HEMA-Free and TPO-Free Gel in Canada: What the Rules Say and What the Labels Mean

By Edmond Lin, over 10 years in the nail industry, M1 Nail & Beauty Supply, Markham ON · Last updated: November 7, 2026

As of November 2026, neither HEMA nor TPO is prohibited or restricted in cosmetics in Canada. Neither is on Health Canada's Cosmetic Ingredient Hotlist, and neither is in Health Canada's latest notice of proposed changes to it. The European Union is stricter. It banned TPO in cosmetics from 1 September 2025, salon use included, and since 2021 it has limited nail products with HEMA to professional use, with an allergy warning on the label. "HEMA-free" and "TPO-free" are claims made by brands, not terms defined in Canadian rules, so the ingredient list is what tells you what is in the bottle.

How do Canada and the EU treat HEMA and TPO?

The table covers the three ingredients that HEMA-free and TPO-free labels refer to. The Canadian column is based on the Hotlist page dated 13 August 2025. We checked every source on 7 November 2026.

Ingredient What it does in gel Canada European Union
HEMA (2-Hydroxyethyl Methacrylate) A monomer that helps the gel bond to the nail Not on the Hotlist Nail products for professional use only since 2021, labelled "For professional use only" and "Can cause an allergic reaction"
Di-HEMA Trimethylhexyl Dicarbamate Another methacrylate used in nail products Not on the Hotlist Same rule as HEMA
TPO (Trimethylbenzoyl Diphenylphosphine Oxide) A photoinitiator: it reacts to UV or LED light to start the cure Not on the Hotlist Banned in cosmetics from 1 September 2025, including salon use of stock bought earlier

What is HEMA, and why do brands make HEMA-free gel?

HEMA is short for 2-Hydroxyethyl Methacrylate. The GelBottle describes it as an acrylic monomer, common in nail products, that helps create a strong bond between the nail and the gel.

It is also the methacrylate most often behind gel allergies. In a 2017 audit of 13 dermatology units in the UK and Ireland, reported by the British Association of Dermatologists, 1.5% of 4,931 patients tested positive to 2-HEMA, the most common (meth)acrylate to cause allergy, and 2.4% to at least one (meth)acrylate. In the Canadian Medical Association Journal, two Toronto doctors write that about 2.6% of patients with contact dermatitis react to HEMA on patch testing.

The allergy starts with skin contact. The British Association of Dermatologists says sensitisation can happen when uncured product touches any part of the skin. A reaction can mean loosening nails or a red, itchy rash, on the fingertips or anywhere the nails touch, including the eyelids, face and neck. The association also warns that the allergy can have lifelong consequences for dental treatment and surgery, where devices containing the same chemicals are common.

That is why HEMA-free lines exist. DND calls its HEMA-free and TPO-free gel "an additional formula option for those seeking products without HEMA and TPO", and The GelBottle says its HEMA-Free BIAB is made for clients with sensitivities to HEMA.

What is TPO, and why did the EU ban it?

TPO is short for Trimethylbenzoyl Diphenylphosphine Oxide. The GelBottle describes it as a photoinitiator, the ingredient in some gels that reacts to UV or LED light to cure the product, and notes that not every gel contains it.

In 2024 the EU classified TPO as toxic for reproduction, category 1B. Regulation (EU) 2025/877 then moved it to the list of substances banned in cosmetics, from 1 September 2025, saying that in light of that classification it "should no longer be allowed in cosmetic products." Until then it had been allowed in professional artificial nail systems at up to 5%.

The European Commission's questions and answers on the ban make three points for salons. A nail technician cannot use a TPO product on clients from 1 September 2025, even if it was bought earlier. There is no sell-through or use-up period. And the 2015 scientific opinion that found TPO safe in certain professional nail gels at up to 5% predates the new classification.

Is TPO or HEMA banned in Canada?

No. Health Canada uses the Cosmetic Ingredient Hotlist to tell manufacturers which ingredients may be prohibited or restricted in cosmetics. The current list, dated 13 August 2025, does not include HEMA, Di-HEMA Trimethylhexyl Dicarbamate or TPO. Health Canada's latest notice of proposed updates, dated 14 May 2025, names other ingredients, such as Basic Violet 4, Basic Blue 7 and PHMB, and neither HEMA nor TPO is among them.

Not being on the list does not make an ingredient approved. Health Canada says it "can take actions at any time" whether or not a substance is on the Hotlist, and that the sale of a cosmetic "should stop as soon as industry knows the cosmetic may cause injury." Many brands sold in Canada already make HEMA-free and TPO-free versions, so salons do not have to wait for a rule to switch.

Canada does restrict other nail ingredients. These Hotlist entries apply to nail products:

Ingredient Hotlist status What the Hotlist says
Methyl methacrylate (MMA) monomer Prohibited Not allowed in cosmetics
Ethyl methacrylate (EMA) Restricted Label must say "Avoid skin contact."
Benzoyl peroxide Restricted Only in nail products for professional use, up to 10%, labelled "For professional use only", "Avoid skin contact" and "Read directions carefully before using"
Formaldehyde in nail hardeners Restricted Up to 5%, sold with nail shields and directions, with a warning that it can cause skin sensitivity

Does HEMA-free gel mean you will not react?

No. HEMA-free gel leaves out the most common trigger, but gel is still made from other (meth)acrylates, and some people react to those too. In the British audit, the next most common was 2-hydroxypropyl methacrylate, at 1%. The Toronto doctors add that once a methacrylate allergy is found, patients must avoid all methacrylates, because of "substantial cross-reactivity" between them.

The claim itself also varies. The GelBottle's help centre says a "HEMA-free" system "means that the product does not contain 2-Hydroxyethyl Methacrylate or has reduced the concentration of this ingredient." Canada has no definition, so read the ingredient list rather than relying on the word.

If you or a client get a rash, swelling or loosening nails after gel, stop using the products and see a doctor. An allergy to nail products is confirmed by patch testing, and the CMAJ article asks doctors to refer people who use or work with nail products for testing when the rash is on the fingertips or around the nails.

How can you tell if a gel contains HEMA or TPO?

Read the ingredient list. Health Canada requires cosmetic labels to list ingredients by their INCI names, the international names used on cosmetic labels. Look for these:

  • HEMA, also written as 2-Hydroxyethyl Methacrylate
  • Di-HEMA Trimethylhexyl Dicarbamate
  • Trimethylbenzoyl Diphenylphosphine Oxide, which is TPO

HEMA-free and TPO-free are separate claims, so check for each one. Some products carry both. Others, such as Aprés Extend Gel Sensitive and The GelBottle's HEMA-Free gel polish, say only HEMA-free, so do not assume they are TPO-free as well.

Check every layer, not just the colour. Base coat, colour, top coat and tip adhesive all sit on the nail, so a HEMA-free colour over a regular base still puts HEMA on the nail. For a client with a confirmed HEMA allergy, The GelBottle says you must use a full HEMA-free system.

What should salons in Canada do about HEMA and TPO?

  1. Keep uncured gel off the skin. This is how the allergy starts, for clients and for technicians.
  2. Cure every layer fully. Use the lamp the brand recommends and follow its cure times. The British Association of Dermatologists warns that the wrong lamp can leave gel under-cured, which means "an increased chance of allergy."
  3. Protect your own hands. The association recommends nitrile gloves, changed every 30 minutes and taken off with a no-touch technique, because (meth)acrylates pass through many glove types. The CMAJ authors also suggest double gloving. Our glove guide compares the options.
  4. Keep a full HEMA-free set. Stock a HEMA-free base, colour and top coat together for clients who ask for one.
  5. Stop if a client reacts. End the service and suggest they ask their doctor about patch testing.

Which HEMA-free and TPO-free products does M1 carry?

Everything labelled HEMA-free, or HEMA and TPO-free, is in our HEMA-free collection. The table gives examples by type, with what each label says.

Type Label says At M1
Gel colour HEMA and TPO-free DND HEMA & TPO Free Duo 001–099, 101–199 and 201–290; Aprés Gel Couleur (HEMA & TPO Free) and the Prismatic Collection; Notpolish SOLO Gel
Gel colour HEMA-free The GelBottle HEMA-Free gel polish, such as Couture and Royal Navy
Base coat HEMA and TPO-free ONME Bolding Gel Base Coat 15 ml and 16 oz; Aprés Base Gelcoat X 30 ml
Top coat HEMA and TPO-free ONME Diamond Top Coat and Chrome Top Coat; Aprés Non Wipe Top Gelcoat, Top Gelcoat X and Builder Top Gelcoat
Builder gel HEMA and TPO-free, or HEMA-free The GelBottle BIAB TPO & HEMA-Free and Hard BIAB, both TPO and HEMA-free; Notpolish Hard Builder Gel, HEMA-free
Tip adhesive HEMA and TPO-free, or HEMA-free ONME Non-Wipe Tips Adhesive and Soft Gel Tip Adhesive, both HEMA and TPO-free; Aprés Extend Gel Sensitive, HEMA-free

The GelBottle's HEMA-Free BIAB has no built-in base, so it goes over a base coat, and The GelBottle names Bond Base and Glow Top as part of its HEMA-free system. For how the BIAB formulas differ, see our BIAB formulas guide.

Frequently asked questions

Is TPO banned in Canada?

No. As of November 2026, TPO is not on Health Canada's Cosmetic Ingredient Hotlist and is not in Health Canada's latest notice of proposed changes. The EU has banned it in cosmetics, salon use included, since 1 September 2025.

Is HEMA banned in Canada?

No. HEMA is not on the Hotlist either. In the EU, nail products with HEMA have been limited to professional use since 2021 and must be labelled "Can cause an allergic reaction."

Why did the EU ban TPO?

The EU classified TPO as toxic for reproduction, category 1B, in 2024. Regulation (EU) 2025/877 then banned it in cosmetics from 1 September 2025. Before that it was allowed in professional nail systems at up to 5%.

Can salons in Canada still use TPO gel they already have?

Canadian rules do not prohibit it. In the EU, salons had to stop using TPO products on clients on 1 September 2025, even stock bought earlier. Health Canada says it can act on any cosmetic at any time, and TPO-free versions are easy to find, so the choice is the salon's.

Is HEMA-free gel safe for someone allergic to gel?

Not necessarily. It removes HEMA, the most common trigger, but other (meth)acrylates can still cause a reaction, and doctors advise people with a methacrylate allergy to avoid all methacrylates. Anyone who has reacted should see a doctor before having gel again.

Can I use HEMA-free colour over a regular base coat?

You can, but the service is no longer HEMA-free, because the base still puts HEMA on the nail. For a client avoiding HEMA, use a HEMA-free base, colour and top coat.

Is DND gel polish HEMA-free?

Only the DND HEMA & TPO Free line is labelled HEMA-free and TPO-free. Regular DND, DC and DIVA gel polish is not labelled HEMA-free, and DND does not post ingredient lists for it online, so it cannot be treated as HEMA-free. For a full HEMA-free service, use the HEMA & TPO Free line with a HEMA-free base and top coat, such as DND's HEMA & TPO-Free Base Gel #100 and Top Gel #200 or the ones in the table above.

Which builder gels are HEMA-free?

At M1, The GelBottle BIAB TPO & HEMA-Free and Hard BIAB are labelled HEMA-free and TPO-free, and Notpolish Hard Builder Gel is labelled HEMA-free. The GelBottle's Original BIAB contains HEMA, so check the name on the bottle. HEMA-Free BIAB has no built-in base, so put it over a HEMA-free base such as The GelBottle Bond Base.

How do I know if a gel has HEMA in it?

Check the ingredient list on the bottle or box. Canadian cosmetic labels list ingredients by INCI name. Look for HEMA and Di-HEMA Trimethylhexyl Dicarbamate, and for TPO, look for Trimethylbenzoyl Diphenylphosphine Oxide.

Is MMA banned in Canada?

Yes. Methyl methacrylate (MMA) monomer is on the prohibited list of Health Canada's Cosmetic Ingredient Hotlist. Ethyl methacrylate (EMA) is restricted: its label must say "Avoid skin contact."

Shop HEMA-free and TPO-free gel colour, base, top coat and tip adhesive at M1, in our Markham store or online.

Shop HEMA-free gel

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