Nail Care

Nail care spans polishes, gel and acrylic systems, hardeners and removers, and most of its regulatory weight is concentrated in a handful of reactive chemicals: the methacrylates that build and cure the artificial nail, the photoinitiators that set it, and a group of legacy solvents and plasticisers.

Methacrylates and HEMA

Gel and acrylic systems work by curing methacrylate monomers, and the sensitisation risk they carry is the defining issue of the category. HEMA (2-hydroxyethyl methacrylate) and Di-HEMA Trimethylhexyl Dicarbamate are restricted to professional use only, with mandatory warnings that they are for professional use and can cause an allergic reaction, introduced by Commission Regulation (EU) 2020/1683. The risk arises when uncured or undercured product touches the skin around the nail, which is far more likely with poor application or an inadequate lamp. A methacrylate allergy, once established, is lifelong and can cross-react with dental and orthopaedic materials, which is why the controls are strict and why the product has to be assessed as it is actually used and cured.

The TPO prohibition

The photoinitiator TPO (trimethylbenzoyl diphenylphosphine oxide), used to cure gels quickly under UV and LED lamps, was classified as a CMR substance of category 1B, and that classification prohibits it in EU cosmetics from 1 September 2025, even at trace levels, under the rule that bans CMR substances unless a narrow derogation applies. Great Britain follows on its own timeline through SI 2026/23. The industry has moved to alternative photoinitiators such as TPO-L and BAPO, but any gel system still built on TPO has to be reformulated, and a product sold in both markets has to meet the earlier of the two deadlines for the market concerned.

The legacy solvents and plasticisers

The so-called toxic trio remains relevant. Toluene is restricted to a maximum of 25% in nail products with warnings, formaldehyde is permitted only as a nail hardener up to 5% with the prescribed cuticle-protection warning and is otherwise prohibited as a free ingredient, and dibutyl phthalate is a CMR substance prohibited in cosmetics. Removers are largely acetone or acetone-free solvents assessed for their own exposure.

Curing, exposure and the professional user

A nail product has to be assessed in both its uncured and cured states, and the UV or LED curing step is part of the use scenario. Because so many nail products are professional-use-only, the labelling, warnings and assumed level of training differ from a consumer product, and that distinction has to be correct on the pack and in the assessment.

How we help

We assess nail systems as they are mixed, applied and cured, get HEMA, Di-HEMA, toluene and formaldehyde to the right restricted status and labelling, confirm a formulation is free of TPO and other prohibited CMRs against both the EU and GB deadlines, and set the professional-use labelling correctly. Where a salon-only product is heading for consumer sale, we flag the reclassification before it ships.