The number on the front of a polish bottle looks like a grade. It is a list. Each brand decides which substances it leaves out, counts them, and prints the total. Two 10-free polishes from two brands can exclude different things, and a 5-free polish can be formulated more carefully than a 15-free one.
The counts do describe real chemistry. The first three substances were once standard in polish and were removed for good reasons. The numbers above seven mostly describe substances that were never common in polish. Reading the list behind the number, and knowing what European law already requires, turns the claim into information.
What does 10-free nail polish mean?
10-free nail polish is polish formulated without ten named substances that the brand has chosen to exclude. The number counts the brand's own list, so the exact ten vary. Mooncat's 10-free list, for example, is dibutyl phthalate, toluene, formaldehyde, tosylamide/formaldehyde resin, camphor, ethyl tosylamide, xylene, parabens, triphenyl phosphate and TBHP (Mooncat). Another brand may swap one of those for fragrance, gluten or animal-derived ingredients.
There is no regulatory body that defines what 5-free or 10-free means, so the count is a marketing convention, not a standard (Label Lookout). The number tells a reader that the brand has thought about its plasticiser and solvent choices. It does not tell a reader which choices, or whether the substitutes are any better. The ingredient list on the back does that.
What does each number exclude?
The ladder most brands follow is compiled from Label Lookout, Mooncat and Manucurist (Label Lookout; Mooncat; Manucurist). Each step adds to the one before.
| Count | Substances added at this step | Job in polish | EU status |
|---|---|---|---|
| 3-free | Formaldehyde | Nail hardener | Prohibited, Annex II entry 1577 (Regulation (EU) 2019/831) |
| 3-free | Toluene | Solvent | Restricted to 25% in nail products with warnings, Annex III entry 185 |
| 3-free | Dibutyl phthalate (DBP) | Plasticiser | Prohibited, Annex II entry 675 |
| 5-free | Tosylamide/formaldehyde resin | Adhesion resin | Permitted; a known contact allergen |
| 5-free | Camphor | Plasticiser | Permitted |
| 7-free | Ethyl tosylamide | Film former and plasticiser | Listed by CosIng under Annex II entry 307 (sulphonamides), so not used in EU polish |
| 7-free | Xylene | Solvent | Permitted, rarely used |
| 9 or 10-free | Parabens | Preservative | Several permitted with limits; rarely needed in a water-free polish |
| 9 or 10-free | Triphenyl phosphate (TPHP) | Plasticiser | Permitted; endocrine concern under study |
| 10-free and above | TBHP, fragrance, gluten, lead, acetone, animal derivatives, benzophenone-1, styrene, bisphenol A | Varies; most were never common in polish | Varies; lead is prohibited in any case |
The regulatory entries come from the consolidated annexes of Regulation (EC) No 1223/2009 and its amendments (EUR-Lex; EUR-Lex, Regulation (EU) 2019/831). Ethyl tosylamide's status rests on the Commission's ingredient database, CosIng, which files it under the prohibited sulphonamide entry (CosIng).
Why is there no legal definition of 5-free or 10-free?
Cosmetics law in the EU and the US regulates substances, not marketing counts. Regulation (EC) No 1223/2009 lists what is prohibited (Annex II), what is restricted (Annex III) and which colourants are allowed (Annex IV), and requires a safety assessment on every finished product (EUR-Lex). A polish is either compliant or it is not. The law has no category for a polish that excludes five permitted substances instead of three.
The counts began in the United States, where 3-free appeared in the mid-2000s after brands removed the three substances that were then under the most public pressure. Each later step was a brand adding to its own list, and higher numbers often add ingredients that were never commonly used in nail polish in the first place (Label Lookout). The number grew because it could.
What is the EU baseline?
In the EU the three substances behind 3-free are already handled by law. Dibutyl phthalate has been prohibited in cosmetics since 2004 and is Annex II entry 675. Formaldehyde was moved to Annex II, entry 1577, by Commission Regulation (EU) 2019/831 of 22 May 2019, which ended its use in nail hardeners even though the scientific committee had found about 2.2% free formaldehyde in hardeners to be safe, because alternatives existed (EUR-Lex). Toluene is restricted under Annex III entry 185 to nail products at a maximum of 25%, with the warnings Keep out of reach of children and To be used by adults only (EUR-Lex).
A polish sold legally in the EU is therefore at least 2-free by law and, in practice, 3-free, because almost every European brand has replaced toluene with butyl and ethyl acetate. A 3-free claim on a European shelf describes the legal minimum. The steps that describe an active choice by the brand begin at 5-free, with the adhesion resin and camphor.
Which exclusions matter and which are padding?
Three exclusions change the chemistry of a polish. Leaving out tosylamide/formaldehyde resin removes a known contact allergen from the adhesion system, at some cost to wear. Leaving out camphor removes an old plasticiser with a strong smell and a history of irritation. Leaving out triphenyl phosphate (TPHP) removes the plasticiser that most free-from lists miss; Label Lookout calls it a suspected endocrine disruptor and notes that many 10-free polishes still contain it (Label Lookout). A brand that excludes TPHP has usually moved to citrate or diisobutyrate plasticisers.
Several exclusions are padding. Parabens are preservatives for water-containing products, and a solvent polish contains no water for microbes to grow in. Gluten is a protein that has no role in a lacquer. Lead is prohibited in cosmetics in any case. Acetone is a remover solvent, not a polish ingredient. A count that includes these is counting absences that cost the brand nothing.
What each of the substantive substances did in polish, why it drew attention and how to spot it on a label is covered in the companion guide to toluene, formaldehyde, DBP, camphor and TPHP.
Can brands print free-from claims in the EU?
Yes, within limits. Article 20 of Regulation (EC) No 1223/2009 says claims must not imply characteristics a product does not have, and Regulation (EU) No 655/2013 sets six common criteria for every cosmetic claim: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making (EUR-Lex). A free-from claim that is true and verifiable passes the first three. The last three are where free-from counts get into difficulty.
The Commission's Technical Document on cosmetic claims, agreed on 3 July 2017 and applied from 1 July 2019, added an annex on free-from claims. Its position is that a claim should not suggest a product is safer because it leaves out a permitted ingredient, and that free-from claims for substances the law already prohibits are not acceptable, since they imply a legal product could contain them (CTPA). On that reading, formaldehyde-free and DBP-free are claims a European brand should not make, while TPHP-free or camphor-free can be made if they are true and not presented as a safety advantage.
The UK trade association's advice is to talk about the ingredients a product uses, not the ones it leaves out (CTPA). India Anaïs follows that approach: the ingredient list is published in full, and the lacquers are described by what they contain.
How to read a free-from claim on a bottle
You will need: the bottle or its product page, the full ingredient list, and about two minutes.
- Find the brand's own list of exclusions. A number without a list is a claim without content; most brands publish the list on a FAQ page.
- Cross the three EU-regulated substances off. Formaldehyde, DBP and toluene are prohibited or restricted by law, so they add nothing to the claim on a European shelf.
- Check the plasticiser on the INCI list. Triphenyl phosphate means TPHP is present, whatever the count says. Acetyl tributyl citrate, trimethyl pentanyl diisobutyrate or sucrose acetate isobutyrate mean the brand has replaced it.
- Check the resin. Tosylamide/formaldehyde resin is the allergen 5-free removes; tosylamide/epoxy resin or a polyester copolymer is the usual replacement.
- Ignore exclusions that cost the brand nothing, such as gluten, lead or acetone, when comparing two polishes.
- Weigh the rest against wear. A polish with fewer resins and older plasticisers replaced may chip a little sooner; whether that trade is worth it is a personal choice, not a safety verdict.
- A free-from number counts the brand's own list of exclusions; no regulator defines 5-free or 10-free.
- 3-free covers formaldehyde, toluene and DBP, which EU law already prohibits or restricts, so it is the legal baseline in Europe.
- The exclusions that change the chemistry are formaldehyde resin, camphor and TPHP; gluten, lead and acetone are padding.
- TPHP is the plasticiser most 10-free lists miss; look for triphenyl phosphate on the INCI list.
- EU claims rules discourage free-from claims for prohibited substances and any suggestion that a permitted ingredient is unsafe.
Questions people ask
Is 10-free nail polish safer than 3-free?
Not by definition. The counts are set by each brand, and the extra exclusions above 7-free are mostly substances that were never common in polish. A 5-free polish that has replaced TPHP can be a more considered formula than a 15-free one that still contains it. Read the ingredient list.
What does 3-free mean in nail polish?
Formulated without formaldehyde, toluene and dibutyl phthalate, the three substances that came under pressure in the mid-2000s. In the EU, formaldehyde and DBP are prohibited and toluene is restricted to 25% with warnings, so 3-free describes the legal minimum on a European shelf.
What does 5-free add to 3-free?
Tosylamide/formaldehyde resin, an adhesion resin that is a known contact allergen, and camphor, an old plasticiser with a strong smell. Both are permitted in the EU, so leaving them out is an active choice by the brand.
Is TPHP in 10-free nail polish?
Sometimes. TPHP, triphenyl phosphate, is a plasticiser that many free-from lists miss, and some 10-free polishes still contain it. Check the ingredient list for triphenyl phosphate; if a citrate or diisobutyrate plasticiser appears instead, TPHP has been replaced.
Are free-from claims allowed in Europe?
Yes, if they are true, verifiable and not presented as a safety advantage. The Commission's Technical Document on claims, applied from 1 July 2019, advises against free-from claims for substances that are prohibited anyway and against claims that imply a permitted ingredient is unsafe.
Does 12-free or 15-free mean anything more?
It means the brand's list is longer. Manucurist, Kure Bazaar and Nailberry use 12-free; Olive and June uses 15-free. The additions at that level, such as styrene, bisphenol A or animal derivatives, are rarely found in polish, so the practical difference from a good 7-free formula is small.
- Label Lookout, what 10-free nail polish means
- Mooncat FAQ, 10-free ingredient list
- Manucurist, Green Flash collection (12-free)
- EUR-Lex, Regulation (EC) No 1223/2009 on cosmetic products
- EUR-Lex, Commission Regulation (EU) 2019/831 (formaldehyde prohibited)
- EUR-Lex, Regulation (EU) No 655/2013 on common criteria for cosmetic claims
- CTPA, cosmetic claims: focus on free-from claims
- European Commission, CosIng ingredient database