DARK gel base coat formula updates & TPO ban compliance in 2025

Why We Openly Discuss Formula Changes

In today’s nail care industry, brand responsibility goes far beyond attractive packaging or trendy textures. At DARK, we believe in transparent communication at every stage of product evolution, especially when it concerns safety and quality.

In 2024, new regulations came into effect across the European Union. According to Regulation (EU) 2024/197, the photoinitiator TPO (Trimethylbenzoyl diphenylphosphine oxide), previously used in some gel base coats for nails and gel-based nail polishes, has been classified as a CMR Category 1 substance (carcinogenic, mutagenic, or toxic to reproduction). This means that from September 1, 2025, the use of TPO in cosmetic products will be prohibited.

This applies not only to DARK but to all professional nail product manufacturers within the EU. We are not waiting for the deadline — we are already acting.

You can read the official Regulation (EU) 2024/197 text on EUR-Lex.

We are revealing this process publicly for the first time because trust from nail technicians is built on transparency, not marketing campaigns.

Therefore, in upcoming posts, we will walk you through the formula updates, the rigorous product testing, why some products never made it to market, and what exciting launches are coming soon.

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What Exactly We Updated — and Why It Matters

We didn’t wait for the deadline — all formulas containing the photoinitiator TPO have already been reformulated without compromising the quality DARK is known for.

During the update, we retained all the critical properties essential for daily professional use, including:

• Consistent durability across varied wear conditions;

• A flexible, predictable consistency that’s easy to work with for both beginners and seasoned technicians;

• Reliable and clear curing under various UV and LED lamps;

• Versatility for different techniques such as smoothing, thin layering, and architectural reinforcement.

These attributes are not compromises — they are the foundation of our products. DARK was founded by Zhanna, a top nail technician with over 15 years of hands-on salon experience.

Our brand wasn’t created in a design studio; it was born from real salon practice where every rubber base gel nail polish and gel base coat is tested in the dynamic pace of an actual working day.

That’s why DARK never prioritises trends over comfort and consistently advocates for formulas that technicians can trust and comfortably work with daily — not just for photo shoots or exhibitions.

All updated products have been available since May 1, 2025. They are easily identifiable by the “TPO-free” mark in their ingredient descriptions.

We have also updated the certification of each reformulated product to comply with the new regulations.

How We Truly Test Our Products

From the outside, “updating a formula” might seem like a simple swap of one ingredient. But for us at DARK, it’s a months-long process of testing, comparing, rejecting, and gathering feedback from professional nail technicians.

No product, whether a gel base coat for nails or a rubber base gel nail polish, is released without undergoing rigorous real-world salon testing.

 Each formula goes through:

• Testing by at least five technicians of varying skill levels;

• Application trials across multiple techniques including smoothing, strengthening, and thin layering;

• Curing tests under UV, LED, and hybrid lamps of various power outputs;

• Trials on diverse nail types — thin, strong, and moist;

• Assessment of drying time, texture, ease of use, and durability.

This data doesn’t just go into spreadsheets — it drives our decision to launch or reject a product.

For example, in our latest round of tests:

• Out of five transparent base gel nail polish formulas, only one made it to production;

• Four gel medium formulas were tested, with just one progressing;

• Three top gel top coat formulas were evaluated, and only one was released.

We don’t mass order blindly — we start with samples, test extensively, discard, optimise, and only then launch.

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The Unseen Losses No One Talks About

Behind every beautiful product that reaches your hands lies a story of uncompromising pursuit of perfection. What you don’t see on the label are the countless times we said “no” when it would have been easier to say “just go with it.”

 “Do you know how many products never saw the light of day simply because they were ‘almost good enough’? ” — Zhanna, DARK founder

These formulas weren’t harmful — they just didn’t meet our internal standards:

• Uncomfortable consistency;

• Excessively long drying times;

• Unstable behaviour across different techniques;

• Or simply unable to match the quality of our existing gel base coat for nails and gel-based nail polish.

We don’t usually publicise these stories because not everyone can accept that a company might willingly forgo profit for the sake of principle. But we can — because DARK is more than a brand. We are a team of technicians, formulators, and a founder who has held the brush every single day for 15 years.

No compromises. Even when it’s costly. Even if it means halting a launch a day before release.

Because for us, this isn’t just about products. It’s a responsibility — to you, our technicians, and to the clients who trust your craft.

What’s Next?

At DARK, we’re not merely adapting to new regulations — we’re rethinking our entire approach to formula development.

Right now, our team is hard at work creating a new line of products free from TPO. But it’s important to understand: our goal isn’t just to remove one ingredient and quickly restock shelves.

We deliberately reject the mentality of “no TPO — so it’s good to sell.”

For us, a new formula means a complete redesign from the ground up, ensuring:

• A well-tested, ideal consistency;

• Reliable curing performance under all types of UV and LED lamps;

• Proven long-lasting wear;

• Ease of application in real salon environments.

Many TPO-free products we tested failed to meet our standards. Their performance simply didn’t align with the high level of quality we demand — even if they were technically “safe.”

That means the upcoming releases won’t be just another “TPO-free” option, but products that professionals have truly been waiting for: convenient, expert-grade, and thoroughly tested.

And, as always, aligned with our philosophy: no product hits the shelves unless we are 200% confident in it.

TPO in cosmetic products in Ukraine

Although the use of TPO in cosmetic products is not currently prohibited in Ukraine, the DARK team has made a decisive commitment to fully transition to TPO-free formulas, aligning with the European Regulation (EU) 2024/197.
This decision reflects not only our dedication to safety but also the fact that a significant portion of DARK’s orders come from international markets, making compliance with European legislation strategically essential for us.

We are currently in a transitional phase, and some remaining stock with the previous formula—legally sold in Ukraine—is still available on the market. Due to the brand’s high demand, these items are rapidly depleting, and a complete switch to the updated formulations is expected within the next month.

All orders destined for international delivery are fulfilled exclusively with the updated TPO-free products.
For customers ordering within Ukraine but shipping abroad, we recommend informing them in advance about the transition phase to prevent any misunderstandings.

This reflects our responsible stance as a brand built on trust with clients worldwide.