On May 15, 2026, Argentina's National Administration of Drugs, Food and Medical Devices (ANMAT) published Order No. 2820/2026, formally incorporating Mercosur/GMC/Resolution No. 27/2025 into national law. The Order amends the list of prohibited cosmetic substances established under Order No. 6433/2015 by adding two new entries: Trimethylbenzoyl Diphenylphosphine Oxide (TPO) and N,N-Dimethyl-p-Toluidine (DMPT).
Regulatory Background
The prohibition is rooted in a Mercosur regional harmonization effort. In 2025, the Mercosur Common Market Group (GMC) adopted Resolution No. 27/2025, which adds TPO and DMPT to the regional technical regulation on cosmetic ingredient lists. This resolution aligns Mercosur member states with recent actions taken by the European Union, which classified both substances as CMR hazards and moved to prohibit their use in cosmetic products.
Argentina's cosmetics regulatory framework governs ingredient safety through Order No. 6433/2015, which maintains a list of approximately 1,400 prohibited substances. The new ANMAT Order appends TPO and DMPT as entries No. 1418 and No. 1419, respectively, expanding the prohibited list in line with updated scientific assessments of the risks these substances pose to human health.
Substances Added to the Prohibited List
1. Trimethylbenzoyl Diphenylphosphine Oxide (TPO)
TPO (CAS No. 75980-60-8, EC No. 278-355-8) is a photoinitiator widely used in UV/LED-curable nail products, including gel nail polishes and semi-permanent nail coatings. When exposed to UV or LED light, TPO initiates the polymerization reaction that cures and hardens the nail coating.
2. N,N-Dimethyl-p-Toluidine (DMPT)
DMPT (CAS No. 99-97-8, EC No. 202-805-4) is an aromatic amine that has been used as a curing accelerator or catalyst in certain nail products, including UV/LED gel systems and acrylic nail applications.
Table: Newly Prohibited Substances Under ANMAT Order No. 2820/2026
| Entry No. | Substance Name | CAS No. | EC No. |
| 1418 | Trimethylbenzoyl Diphenylphosphine Oxide (TPO) | 75980-60-8 | 278-355-8 |
| 1419 | N,N-Dimethyl-p-Toluidine (DMPT) | 99-97-8 | 202-805-4 |
Transition Period and Compliance Deadline
Order No. 2820/2026 establishes a 60-day transition period from the date of its publication in the Boletín Oficial (May 15, 2026). During this period, cosmetic products that were already authorized and placed on the Argentine market prior to the Order's publication may continue to be sold until the existing stock is depleted, provided they comply with all other applicable regulatory requirements.
After the transition period expires (approximately mid-July 2026), any cosmetic product containing TPO or DMPT that has not been reformulated will be considered non-compliant and subject to regulatory enforcement action, including potential market withdrawal.
Global Regulatory Context
Argentina's action is part of a broader global trend toward restricting CMR substances in cosmetics. Key developments in other jurisdictions include:
- European Union: Prohibited TPO in cosmetic products effective September 1, 2025, via Regulation (EU) 2025/877. DMPT is similarly subject to restriction as a CMR Category 2 mutagen under the EU Cosmetics Regulation.
CIRS Reminder
The prohibition will primarily affect manufacturers and importers of nail care products, where TPO and DMPT have been commonly used as photoinitiators and curing accelerators. Companies engaged in business in Argentina, including local manufacturers and overseas exporters, are strongly advised to note that:
- Conduct an immediate ingredient audit to determine whether any products in the Argentine market contain TPO or DMPT.
- Initiate reformulation using alternative photoinitiators and curing agents that do not carry CMR classifications.
- Ensure that new product registrations and existing market authorizations are updated to reflect compliance with the Order.
- Monitor the Boletín Oficial and ANMAT's cosmetics regulations page for any additional guidance or enforcement actions.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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