Don’t discard your products containing silver pigment just yet!
Let’s start with the most important point: if you still have a product whose label lists CI 77820, don’t throw it away or discard it just yet.
CI 77820 is the INCI identifier for silver pigment powder, which became prohibited in cosmetics from 1 May 2026, including nail products.
Now, however, it looks like the rules are about to take a turn.
What has changed around silver pigment?
In August 2025, the European Commission received a new study report that revealed previously unknown information about the absorption of silver pigment through the skin.
In light of this, the SCCS, the Scientific Committee on Consumer Safety, issued a new scientific opinion.
This new position is now being incorporated into legislation, and the expected amendment will ease the current ban on silver pigment.
In other words, this does not mean that every CI 77820 will automatically be fine from now on. It means that the use of silver pigment may be permitted again if certain conditions are met.
And what matters most to us:
in nail cosmetic products, it may be present at a maximum concentration of 0.3%.
For a pigment, this is a completely realistic amount, as a gel polish or other coloured nail product typically does not require a higher concentration than this.
Not every CI 77820 automatically gets the green light!
This is where the regulation gets a little more complicated.
CI 77820 covers several types of silver pigment, while the expected relaxation applies only to specific types.
One of the conditions is particle size.
The particles of the permitted silver pigment must be larger than 100 nanometres but smaller than 1 millimetre.
If nanometres are not exactly a unit you use every day either: 1 millimetre equals 1,000,000 nanometres.
So we are still talking about very small particles, just not the smallest category.
The second condition is that the silver pigment must have a porous and sintered structure.
That may not sound much friendlier than the legislation itself at first, so let’s translate it into plain language.
During sintering, very small metal particles are joined together so that larger particles are formed. Put simply, porous means that the surface of the particle has a structure with tiny openings.
According to the new studies, this type of silver particle cannot be absorbed through the skin. This is one of the reasons why the previous regulation may now be relaxed.
There is one more condition, but it affects us less
Silver pigment cannot be used in products where there is a risk of inhalation.
This is less relevant for nail cosmetics. Silver pigment will not become airborne from a gel polish or gel in the same way it could, for example, from a powder-based make-up product.
For us, the key points are therefore the particle size, the particle structure and the maximum concentration of 0.3%.
How do you know whether the product you have meets these requirements?
And this brings us to the question that probably comes up first for most nail techs.
You have a product in front of you, and the ingredient list says:
CI 77820.
But how do you know whether the pigment is the right size? Whether it is porous and sintered? Whether its concentration is below 0.3%?
The short answer: you don’t.
And you are not the one who has to determine this.
These are technical details that you cannot check from a product label. Verifying compliance is the responsibility of the manufacturer and the brand.
So if the amendment enters into force, the fact that CI 77820 appears on a product’s ingredient list will not in itself mean that there is a problem with the product.
The question will be whether the silver pigment it contains meets the required conditions.
And that is not something you need to investigate at home or in your salon.
So what should you do with the products you already have?
Don’t discard them automatically.
If you have a product that lists CI 77820 and you have not thrown it away yet, it is worth holding on to it.
Based on the current situation, it very much looks as though silver pigment will be permitted again under specific conditions, with a maximum concentration of 0.3% in nail cosmetics.
If an authority later wants more detailed information about the particle size, structure or concentration of the pigment in a particular product, that is the responsibility of the manufacturer or the brand.
When is the amendment expected?
The amendment to the legislation is currently expected around the fourth quarter of 2026.
Even more importantly, the change is expected to apply retroactively to 1 May 2026, the date when the current ban on silver pigment came into force.
That is why we are saying that there is no reason to rush to throw away products containing CI 77820 right now.
And what about regulatory inspections?
During this transitional period, major salon inspections specifically because of silver pigment are not really expected.
The logic is simple: if an amendment is already being prepared to settle the situation retroactively, there would be little point in issuing penalties now in cases that may soon be regulated differently.
That does not mean, however, that ingredient-related rules are not checked at all.
In the case of TPO, for example, we do not know for certain about inspections carried out in salons, but inspections did take place at distributors and stores, both in Hungary and abroad.
So the regulations are taken seriously. The current situation simply seems to be more of a transitional period.
Sound familiar? We have seen something similar with TPO before
If you feel like it is becoming almost impossible to keep track of which ingredient is banned, which one gets an exemption and when the next amendment is coming, that is completely understandable.
And this is not the first case like this.
TPO was already completely banned in cosmetics once in 2013. A few months later, however, the regulation was amended and TPO was permitted again in nail cosmetics at a maximum concentration of 5%.
Then, in 2025, twelve years later, it was finally fully banned.
So it is by no means unprecedented for the regulation of an ingredient to change as a result of new research findings.
Now it looks like the story of CI 77820 has reached a similar turning point.
What should you take away from all of this?
If you remember just one thing, let it be this:
if you have a product containing CI 77820, don’t throw it away just yet.
Based on the information currently available, the regulation is expected to be relaxed, and silver pigment will once again be permitted in nail cosmetics under specific conditions at a maximum concentration of 0.3%.
And it is not your job to determine whether the pigment in a particular product technically meets these requirements.
Regulations have been changing quickly lately, and they are not always easy to follow. That is exactly why we keep track of these changes, so you know in time what is changing, what you need to pay attention to and what actually affects your day-to-day work in the salon.
