California Lists Certain TPhP-Containing Nail Products as Priority Products

California’s Department of Toxic Substances Control has finalised a new regulation covering nail products that contain Triphenyl Phosphate (TPhP) at concentrations above 250 parts per million.

The regulation will take effect on 1 October 2026 and will classify affected nail products as Priority Products under California’s Safer Consumer Products framework. The measure is intended to address potential health risks associated with exposure to TPhP, particularly for nail salon professionals and consumers.

The 250 ppm threshold applies regardless of how TPhP is present in the product. Consequently, nail products may fall within scope where the substance is intentionally added to the formulation or occurs as a residual substance, impurity or contaminant.

The regulation does not introduce an automatic prohibition on the sale of affected nail products. However, manufacturers will become subject to specific obligations under the Safer Consumer Products Regulations.

According to the implementation timeline established by the DTSC, manufacturers of products falling within scope must submit a Priority Product Notification by 30 November 2026.

Following notification, companies may need to assess the regulatory options available for their products. These may include reformulating to remove or replace TPhP, withdrawing the affected product from the California market or conducting an Alternatives Analysis to evaluate potential safer substitutes.

Companies marketing nail polishes, gels, artificial nail systems or other nail products in California should review their formulations, raw-material specifications and supplier documentation to determine whether TPhP may be present above the applicable threshold.

Particular attention should be given to trace concentrations and impurities, as the regulation is not limited to products in which TPhP appears as a deliberately added ingredient.

Businesses affected by the new requirements should begin gathering the necessary compositional and supply-chain information in advance of the October 2026 effective date and the November notification deadline.