Triphenyl phosphate in EU cosmetics: the 2027 and 2028 deadlines

Brands with nail products have two dates to put on the calendar. From 1 January 2027, cosmetic products containing triphenyl phosphate that do not comply with the new prohibition cannot be placed on the EU market. From 1 July 2028, those noncompliant products cannot be made available on the EU market.¹

Commission Regulation (EU) 2026/909 adds triphenyl phosphate to Annex II of the EU Cosmetics Regulation, the list of prohibited substances. Its corrected entry number is 1767; the originally published regulation showed 1752, which was changed by a corrigendum.¹² The regulation entered into force on 18 May 2026, with later transition dates for this change. Those dates cover different points in a product’s journey through the supply chain. Neither is simply a manufacturing deadline.¹

What changed, and why?

Triphenyl phosphate, also called TPP, has the INCI name Triphenyl Phosphate, CAS number 115-86-6 and EC number 204-112-2. The Commission describes it as a plasticiser used to soften or make synthetic polymers more flexible.¹

TPP is different from TPO, or Trimethylbenzoyl Diphenylphosphine Oxide (CAS 75980-60-8), another ingredient associated with nail products. TPO has been prohibited in EU cosmetics since 1 September 2025; the TPP transition dates in this article do not apply to it.³

The Scientific Committee on Consumer Safety (SCCS) evaluated its use as a plasticiser in nail products at up to 5%. In its final 2024 opinion, the committee said the available information did not allow it to conclude on safety because a potential for genotoxicity could not be excluded. The Commission subsequently placed the substance on the prohibited list.¹⁴

The 5% was part of the question put to the SCCS; it is not a permitted limit under the new entry. An inability to conclude on safety is also distinct from a finding that every use has been shown to cause harm.

Two deadlines, two different actions

Under the Cosmetics Regulation, placing on the market is the first making available of a cosmetic product on the EU market. Making available is supply for distribution, consumption or use during a commercial activity, whether paid for or free of charge.⁵

The European Commission’s Blue Guide explains that market placement concerns each individual product, not just a product model. An earlier sale of the same nail polish does not establish that every bottle made later was already placed on the market.⁶

Consider a fictional batch of nail polish containing intentionally added triphenyl phosphate. Bottles sold and delivered by the manufacturer to an EU retailer in December 2026 have been supplied before the first deadline. Subject to the other applicable requirements, those bottles may continue through the supply chain during the transition, but noncompliant stock must not be made available from 1 July 2028. Bottles from the same product line that are first placed on the EU market on 2 January 2027 do not gain the earlier bottles’ market-placement history.¹⁶

For stock near either deadline, identify the actual units and transactions. A batch’s production date, a product notification or a historic launch date alone does not demonstrate when those units were first placed on the market. Keep relevant commercial and delivery records, and resolve uncertain cases with the responsible person and regulatory advisers before releasing stock.

Check the formula and the evidence

Start with nail products, where the SCCS examined the substance’s plasticising role, then check the rest of the cosmetics portfolio as well. The Annex II entry is not limited to a particular cosmetic category.¹⁴

• Search formula records, ingredient lists and supplier specifications using the INCI name and CAS number. Ask suppliers about complete compositions of mixtures and any relevant raw-material changes.
• Identify affected formula versions, product codes and finished stock. Include products made by contract manufacturers and products awaiting import or distribution.
• Agree a reformulation and testing plan with the relevant formulation and safety teams. A replacement plasticiser needs its own assessment for the intended product, including performance, stability and compatibility; a supplier’s proposed substitute is a starting point for review.
• Connect the approved formula, safety assessment, labeling and product information file to the version that will actually be supplied. Plan stock decisions with manufacturers, distributors and retailers before the relevant deadline.

A supplier declaration is useful only if the team can connect it to the material, version and product being assessed. Keep the supporting explanation and follow up on gaps rather than relying on a generic statement for an entire portfolio.

What about an unintended trace?

The prohibition concerns a substance listed in Annex II. Article 17 of the Cosmetics Regulation separately addresses the unintended presence of a small quantity of a prohibited substance when it is technically unavoidable in good manufacturing practice and the product remains safe under Article 3. Annex I also calls for evidence of technical unavoidability when prohibited-substance traces are present.⁵

That provision is not a blanket permission to keep adding triphenyl phosphate to a formula, and the new entry does not set a general trace allowance. If an unintended trace is identified, document its origin and the evidence for technical unavoidability and have the qualified safety assessor evaluate the finished product. Do not assume that “below detection” or a supplier’s statement alone resolves the assessment.

Keep the other ingredient changes separate

Regulation 2026/909 also changes rules for several other substances, including benzyl salicylate, citral, aluminium-containing ingredients and the UV filter DHHB. Its entries and footnotes have their own conditions and, where provided, transition dates.¹ The triphenyl phosphate dates should not be copied to every ingredient in the regulation without checking the relevant entry.

For the first review, select one affected nail product and trace its current formula, suppliers and unsold units. Record which team owns the reformulation, which stock may still move through the EU supply chain, and what evidence supports those decisions.

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