Nail gel and acrylic: the rules that apply in Switzerland

A nail studio in Thun receives a delivery: gel in twelve colours, a primer, a top coat, plus liquid and powder for acrylic sets. The owner unpacks it and wonders what actually has to be printed on these little bottles. A client in Lugano asks her nail technician what is in the gel that is about to go under the UV lamp.

Both questions lead to the same rules. Switzerland has no separate law for nail products. Gel, acrylic and primer are cosmetic products, and the food law, which also governs cosmetics, applies to them. This article describes how these rules are built, what they set out specifically for gel and acrylic systems, and what cantonal laboratories have found in their inspections.

Nail products are cosmetic products

The Foodstuffs and Utility Articles Ordinance (LGV, from the German name) defines cosmetic products as substances or preparations that come into contact with parts of the body from the outside, for instance to change their appearance or to protect them. Nails are expressly named (Art. 53 LGV). Annex 1 of the FDHA Ordinance on Cosmetic Products (VKos) contains an illustrative list in which “nail care products and cosmetics” appear.

For a nail studio this means: whether it is UV gel, acrylic liquid and powder, primer, base and top coat or classic nail polish, all of them fall under the same set of rules. It mainly regulates two things: ingredients and labelling.

One provision of the VKos is particularly telling for studios: there, an end consumer is not only someone who uses a cosmetic product themselves but also someone who uses it professionally (Art. 2 para. 1 let. f VKos). The nail technician is therefore herself one of the people the label and the warnings are addressed to.

How Swiss law refers to the EU lists

Which substances are permitted, restricted or prohibited in cosmetics is not set out in Swiss lists of its own. Art. 54 LGV refers to the annexes of the EU Cosmetics Regulation (Regulation (EC) No 1223/2009), in the version that is binding in the EU at any given time. When the EU amends an annex, the amendment therefore applies in Switzerland too. Deviations are regulated by the FDHA in the VKos.

Annex of the EU regulation	Content	Basis in the LGV
Annex II	Prohibited substances	Art. 54 para. 1
Annex III	Substances with restrictions and warnings	Art. 54 para. 2
Annex IV	Permitted colourants	Art. 54 para. 3
Annex V	Permitted preservatives	Art. 54 para. 4
Annex VI	Permitted UV filters	Art. 54 para. 5

The Federal Food Safety and Veterinary Office (FSVO, BLV in German) publishes these annexes as regularly updated lists in German. It points out that they are aids and that only the legal bases are legally binding. According to the FSVO, substances that are not regulated in any annex may be used if their safety is documented in the product’s safety report.

What applies to gel and acrylic systems specifically

Annex III contains several entries for nail products. The table below reproduces them according to the FSVO list, in simplified form:

Substance on the label	Product type and restriction	Required warnings
HEMA	Nail products, professional use only	“For professional use only”, “May cause an allergic reaction”
Di-HEMA Trimethylhexyl Dicarbamate	Nail products, professional use only	as for HEMA
Benzoyl Peroxide	artificial nail systems, at most 0.7 % after mixing, professional	“For professional use only”, “Avoid skin contact”, “Read the instructions for use carefully”
Hydroquinone, p-Hydroxyanisole	artificial nail systems, at most 0.02 % each after mixing, professional	as for Benzoyl Peroxide
Toluene	Nail products, at most 25 %	“Keep out of the reach of children”, “For use by adults only”

HEMA and Di-HEMA Trimethylhexyl Dicarbamate are monomers; according to the report of the Cantonal Laboratory of Basel-Stadt, HEMA is still the most commonly used monomer in UV gel nail polishes. Annex III expressly regulates Benzoyl Peroxide, Hydroquinone and p-Hydroxyanisole for “products for artificial nail systems”. According to the same report, p-Hydroxyanisole serves as a stabiliser that prevents premature curing in the bottle; the laboratory found Benzoyl Peroxide in a powder for the dip method. The limits in each case refer to the mixture as it is used.

For primer, Annex III has no product type of its own. What applies to it is what applies to all cosmetics: what counts are the substances it contains and the warnings prescribed for those substances.

TPO: prohibited since 1 September 2025

The most important change of recent years concerns a photoinitiator, that is, a substance that triggers curing under the lamp. Trimethylbenzoyl Diphenylphosphine Oxide, TPO for short, was added by Regulation (EU) 2025/877 to Annex II, the list of prohibited substances. According to the FSVO, the reason is its classification as a substance toxic to reproduction, category 1B.

In a letter to interested parties on 18 July 2025, the FSVO set out what this means for Switzerland:

• Through Art. 54 LGV, the ban also applies in Switzerland, since 1 September 2025.
• According to this account, using a product containing TPO in a studio or salon falls under the ban, expressly including nail studios.
• The ban does not provide for a period to sell off existing stock. Products bought before 1 September 2025 may not be used since then either.

In this letter the FSVO recommends that all professional users check the composition of their products. The exact name helps here: in the test report of the Cantonal Laboratory of Basel-Stadt, a similar-sounding photoinitiator, Ethyl Trimethylbenzoyl Phenylphosphinate, appears as a substance of its own, for which the laboratory objected to missing declarations, but not to its use.

What the label must show

The VKos regulates labelling in two articles. Art. 8 concerns the list of ingredients, Art. 9 the other particulars. In summary:

Particular	What the VKos requires
List of ingredients	under the heading “Ingredients”, in descending order of weight; ingredients below 1 % at the end in any order
Names	according to the EU glossary of common ingredient names (Implementing Decision (EU) 2022/677), otherwise a recognised nomenclature
Colourants	with CI number; for colour palettes with “may contain” or “+/–”
Function	where it is not clear from the presentation
Name and address	of the manufacturer, importer, distributor or responsible person
Shelf life	date of minimum durability; for a shelf life of more than 30 months, instead the period after opening, with the symbol from Annex 3 VKos
Batch	batch number or a mark for identification
Warnings	the warnings under Annex III and, where applicable, special precautions for professional use, clearly set apart from the other labelling

If there is no room on a small bottle, ingredients and warnings may appear on an enclosed or attached leaflet, with a note or symbol on the container. The particulars must also be clearly visible, easily legible and given in at least one official language (Art. 47 para. 2 LGV).

What cantonal laboratories find in inspections

Enforcement of food law lies with the cantons; they also inspect utility articles and operate laboratories for that purpose (Art. 47 and 48 LMG, the Food Act). How gel nail polishes perform in practice was described by the Cantonal Laboratory of Basel-Stadt in a report of 31 March 2026, for a joint campaign with the canton of Aargau. It examined 28 products from 18 brands from 14 Swiss online shops, all based on acrylate or methacrylate and intended for professional use.

According to the report, 27 of the 28 products were objected to, and for 22 the laboratory imposed a sales ban. The most frequent reasons were colourants that are not permitted, prohibited monomers and photoinitiators, exceeded limits for stabilisers, and ingredients that were missing from the label or did not match the product. The laboratory found HEMA in 28 samples; in nine, the prescribed warnings were missing. According to the report, a product labelled “HEMA-free” contained 0.9 % HEMA.

In an earlier campaign in 2024, the laboratory had examined products in nail studios and in retail. By its own account it objected to 50 of 54 samples; for 31, a sales ban or, in studios, a ban on use was imposed.

On allergies, the report says: the majority of these polishes are intended for professional use only because of the sensitising substances they contain. When they are used privately, lack of knowledge and poor ventilation increase the risk of allergic reactions, in the laboratory’s view. The laboratory also points to a gap it sees in the law: some substances are only permitted in products for professional use, but sale to private individuals is not restricted.

What you can read off when unpacking

The ordinances and the report show which particulars must be found on a nail product. Much of it can be checked without a laboratory, with the bottle in hand:

1. Is there a list of ingredients under “Ingredients”?
2. Are colourants with a CI number given for coloured products?
3. Does Trimethylbenzoyl Diphenylphosphine Oxide appear in the list?
4. Do products with HEMA or Di-HEMA Trimethylhexyl Dicarbamate carry the warnings “For professional use only” and “May cause an allergic reaction”?
5. Are the batch, shelf life, and the name and address of the responsible body given?
6. Are the particulars legible in an official language?

The Basel laboratory notes that some deviations would have been recognisable to those responsible even without analysis, for example a missing list of ingredients. What checking the label cannot do is prove that a product contains what it claims. That is the responsibility of the manufacturer, importer and distributor (Art. 3 VKos), and the cantonal laboratories check it. The contact point for a studio’s questions is the food inspectorate of its own canton.

The idea for nail studios that we are working on concerns the administration around the treatment: appointments, client file and nail cards. Checking the products remains a matter for the studios, their suppliers and the authorities.