Upcoming California DTSC Deadlines for Nail Products Containing TPhP

Cosmetics manufacturers and distributors must prepare for regulatory deadlines enforced by the California Department of Toxic Substances Control (DTSC). The agency has enacted new regulations specifically targeting nail products that contain triphenyl phosphate (TPhP) at concentrations exceeding 250 parts per million (ppm). 

Companies marketing these affected formulations within California are subject to a mandatory two-step compliance framework. The immediate requirement mandates that responsible entities file a Priority Product Notification with the CA DTSC no later than November 30, 2026. 

Following this initial disclosure, organizations must commit to a secondary compliance action by March 30, 2027. By this deadline, businesses must submit one of the following official documents to the state: 

• A notification indicating the intent or confirmation to remove the chemical from the product. 
• A notification indicating the intent or confirmation to remove the specific product from the California market. 
• A notification indicating the intent or confirmation of a product-chemical replacement. 
• A Preliminary Alternatives Analysis Report, or utilizing other approved alternate reporting options. 

Please contact our team if you would like us to review your nail product formulations and assist you with timely submissions and prevent potential market disruptions.