the work area while their appropriate outcomes are determined. The second group must not return to professional use or commercial supply. 'Unresolved' never means 'probably acceptable'; the first category also remains subject to all other product requirements, not just the TPO rule.
Do not try to dispose of TPO-containing inventory by selling it on clearance, offering it free to another stylist or reserving it for a paid training session. These do not create an exemption from commercial activity. Record the decision and ask the supplier about take-back or the relevant local disposal route. Do not assume a universal waste classification or advise emptying the contents down a drain: waste handling depends on local requirements and the product's properties.
For a large collection a compact stock list may be enough: brand, line, variant, SKU, lot, source of information, date, decision and follow-up. One colleague can identify physical containers, another can review uncertain answers. The objective is a usable, verifiable storage system, not paperwork for its own sake. It is especially important when visually similar packaging from different production periods is stored together in one drawer.
Order replacement products deliberately
Specify the function first: do you need a clear base, a colour, a builder or a decorative finishing coat? Then compare the exact current variant in Prohaar's nail product range with the actual delivered packaging. A commercial product name lets you place an order; it does not on its own certify the ingredients. An appealing finish or a claim about long wear is unrelated to the regulatory question concerning TPO.
If the evidence is not sufficient, ask your supplier four targeted questions. Does the declaration identify this full name and exact article code? Which formula version will be supplied? Can you provide the complete current INCI? How does it correspond to the lot number of the received bottle? Also identify the EU responsible person and relevant product warnings. 'Our range has been updated' does not establish which version of a similarly named bottle is sitting in a particular salon.
Compliance with one ingredient ban is only one part of responsible purchasing. You must still consider product instructions, system compatibility, warnings and the correct curing conditions for the version bought. Similar colours and identical UV/LED symbols do not guarantee interchangeable procedures. A reformulated product should not be promised to have exactly the same results or be free of allergy concerns unless the specific evidence supports those claims.
Three example decisions
Case 1 — an unopened gel purchased in 2024. A stylist finds a sealed bottle whose INCI clearly lists TPO. Its purchase date and unopened condition do not allow a final paid treatment. The salon removes it from the workstation, records its identity and determines an appropriate return or disposal route. This is a hypothetical case illustrating the legal position, not an account of an in-house test.
Case 2 — an unreadable ingredients label. A supplier webpage shows a new-looking package, while the physical bottle lacks a readable complete declaration. A 'TPO-free' badge on its front is not enough to resolve the question. Examine the carton and peel-back label, note the lot and obtain corresponding information from the supplier. Do not place the product back in use merely because a short marketing paragraph did not mention TPO.
Case 3 — ordering a base and an effect top. The salon wants a clear foundation and a matte gold-particle finish. Base Power Clear 01 and Bubble Gold Matt No Wipe have different identifiers and functions. Online ingredients supplied for the base cannot be transferred to the top. If one shipment is fully documented and the other lacks a matching ingredient declaration, decide their status separately instead of assigning both the favourable answer for one.
Frequently asked questions
May a salon finish a TPO gel bought before September 2025?
No. The Commission explains that there is no sell-through or use-up period for these cosmetics. Professional use on clients has been prohibited from 1 September 2025 regardless of the purchase date.
Is every product containing “benzoyl” or “phosphinate” in its INCI prohibited?
No. The specific substance is Trimethylbenzoyl Diphenylphosphine Oxide, CAS 75980-60-8. Check the complete chemical identity, rather than declaring different but similarly spelled names identical.
Does TPO-free also mean HEMA-free or hypoallergenic?
No. These are separate ingredients and claims. The TPO check does not replace a review of HEMA, other substances, warnings or possible allergic reactions to a cosmetic product.
What if the only ingredients list is on a website?
Treat it as a starting point, not final batch verification. Compare it with the received bottle or carton and obtain version- or lot-specific information if there is a mismatch or missing text.
Can the two Claresa products share one ingredient check?
No. The base and matte gold top are different products with distinct codes and purposes. Review the physical documentation for each separately; one product's ingredient list cannot certify the other.
Can a salon give old TPO stock away rather than use it?
Not as a workaround. The Commission clarifies that free commercial transfer is also prohibited. Remove the product from business stock and establish the suitable return or local disposal process.
What belongs on a one-page stock audit?
The full name, variant, size, SKU, lot number, readable INCI, verification date and source, decision and follow-up action. Those details allow a colleague to locate the same bottle without guesswork.
Make the final purchasing decision
Choose the needed function, then verify the actual received formula. Compare Claresa Base Power Clear 01 or Claresa Bubble Gold Matt No Wipe and browse other options in Prohaar nail care. Buying the right type of base or top and demonstrating that a particular lot meets the TPO rule are two distinct decisions; neither replaces the other.
Prohaar editorial team · Checked 14 October 2026. Legal references: European Commission and Regulation (EU) 2025/877. Online product specifications do not certify batches that have not been verified.