What Should You Do with Opened TPO-Containing Materials?

What happens if, after September 1, 2025, you still have materials containing TPO in your drawer?

As I mentioned in a previous blog post, on January 5, 2024, the European Commission adopted Delegated Regulation (EU) 2024/197, which amends Regulation (EC) No 1272/2008 concerning the classification and labeling of certain substances.

This amendment classifies TPO (2,4,6-Trimethylbenzoyl-diphenyl phosphine oxide) as a Category 1B CMR substance (toxic to reproduction), and this classification will become effective on September 1, 2025.

With this reclassification, TPO will be added to the list of banned substances for cosmetic products, which is included in Annex II of the EU Cosmetics Regulation (Regulation (EC) No 1223/2009).

As a result, cosmetic products containing TPO can no longer be placed on the market or sold within the EU.

So far, so clear. But what about materials that nail technicians purchased before September 1, 2025, which may still contain TPO?

Can you still use products containing TPO after September 1?

Or should you just throw them all away?

It’s a fair question, and the answer is unclear, because the regulation does not explicitly address this scenario. However, in our opinion, it is unreasonable for legislators to expect that every opened product containing TPO should be thrown away immediately after September 1.

Especially since, under the law, TPO-containing products can still be sold until August 31, and obviously, they won’t expire overnight.

Furthermore, even if the ban applied to already opened products, it is highly unlikely that anyone would actually be penalized for using them. However, I want to emphasize that this is my personal opinion, not an official legal statement!

It’s also important to note that nail cosmetics containing TPO (with a legally permitted maximum of 5%) are still in use today. If they were considered highly unsafe, regulators would have immediately banned them rather than allowing an extended transition period for manufacturers and distributors.

So, there’s no need to panic. Instead, I recommend that you start testing TPO-free alternatives now, so the transition is as smooth as possible. What’s certain is that after September 1, 2025, only TPO-free formulas will be available on the market.

And now, I have to smirk a little behind my hand, because let’s be real—there will definitely be some brands (mainly from Asia) that will continue producing with TPO but will simply leave it off or alter the ingredient list on the label. Problem solved—the Chinese way! Just like they handle CPNP notifications.

What is a CPNP notification?

It’s something you should know about for your own safety! Read more here!

Best regards,
Laci Gyimesi
CEO of Mystic Nails