July and August 2026 mark one of the biggest regulatory changes for the UK nail industry in recent years. Whilst much of the attention has focused on cosmetic manufacturers generally, the changes have particular significance for professional nail products because one commonly used ingredient in UV and LED gel systems, Trimethylbenzoyl Diphenylphosphine Oxide (TPO), is caught by the new rules.

If you own a nail salon, manufacture gel products, distribute professional nail systems or import products into Great Britain, understanding the deadlines is essential. Failure to comply could result in products being withdrawn from the market and potential enforcement action.

Why are the regulations changing?

Following scientific assessments into cosmetic ingredients classified as carcinogenic, mutagenic or toxic for reproduction (CMR), the UK has amended the retained Cosmetics Regulation through the Cosmetic Products Regulation (Restriction of Chemical Substances) (Amendment and Transitional Provisions) Regulations 2026. These amendments introduce new ingredient prohibitions, updated labelling requirements and transitional periods for existing stock. 

CMR substances are chronically toxic chemicals which can cause significant health complications following exposure. The severe risks to health have called for tighter regulations in order to protect individuals and reduce the risks to a minimum.

What happened on 15 July 2026?

The first phase of the amendments took effect on 15 July 2026.

From this date:

• products containing the UV filter 4-MBC (Enzacamene) can no longer be placed on the Great Britain market;
• new formaldehyde labelling requirements began to apply where relevant; and
• transitional arrangements started for products already lawfully placed on the market before the deadline. 

Although these changes primarily affect sunscreen and certain preserved cosmetic products, they form part of the wider package of reforms that businesses in the beauty sector should understand.

What changes on 15 August 2026?

The date that has attracted the greatest attention within the nail industry is 15 August 2026.

From this date, cosmetic products containing a number of newly prohibited CMR substances can no longer be placed on the market in Great Britain. One of those substances is:

Trimethylbenzoyl Diphenylphosphine Oxide (TPO)

TPO is a photoinitiator commonly used in UV and LED cured gel nail systems because it assists the curing process under UV or LED lamps.

As a consequence:

• manufacturers cannot place new TPO-containing products onto the GB market from 15 August 2026;
• importers and distributors must ensure products supplied after that date comply with the new rules; and
• businesses should already have identified compliant alternative formulations where necessary. 

Can salons still use existing stock?

This is where many businesses become confused.

The regulations distinguish between:

• placing a product on the market, and
• making it available on the market.

Products lawfully placed on the market before the relevant deadline benefit from transitional provisions.

For TPO-containing products, the sell-through period runs until 14 February 2027. After that date, distributors can no longer supply those products to salons.

Importantly, current guidance indicates that professional nail technicians who already own compliant stock purchased before the deadline may continue to use that stock after February 2027, although they will no longer be able to purchase additional TPO-containing products in Great Britain. Businesses should nevertheless keep records demonstrating when stock was acquired and continue to monitor any further guidance issued by the Office for Product Safety and Standards (OPSS). 

Who needs to take action?

The new rules affect more than manufacturers.

Businesses that should review their compliance include:

• nail salons;
• freelance nail technicians;
• cosmetic manufacturers;
• importers;
• wholesalers;
• distributors;
• online retailers;
• private label brands
• Each business should review product inventories, ingredient specifications, supplier assurances and Product Information Files (PIFs) where applicable.

What should nail businesses do now?

Practical steps include:

• auditing all gel nail products currently in stock;
• identifying whether any products contain TPO;
• speaking with manufacturers or suppliers regarding reformulated products;
• reviewing purchasing arrangements before the February 2027 deadline;
• updating compliance documentation where required; and
• ensuring staff understand which products may continue to be purchased and supplied.

Could businesses face enforcement action?

Yes.

The Office for Product Safety and Standards (OPSS) is responsible for enforcing the UK Cosmetics Regulation. Businesses placing non-compliant cosmetic products on the market may face investigations, product withdrawals, improvement notices and other enforcement action depending upon the circumstances. Recent OPSS publications also demonstrate increasing regulatory scrutiny of cosmetic product compliance and notification requirements. 

Frequently Asked Questions

Does the TPO ban mean I have to throw away all my gel nail products?

Not necessarily. The regulations distinguish between products being placed on the market and those that have already been lawfully supplied. Products that were lawfully placed on the Great Britain market before the relevant deadline may benefit from transitional arrangements. Whether you can continue to use existing stock will depend on the applicable transitional provisions and any further guidance issued by regulators.

What is TPO and why has it been banned?

Trimethylbenzoyl Diphenylphosphine Oxide (TPO) is a photoinitiator commonly used in UV and LED gel nail products to help the gel cure under a lamp. Following scientific assessment, it has been classified as a substance that can no longer be used in cosmetic products under the UK Cosmetics Regulation, leading to its prohibition.

When do the new rules come into force?

The regulatory changes are being introduced in stages.

• 15 July 2026 – the first package of amendments takes effect, including changes affecting certain cosmetic ingredients and labelling requirements.
• 15 August 2026 – additional restrictions apply, including the prohibition of TPO in cosmetic products placed on the Great Britain market.
• 14 February 2027 – deadline to sell existing stock of items containing TPO

Can nail salons still buy products containing TPO after 15 August 2026?

No. Once the prohibition takes effect, TPO-containing cosmetic products cannot generally be placed on the Great Britain market. Salons should therefore ensure future purchases are from reformulated, compliant product ranges.

What happens to products already in my salon?

Businesses should identify when products were supplied and retain appropriate purchasing records. Existing stock may benefit from transitional arrangements, but businesses should ensure they understand the relevant deadlines and keep up to date with any further regulatory guidance.

Do these rules apply to every nail salon?

Yes. Although manufacturers and importers have the greatest compliance obligations, nail salons, mobile nail technicians and beauty businesses should also ensure the products they purchase and use comply with the law.

Do the regulations affect online retailers?

Yes. Online retailers, wholesalers and distributors supplying cosmetic products into Great Britain must ensure that products offered for sale comply with the UK Cosmetics Regulation.

How can I check whether my gel products contain TPO?

Review the ingredient list on the product packaging or request the ingredient specification or safety documentation from your supplier. TPO may appear as Trimethylbenzoyl Diphenylphosphine Oxide or by its recognised INCI name.

What should manufacturers and distributors do now?

Businesses should:

• review all affected product ranges;
• identify products containing restricted substances;
• work with suppliers on compliant reformulations;
• update Product Information Files where necessary;
• review product notifications; and
• ensure any remaining stock is managed in accordance with the transitional arrangements.

What enforcement action can be taken?

The Office for Product Safety and Standards (OPSS) has powers to investigate suspected non-compliance and may require products to be withdrawn, recalled or removed from sale. Depending on the circumstances, businesses may also face further enforcement action where non-compliance continues.

Will there be further cosmetic regulation changes?

Possibly. The UK Cosmetics Regulation continues to evolve following scientific advice and regulatory reviews. Manufacturers, distributors and beauty businesses should monitor developments to ensure ongoing compliance.

When should I seek legal advice?

You should consider obtaining legal advice if:

• you receive correspondence from the OPSS or another regulator;
• you are uncertain whether products can continue to be supplied;
• you are importing cosmetic products into Great Britain;
• you are reformulating products to comply with the new rules; or
• you are facing an investigation or proposed enforcement action.

How JMW Solicitors can help

Our Business Crime & Regulatory team advises manufacturers, importers, distributors, wholesalers and beauty businesses on cosmetic product regulation, OPSS investigations and regulatory compliance. Whether you need advice on the TPO ban, product compliance or responding to regulatory enquiries, our team can help you minimise regulatory risk and protect your business.