Nail products, UV gels and lamps

• Regulation (EC) No 1223/2009 — Cosmetics
• Regulation (EC) No 1272/2008 — CLP
• Directive 2014/35/EU for UV lamps
• Regulation (EU) 2023/988 — GPSR

Who has to appoint one

Manufacturers and sellers outside the Union placing nail products on the EU market. Gels and polishes are cosmetics with a responsible person, safety report and CPNP notification; the curing lamp is an electrical product with its own conformity route.

Thresholds and exemptions

None. Several acrylates used in gels have been restricted or banned for consumer use following sensitisation cases, and professional-only restrictions apply to some substances.

What must appear on the label

Full cosmetic labelling with the responsible person, INCI list, batch, durability and precautions, including sensitisation warnings. HEMA and di-HEMA TMHDI containing products carry a professional use restriction. Lamps carry CE marking and photobiological information.

Marketplace fields

Marketplaces have removed consumer nail gels containing restricted acrylates, and this was one of the most enforced cosmetic restrictions of recent years.

Documentation you must hold

Product Information File with the safety report signed by a qualified assessor, CPNP notification, formulation records evidencing the restricted substance concentrations, and for lamps the declaration of conformity and photobiological assessment.

Standards and testing

Stability, compatibility and preservative efficacy, analytical verification of restricted acrylates, and for lamps IEC 62471 photobiological testing given the UV emission.

Language requirements

Precautions and warnings in the language of each member state of sale.

When it applies

CPNP notification before the first sale.

How long records are kept

Ten years after the last batch.

What happens if you do not comply

Withdrawal and fines, with sensitisation cases attracting particular attention because the harm is permanent and widespread.

Who enforces it

Cosmetics competent authorities, market surveillance authorities and customs.

Where the boundary lies

Products containing HEMA above the permitted limits may only be supplied for professional use, and selling them to consumers online is the recurring infringement. The lamp and the gel are two different regulated products in one kit.

Questions we are asked

Can we sell HEMA gels to consumers?

Not where the substance is restricted to professional use. The restriction followed widespread allergic sensitisation from home use.

Does the UV lamp need its own documentation?

Yes, as an electrical product with photobiological assessment, separate from the cosmetic notification.