The Cosmetic, Toiletry and Perfumery Association has published an important interpretation concerning how transition deadlines for banned cosmetic ingredients apply to products used in professional settings.
The clarification is particularly relevant to cosmetic products containing Trimethylbenzoyl Diphenylphosphine Oxide, commonly known as TPO. The ingredient is widely associated with UV gel, gel polish and other light-curing professional nail products.
Under the Great Britain Cosmetics Regulation, the deadline for placing TPO-containing cosmetic products on the market is 15 August 2026. The final date on which these products may be made available on the GB market is 14 February 2027.
What Is TPO and Where Is It Used?
Trimethylbenzoyl Diphenylphosphine Oxide is a photoinitiator used to support the curing of certain cosmetic nail products when exposed to ultraviolet or LED light.
TPO may be found in products such as:
- UV gel nail products
- Gel nail polish
- Light-curing nail coatings
- Professional manicure systems
- Other UV or LED-cured nail products
The prohibition is therefore especially relevant to manufacturers, importers, distributors and professional salons supplying or using nail cosmetics.
Key Transition Dates for TPO-Containing Products
The following deadlines apply in Great Britain:
- 15 August 2026: Final date for placing TPO-containing cosmetic products on the GB market.
- 14 February 2027: Final date for making these products available on the market.
- From 15 February 2027: TPO-containing cosmetics may no longer be sold, distributed or supplied to professional users in Great Britain.
“Placing on the market” generally refers to making a product available on the GB market for the first time.
“Making available on the market” covers subsequent supply activities within the commercial distribution chain, including sales and distribution to retailers, salons and other professional users.
Can Professional Salons Continue Using Existing TPO Stock?
According to CTPA’s interpretation, professional users will not be permitted to purchase or receive new supplies of TPO-containing cosmetic products after the making-available deadline.
However, products that were legally purchased by a salon or another professional user before the deadline may continue to be applied to clients until the existing stock has been exhausted.
CTPA states that this interpretation has been discussed with UK Trading Standards and that both parties are aligned on the approach.
In practical terms:
- Stock legally purchased by a professional user by 14 February 2027 may continue to be used in treatments.
- New TPO-containing products may not be purchased or supplied from 15 February 2027.
- Existing stock may not be resold or redistributed to another business after the deadline.
- Professionals should retain invoices and purchasing records demonstrating when the products were acquired.
This position reflects CTPA’s industry interpretation. Businesses may also wish to seek product-specific guidance from their Responsible Person, legal adviser or relevant local Trading Standards authority.
Why Is TPO Being Prohibited in Cosmetics?
The prohibition follows the classification of TPO under the Great Britain Classification, Labelling and Packaging framework as a carcinogenic, mutagenic or toxic for reproduction substance.
Under Article 15 of the GB Cosmetics Regulation, substances classified as CMR are generally prohibited for use in cosmetic products unless the applicable conditions for an exemption are met.
CTPA has emphasised that the prohibition does not result from evidence that currently marketed nail cosmetics containing TPO present a direct safety concern under their existing conditions of use. The association notes that the ingredient is typically used at low concentrations and that previous safety assessments supported its cosmetic use.
Nevertheless, its classification under GB CLP triggered additional regulatory requirements. As the necessary exemption was not established, TPO was added to the list of substances prohibited in cosmetic products.
Where Do the GB Requirements Apply?
The transition dates apply to cosmetic products placed on the market in Great Britain, which includes:
- England
- Scotland
- Wales
Northern Ireland may be subject to different cosmetic regulatory requirements and implementation dates due to its relationship with the European Union regulatory framework.
Companies operating across the United Kingdom should therefore assess products intended for Great Britain and Northern Ireland separately.
How Should Cosmetic Companies Prepare?
Manufacturers, importers, distributors and professional users should review TPO-containing products before the transition periods expire.
Recommended compliance actions include:
- Screening product formulations for TPO
- Identifying affected products and remaining stock
- Documenting placing-on-the-market dates
- Retaining supplier invoices and purchase records
- Stopping the placement of new products after 15 August 2026
- Completing supply and distribution activities by 14 February 2027
- Transitioning to TPO-free formulations
- Updating labels and product information files
- Informing distributors, retailers and professional salon customers
- Assessing Northern Ireland and EU requirements separately
Impact on the Professional Nail Product Sector
The ban is expected to have a significant operational impact on companies involved in professional gel nail and manicure products.
Manufacturers may need to reformulate products, importers may need to revise sourcing plans and distributors will need to manage existing inventory against the applicable deadlines. Professional salons should review ingredient lists and retain evidence showing that affected products were purchased before the making-available deadline.
Failure to plan for the transition could result in unsaleable stock, product disposal, supply disruption and additional compliance costs. Companies should therefore complete their transition strategies well ahead of the August 2026 and February 2027 deadlines.