EU Cosmetics Regulation 2025: Key Ingredient Changes and What They Mean for Pigment Buyers

The most significant change for nail product manufacturers is the reclassification of TPO (diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide), a photoinitiator commonly used in UV-cured gel nail systems. Previously listed in Annex III with restricted concentrations, TPO now moves to Annex II as a fully prohibited substance.

What the Ban Covers

Under the updated regulation, cosmetic products containing TPO or other newly listed CMR substances cannot be placed on the EU market after September 1, 2025. This includes:

• UV gel nail polishes using TPO as a curing agent
• Hybrid nail systems with photoinitiator blends containing TPO
• Products formulated before the ban but not yet sold

The regulation does not provide a grace period for existing inventory. Products on shelves after the effective date must be removed.

Kolortek Effect Pigments Remain Compliant

Kolortek's cosmetic-grade effect pigments do not contain TPO or other photoinitiators. Kolortek nail pigment portfolio—including pearlescent, metallic, chameleon, holographic, and chromatic shift effects—consists of inorganic substrates coated with titanium dioxide, iron oxides, tin oxide, and other colorants approved under EU regulations.

Our effect pigments are manufactured to meet REACH registration requirements and undergo regular third-party testing for heavy metals and restricted substances. Customers reformulating nail products in response to the TPO ban can continue using our pigment ranges without regulatory concern.

Kolortek maintains documentation including REACH certificates, SGS test reports, and CMR substance declarations for its cosmetic product lines. The company's pearl pigments use mica or synthetic fluorphlogopite substrates with metal oxide coatings. None of the coating processes involve photoinitiators or other UV-curing agents.

Affected Product Categories and Reformulation Considerations

The TPO ban primarily affects UV-cured gel nail systems. Conventional nail lacquers and dipping powder systems do not typically use photoinitiators and are not directly impacted by this change.

Manufacturers reformulating gel systems will need to identify alternative photoinitiators from the Annex III permitted list or redesign products using different curing mechanisms. Effect pigments can transfer directly to reformulated systems, as their compatibility depends on the base resin and dispersion method rather than the curing chemistry.

Kolortek provides technical support for pigment dispersion in various nail gel formulations, including solvent-free UV systems, hybrid formulas, and aqueous-based products.

Heavy Metal Compliance Documentation

Beyond the TPO restriction, EU cosmetics regulations maintain strict limits on heavy metals including lead, arsenic, cadmium, mercury, antimony, and nickel. Kolortek's cosmetic-grade pigments undergo batch testing to verify compliance with these limits.

The company provides:

• Certificate of Analysis (CoA) with heavy metal test results per batch
• REACH registration numbers for applicable substances
• Safety Data Sheets (SDS) conforming to EU CLP requirements
• Third-party verification from SGS, TÜV SÜD, and other accredited laboratories

Technical specifications and compliance documentation for Kolortek's nail pigment range are available through the company's sales team. Sample kits can be requested for formulation testing in reformulated gel systems or other nail product categories.

Contact: For compliance documentation, technical data sheets, or samples of EU-compliant effect pigments, contact Kolortek's export team contact@kolortek.com, or visit the company website.