The Triphenyl Phosphate Ban: What Changed and the Reformulation Deadline

Spectra Cosmetic Compliance

This ban is part of Regulation (EU) 2026/909 (Omnibus 2). Confirm the current detail for your specific products, as positions can change.

What is triphenyl phosphate?

Triphenyl phosphate (TPhP) is a substance used in cosmetics as a plasticiser an ingredient that softens or adds flexibility to synthetic polymers. Its main use is in nail products, such as nail polishes and treatments, where it helps improve flexibility, durability and adhesion of the film the product forms on the nail.

Interestingly, triphenyl phosphate was not previously specifically regulated under the EU Cosmetics Regulation it was in use as a plasticiser without a dedicated restriction. That changed when its safety was assessed and the decision taken to prohibit it, moving it from an unregulated ingredient to a banned one.

Why it has been banned

The ban follows an assessment by the Scientific Committee on Consumer Safety (SCCS), which concluded it could not confirm the safety of Triphenyl Phosphate the available data was insufficient to fully assess and rule out potential genotoxicity, the potential to damage genetic material. Concerns about endocrine-disrupting properties have also been associated with the substance.

Where the SCCS cannot conclude a substance is safe, the precautionary response under the EU Cosmetics Regulation is to restrict or prohibit it. In this case, on the basis of unresolved safety concerns, Triphenyl Phosphate has been added to Annex II the list of substances prohibited in cosmetics under Regulation (EU) 2026/909, rather than merely restricted under Annex III.

A full ban, not a restriction

Because triphenyl phosphate is added to Annex II, this is a complete prohibition, not a restriction to a permitted level. There is no maximum concentration at which it may be used; it simply cannot be present in a cosmetic product placed on the EU market once the ban applies. This is a stronger measure than the restrictions applied to some other substances in the same amendment.

The practical consequence is that any product containing triphenyl phosphate requires full reformulation to remove it entirely. Reducing the level is not an option the substance must be replaced. For nail products built around its plasticising properties, this is a genuine formulation change.

The deadline

Under Omnibus 2, products containing triphenyl phosphate and not complying cannot be placed on the EU market from 1 January 2027, and cannot be made available on the market from 1 July 2028. So there is a placing on market deadline at the start of 2027, with a sell through period for existing stock running into mid 2028.

This gives brands a defined window to reformulate, but the placing on market deadline is firm: from the start of 2027, new products entering the market must be triphenyl phosphate free. Given that reformulation and reassessment take time, brands should be well advanced before that date rather than approaching it at the last minute.

Who is affected

The ban primarily affects nail product brands and manufacturers whose nail polishes, treatments or similar products use triphenyl phosphate as a plasticiser. Because it was a common plasticiser in nail products, a significant number of nail formulations may contain it, so nail brands should treat this as a priority check.

Brands should examine the INCI lists and formulations of their nail products for triphenyl phosphate. Where it is present, reformulation is required for the EU market. Products sold in Northern Ireland are also affected, as Northern Ireland follows the EU rules.

What brands need to do

• Identify every product containing Triphenyl Phosphate
• Reformulate to remove it, using an alternative plasticiser
• Complete reformulation ahead of the 1 January 2027 placing on market deadline
• Manage existing stock within the 1 July 2028 sell-through period
• Update the CPSR and PIF for every reformulated product
• Treat reformulation as a full development exercise, not a casual swap since the plasticiser affects a nail product's flexibility, durability, and finish
• Test the new formula for performance and stability before reassessment

Our guide to Omnibus 2 covers the other substances affected by the same amendment.

Reformulating nail products without TPhP

Removing triphenyl phosphate from a nail formulation is a genuine technical exercise, because the substance was performing a real function as a plasticiser giving the nail film flexibility, durability and adhesion. Simply omitting it can leave a product that chips, cracks or adheres poorly, so brands need to reformulate with an alternative plasticiser or resin system that restores those properties.

This means reformulation should be approached as proper product development: select an alternative, test that the reformulated product performs wear, flexibility, adhesion, drying and remains stable over its shelf life, and then reassess it. Nail products are demanding in performance terms, so the replacement has to work as well as the original to be commercially viable, not just to be compliant.

The encouraging news is that the nail industry has been moving away from triphenyl phosphate, so alternative approaches exist and suppliers are increasingly geared up for TPhP-free formulation. Brands that start early can reformulate in an orderly way, test thoroughly, and update their CPSRs and PIFs well before the deadline, rather than scrambling as it approaches.

A nail sector facing two bans at once

The triphenyl phosphate ban lands on a nail sector already adapting to another major change: the prohibition of TPO, the gel-nail photoinitiator banned in EU cosmetics from September 2025 and in Great Britain from August 2026. Together, these two measures mean nail brands are reformulating away from two different ingredients a photoinitiator and a plasticiser in a relatively short window.

For nail brands, the sensible response is to treat these not as separate fire fights but as a single reformulation programme: review the whole nail range against both bans at once, and reformulate products to be free of both TPO (where relevant) and triphenyl phosphate together. Doing the work in one coordinated effort is more efficient than reformulating twice, and produces products that are compliant across both markets and both measures.

It also underlines a broader point: the nail category has been under particular regulatory focus, and further change is plausible as more nail relevant substances are assessed. Nail brands benefit especially from active regulatory monitoring, so they can anticipate rather than react to the next restriction affecting their formulations.