Date: 23 October 2026
Prepared for: Importers, Manufacturers, Suppliers and Buyers of Cosmetic Products for the EU, US, Canadian, Australian and New Zealand Markets
Triphenyl phosphate (TPhP, CAS 115-86-6) is now under active control in the European Union, California and Canada. EU has prohibited TPhP in all cosmetic products from 1 January 2027. California has listed nail products containing TPhP above 250 ppm as a Priority Product, with notification due to the Department of Toxic Substances Control by 30 November 2026. Canada has proposed restrictions but has not yet legislated.
1) EU: TPhP is prohibited from 1 January 2027
Commission Regulation (EU) 2026/909 of 27 April 2026 amends Regulation (EC) No 1223/2009, revising Annexes II, III, V and VI. It was published in the Official Journal on 28 April 2026 and entered into force on 18 May 2026. Annex II entries carry no permitted concentration, so no level of TPhP keeps a product lawful on the Union market.
The two dates govern two different things: 1 January 2027 is the last date on which a product containing TPhP may be placed on the Union market, which means first supply. 1 July 2028 is the last date on which product already placed on the market may be made available, so existing stock can clear the market until 30 June 2028. The obligation attaches to the product, so it reaches TPhP carried over from a raw material. The scientific basis is SCCS opinion SCCS/1664/24 of 25 July 2024, which could not exclude potential genotoxicity on the information submitted. In the consolidated Annex II, TPhP is entry 1767.
2) California: A notification duty above 250 ppm
The Priority Product listing took effect on 1 October 2026 (DTSC reference R-2025-03R). Above 250 ppm, the manufacturer must:
l Submit a Priority Product Notification to DTSC via CalSAFER by 30 November 2026.
l By 30 March 2027, select one of four routes: Chemical Removal, Product Removal, Product-Chemical Replacement, or a Preliminary Alternatives Analysis Report.
DTSC does not mandate a response and does not prohibit the product. Products at or below 250 ppm require no action, but keep your evidence on file.
3) Canada, United Kingdom, Australia and New Zealand
l Canada: Environment and Climate Change Canada and Health Canada published an updated Risk Management Scope for triphenyl phosphate in November 2025 and propose to conclude that it is toxic under paragraph 64(c) of the Canadian Environmental Protection Act, 1999, with TPhP proposed for addition to Part 2 of Schedule 1 and for listing on the Cosmetic Ingredient Hotlist. The comment period ran to 21 January 2026 and no final Risk Management Approach has been published, so nothing is enforceable today.
l UK: TPhP is not prohibited under the Assimilated Regulation (EC) No 1223/2009 (the UK’s retained cosmetics framework). No UK statutory instrument mirroring Regulation (EU) 2026/909 has been made to date, so TPhP remains unregulated in UK cosmetics.
l Australia: There is no cosmetic-specific prohibition. Although AICIS completed health assessments (2018 and 2023), no cosmetic restrictions were introduced. It is not listed in the Poisons Standard as a prohibited cosmetic ingredient.
l New Zealand: TPhP is not listed in Schedules 4 or 5 of the Cosmetic Products Group Standard 2020. While it is listed on the NZIoC, cosmetic compliance is assessed under the HSNO Act and the Group Standard, with no specific cosmetic prohibition.
Market | What it means for TPhP | Key Dates |
EU | Prohibited in all cosmetics. No permitted concentration. Reaches TPhP as a contaminant or carry-over from raw materials. | 1 January 2027 – no placing on the EU market; 1 July 2028 – no making available |
US - California | Priority Product above 250 ppm. Notification plus one of four compliance routes. 250 ppm is the listing threshold, not a permitted level. | 30 November 2026 – notification due; 30 March 2027 – compliance route due |
US - Federal | No federal prohibition or restriction. | No restriction |
Canada | Proposed toxic classification under CEPA and proposed Hotlist restriction. | No compliance date set. Proposal only. |
UK | Not yet prohibited. Expected to follow the EU. | No restriction |
Australia / New Zealand | No cosmetic-specific prohibition. | No restriction |
What this means for you
1. Check and verify your supply chain. TPhP can be present as a carry-over from raw materials. Ask suppliers in writing for actual test data (not just "free from" claims) and confirm the concentration in the finished product.
2. California Compliance: If any formulation exceeds 250 ppm, you must file a Priority Product Notification by 30 Nov 2026. If unsure, test immediately.
3. EU Transition: From 1 Jan 2027, no new products can enter the EU. Existing stock can sell through until 30 June 2028. Plan your reformulation early, or keep proof of early placement.
4. Reformulation: Substitutes must be film-tested for adhesion, drying time and stability. Update your CPSR and PIF, and record the change against your CPNP.
Reference
Commission Regulation (EU) 2026/909 of 27 April 2026 amending Regulation (EC) No 1223/2009; California Code of Regulations, Title 22, Division 4.5, Chapter 55, Article 11, sections 69511 and 69511.10 (DTSC reference R-2025-03R); SCCS opinion SCCS/1664/24 of 25 July 2024; Risk Management Scope for Triphenyl phosphate, ECCC and Health Canada, November 2025.
This document is prepared by EASYHARMONY TECHNOLOGY CO., LIMITED (EHC) for your reference and may be shared with your suppliers.
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