New ingredients – new labels: what the TPO ban means for the cosmetics industry

Since 1 September 2025, it has been official: the substance TPO (trimethylbenzoyl diphenylphosphine oxide) may no longer be used in cosmetic products in the EU. This primarily affects UV gels and UV polishes, a key segment of nail cosmetics. For manufacturers and studios, this means several steps: developing new formulations, disposing of old stocks and updating labels and packaging.

And this is by no means an isolated case. In the cosmetics industry, legal requirements are constantly changing – today it's nail polish, tomorrow it's shampoo or skin care. Those who fail to respond in time risk not only regulatory consequences, but also gaps in their product range and frustrated customers.

What is TPO and why is it prohibited?

TPO is a so-called photoinitiator. It ensures that gels and varnishes cure quickly and reliably under UV light. This is precisely why it has long been standard in nail cosmetics.

The problem: TPO has been classified by the EU as a Category 1B CMR substance – meaning it is potentially carcinogenic, mutagenic and toxic to reproduction. Even though the studies are not conclusive in all respects, the EU applies the precautionary principle: substances with this risk may no longer be used in cosmetic products.

For you as a manufacturer, the TPO ban means one thing above all else: a rapid changeover. Products containing TPO may no longer be produced, sold or delivered since 1 September. Remaining stocks must be taken out of service, while new formulations with alternative photoinitiators, such as TPOL, are already in use.

This goes hand in hand with the obligation to adapt labels and packaging: TPO is listed in the INCI as trimethylbenzoyl diphenylphosphine oxide and must be removed or replaced. Anyone who delays making these adjustments risks not only legal consequences and fines, but also delivery stoppages and the loss of market share.

What does this mean for labels and packaging?

The cosmetics industry in particular shows how critical this issue is. Ingredients change particularly frequently in this sector – whether due to new legal bans such as TPO, stricter labelling requirements or optimised formulations. For packaging, this means that labels often have to be updated at very short notice to comply with legal requirements and ensure that products remain on the market without delay.

This is a real challenge for many companies. Those with multiple varieties or series in their product range must check each individual label and adjust it if necessary. Long delivery times or rigid minimum quantities are hardly feasible in such situations. That is why flexible solutions are needed. From small test runs to legally compliant overlay stickers for existing packaging to the rapid reprinting of entire series. This is the only way you, as a manufacturer, can ensure that your products remain available despite new regulations and that there are no gaps in your product range.

All this shows: flexibility in labelling and packaging is not just a nice-to-have, but a must-have.

Practical help for manufacturers: How Labelisten provides support

When regulations change, one thing matters above all else: speed. You need labels and packaging that comply with the law, and you need them immediately. This is exactly where Labelisten comes in.

We help you get the right labels quickly and easily. No minimum quantities and no long waiting times. Whether you need custom designs, small or large print runs, overlay solutions for existing packaging or completely new products, we ensure that your products are ready to go back on the market in no time.

You will be supported by Anna-Lena Kaiser. She specialises in regulatory requirements in the cosmetics industry and checks whether all legal requirements for labels are met: from ingredient information (INCI) and labelling requirements to CLP rules. With her expertise, you can ensure that your packaging is legally compliant, up to date and reliable on the market.

In situations such as the current TPO ban, it is crucial to be able to react immediately. With us Labelisten  at your side, you can be sure that your labels or packaging will be adapted quickly. Compliant, reliable and without delays. This ensures that your products remain on the market and your customers are supplied.

Conclusion

New ingredients, new regulations, new labels. With our online calculator, you can recalculate your labels at any time and order them directly – with no minimum quantity and with prices in real time. Everything is done via your personal ordering system: create items, upload designs, place repeat orders – you can order your labels in just a few clicks.

This allows you to remain flexible, save time and ensure that your products are always labelled correctly.