This is not strictly speaking breaking news (since the measure had been in the pipeline for several years, even though it was not “officially” confirmed for cosmetics until May 2025), but the ban on Trimethylbenzoyl Diphenylphosphine Oxide (TPO), used in artificial nail preparations, as of 1 September, has caused quite a stir recently. So much so that the European Commission saw fit to publish a clarification in the form of a Q&A…
Background
A brief historical overview in four dates (which, it should be noted, are not all recent).
• On 24 August 2020, the European Chemicals Agency (ECHA) launched a consultation on Sweden’s proposal for the harmonised classification and labelling of TPO as Rep. 1B, H360Fd (May damage fertility - May damage the unborn child). This is a first serious indication of a possible CMR 1 classification for the substance, which would then be banned under Article 15 of European Cosmetics Regulation 1223/2009…
• On 16 September 2021, the ECHA’s RAC validates this classification. From this point onwards, only a defence dossier submitted by the industry to the SCCS could “save” TPO, if the Scientific Committee found it sufficiently robust to justify an exemption from the ban…
• On 5 January 2024, the European Commission publishes Delegated Regulation (EU) 2024/197, which constitutes the 21st ATP (Adaptation to Technical and Scientific Progress) of the European CLP Regulation (Classification, Labelling and Packaging of Substances), and which formalises the classification of TPO as Rep. 1B. The industry is not defending the substance: the die is cast.
• On 13 May 2025, the European Commission publishes Regulation (EU) 2025/877, the seventh annual …
