California Adopts New TPhP Restrictions for Nail Products
California’s Department of Toxic Substances Control (DTSC) has adopted updated regulations targeting nail products that contain triphenyl phosphate (TPhP), responding to growing safety concerns linked to this ingredient. All manufacturers-whether based in the United States or abroad-are now required to provide justification for the use of TPhP in nail products sold or distributed in California. Companies failing to justify or substitute this chemical will need to reformulate their products or withdraw them from shelves.
The updated legislation will come into force on October 1, 2026. Any nail product exceeding 250 parts per million (ppm) of tphp must be reported to the DTSC. This move is driving industry-wide reformulation, as brands seek alternatives to maintain market access in California.
The Role of tphp in Nail Formulations
TPhP serves primarily as a plasticizer in nail products, allowing for flexible and durable coatings.This function enhances the application and longevity of nail polishes and treatments.
However,research has linked TPhP exposure to health risks affecting the liver,hormone systems,reproductive development,and nervous system. The DTSC reports that most exposure comes from skin contact, but inhalation risks are elevated for salon professionals and frequent users in poorly ventilated spaces.
People working in nail salons, along with their families, face higher exposure than casual users. DTSC’s findings support wider efforts to reduce risks in occupational settings.As of April 28, 2026, TPhP is fully banned in all cosmetics throughout the European Union under Annex II of the Omnibus II Regulation, reflecting a broader move away from this chemical in beauty products.
Implications of the Priority Product Listing
A Priority Product classification means an item contains a chemical considered risky to human health or the environment. Under California’s rules, brands selling nail products with TPhP must submit a Priority Product Notification (PPN) to the DTSC by November 30, 2026.
The PPN is an official compliance document. It identifies the product as containing a “Chemical of Concern” and requires companies to detail why that chemical is present or what steps will be taken to replace it.
Firms can respond by removing TPhP, switching to a safer ingredient, or discontinuing the product’s distribution in California. Alternatively, they may conduct an Alternatives Analysis-an evaluation required by the DTSC to explore and document safer substitute chemicals and their feasibility.
Non-Compliance and Enforcement Actions
If a manufacturer does not complete the required steps on schedule,DTSC may add the product and company to it’s Failure to Comply List. After this happens and an official notice is issued, retailers, importers, and even product assemblers may become responsible for halting distribution and sales throughout the state.
This process increases accountability across the supply chain,prompting compliance not only from creators but from all parties involved in the product’s journey to market.
Wider Moves toward Safer Nail Product Ingredients
TPhP is not the only nail ingredient under close scrutiny or facing global bans. For instance, trimethylbenzoyl diphenylphosphine oxide (TPO) is subject to restriction in several regions. The European Chemicals Agency (ECHA) classifies TPO as a CMR 1B substance, linked to carcinogenic, mutagenic, and reproductive risks.
In 2025, Morocco’s Agency for Medicines and Health Products enacted a comprehensive ban on TPO in nail products, affecting import, manufacturing, marketing, and use. The Moroccan action was soon followed by a similar EU restriction, reflecting a coordinated push against high-risk cosmetic ingredients.
Prompted by the Moroccan rule, Dubai’s Municipality enhanced its Central Laboratory’s capabilities with modern testing methods to identify TPO in nail polish. This technical shift highlights how regulatory changes drive laboratories and brands to update detection and quality assurance protocols, supporting safer products for consumers and workers alike.
