GB Interpretation of ‘Making available’ Dates for Banned Ingredients – Professional Use

Further to this news item, the ban of trimethylbenzoyl diphenylphosphine oxide (TPO) in cosmetic products in GB is expected to come into place with a ‘making available’ (off-shelf) date of 15 February 2027.

CTPA’s interpretation of the UK Cosmetics Regulation’s ‘making available’ date for products containing banned ingredients - when used by professionals - is that professionals may continue to use these products on clients after the deadline, but cannot purchase them from distributors after the ‘making available’ date. 

CTPA has discussed this interpretation with Trading Standards in the UK and both parties are aligned on this position.

Background information on TPO ban in cosmetics

 This ban is based on a “worst-case scenario” assessment, not on how TPO is actually used in cosmetic products. In reality, the amount of TPO used in nail products is extremely low and it is applied to nails, so our exposure to this ingredient is very low . Cosmetic products containing TPO have passed rigorous checks to ensure their safety, by qualified safety assessors, before being sold.

This is further supported by the fact that an independent expert scientific panel, the Scientific Committee on Consumer Safety (SCCS) conducted a detailed safety review of TPO in 2014 and concluded that the way it is used in cosmetics is safe.  

TPO has been reclassified under a separate piece of chemicals legislation, the GB CLP (Classification, Labelling and Packaging) Regulation, meaning that the cosmetics industry would need to submit additional information to the authorities to continue using it in cosmetic products.  The additional information would need to show that not only is the ingredient safe to use, but also that there are no suitable alternative ingredients to TPO available and that TPO is used safely in food.  While the safety of TPO could be proved, it was the difficulty with gathering the additional information which meant that the cosmetics industry did not seek an exemption from the authorities to continue using TPO in cosmetics.

If you see TPO (labelled as Trimethylbenzoyl diphenylphosphine oxide) on the ingredient list of your cosmetics and personal care products in GB, please be reassured that these products are still safe and legal to use in salons until stock lasts.