How to solve the TPO stock problem: advice for brands & distributors
By Guest Writer | 24 September 2026 | Feature
By Lee Bryan, CEO & founder, Arcus Compliance – a compliance consultancy and software company.
From 15 August 2026, TPO-containing products can no longer be placed on the GB market. That is the manufacturer and importer line. It bites the moment a product is first supplied into Great Britain.
From 14 February 2027, those products can no longer be made available. That is the distributor and retailer line – the last day TPO stock can lawfully be sold on to a salon or a nail professional. The tech who already bought it can keep working through what is in their kit.
I keep meeting brands who believe February is their manufacturing deadline. It is not. February is a clearance window for stock lawfully placed on the GB market before August, not a second run of production.
That has teeth in very ordinary situations; a white label run ordered in the spring and landing in September – a distributor buying TPO stock from an overseas supplier and never asking when it entered the GB market. Neither is protected by February, because neither was lawfully placed on the market to begin with.
The stock nobody wants to count
So count it. Not the number in your system. The number on the pallets, including whatever sits at your 3PL, in a rep’s boot, and on the marketplace listing you forgot about. Then date it. For every line, show when it was placed on the GB market. That evidence is the only thing separating stock you can sell through from stock you will destroy, and if you cannot prove it, work on the basis that you cannot sell it.
Then be honest about the run-down. Your customers know the ingredient is going and they will buy accordingly, so discount early rather than late. A margin you chose beats a write-off you did not. And do not plan on exporting the problem. The EU prohibition took effect on 1 September 2025 and Northern Ireland has been under it since.
One more, and it is the one that causes arguments: decide now, in writing, who carries the cost of unsold stock and who pays for disposal. That conversation is far cheaper now, than in March.
Reformulation is not an INCI swap
Plenty of brands told their customers they had reformulated months ago. Some had changed the ingredient list and very little else. Take TPO out and you change the product. The curing profile shifts, as does adhesion and flexibility. Stability and shelf life have to be re-established rather than assumed.
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That is before the paperwork. The safety assessment has to be revisited, the Cosmetic Product Safety Report and Product Information File updated, the notification resubmitted, artwork and batch coding redone. Every lab and safety assessor serving this market is working the same queue at the same time, so a decision taken in October does not land in November.
Then remember: your users were trained on the old cure times. If the new formulation behaves differently under the lamp and nobody tells them, your reformulation comes back to you as a service complaint with your name on it.
You are not being inspected. You are being scanned.
The picture most brands carry of enforcement is somebody walking through the door. Not any more. A banned ingredient printed on your own label is the easiest thing in the world to find. Listings get scanned across marketplaces and ingredient declarations cross-referenced against prohibited substances in seconds. TPO on your label after February is a flag you printed yourself.
Your retailers know it, which is why they are not waiting for a government deadline. They are already asking suppliers to confirm compliance, and they will delist a line long before an enforcement body makes contact. Losing a listing is faster, quieter and usually more expensive than a fine.
TPO was never really the story
TPO was one of 16 CMR substances restricted by the same instrument. Enzacamene went with it. The labelling threshold for formaldehyde releasing preservatives dropped to 0.001% in July. A lot of brands scrambled over one ingredient and never checked whether the rest of that list touched their range.
An ingredient is approved right up until it is reclassified. That is not the system failing, that is the system working. The businesses that will handle the next one calmly are building the habit now. A live register of every substance across the range, a quarterly look at the chemicals pipeline, and a named person whose actual job is to notice early enough to make a commercial decision instead of an emergency one.
February 2027 resets the shelf
Here is the part the panic hides: a ban clears the shelf for everybody at the same time. The brands that reformulated properly, cleared their old stock on their own terms and can evidence all of it do not just avoid the fall. They walk into the space the slower operators leave behind, and they get the buying conversation where the range is already TPO free and fully assessed while a competitor is still promising it.
February will arrive as quietly as August did. The deadline was never the threat. Being unready for it is. The brands that did the work will spend that week selling, and everyone else will spend it counting pallets.
