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Why PFAS turn up in cosmetics, and why it is not always intentional
PFAS can be present in cosmetic products by design or by accident. Find out why, and what the growing regulatory response means for product safety professionals.
Quick summary
- PFAS may be present in cosmetics by design or through unintentional contamination at multiple points in the supply chain.
- Research shows PFAS have been detected in products where they were not listed as ingredients, exposing a significant gap in labeling.
- Regulatory pressure is building globally, with US state bans, France’s national prohibition from 2026, and broader EU restrictions under development.
Per- and polyfluoroalkyl substances (PFAS) have been detected across a wider range of cosmetic products than many in the industry anticipated, and not always as a result of intentional use. For product safety and compliance professionals, that finding raises a practical question: if these chemicals were not deliberately added, how did they get there?
PFAS have become a major focus of regulatory, scientific, and consumer attention. These chemicals are often referenced as “forever chemicals” because of their extreme persistence and accumulation potential in environmental systems and human tissues. PFAS appear in a wide range of industrial and consumer applications. Cosmetics are one of the product categories where they have been detected — through intentional use, or unintentional introduction through the supply chain, impurities, degradation, or contamination.
What are PFAS?
PFAS are a broad class of more than 10,000 synthetic chemicals characterized by carbon–fluorine bonds. This bond is one of the strongest bonds in organic chemistry. It is this stability that makes PFAS so resistant to degradation, both in the environment and in the body.
This gives PFAS several distinctive properties:
- Oil and stain resistance
- Thermal and chemical stability
- Low surface energy, enabling smooth, spreadable textures
- Durability and film‑forming ability
Because of these unique properties, PFAS have found their way into an exceptionally broad range of applications.
Why PFAS have been used in cosmetics
Historically, PFAS were used in cosmetics for performance benefits that are difficult to achieve with other chemistries. Their functional advantages include:
Long‑lasting wear
Some PFAS can create thin, durable films that help products stay in place. These films repel both water and oil, which improves product integrity and durability. Consumer demand for products that perform throughout the day has been a key driver of long-wear formulations, and brands frequently market these benefits with language emphasizing all-day wear and no touch-ups required. This is especially valued in:
- Long‑wear foundations
- Transfer‑resistant lipsticks
- Waterproof mascaras
It’s worth noting that long-wear performance can be achieved through a range of formulation approaches. PFAS are one historical route, not the only one.
Texture and finish
Performance is only part of the picture. Consumers also expect cosmetics to feel good, and the film-forming ability and low surface energy that make PFAS useful for durability are the same properties that can contribute to texture and finish. Some PFAS reduce surface tension, giving products:
- A silky, smooth finish
- Even application and adhesion
- Lightweight textures
- Shine or matte effects
Intentional versus unintentional PFAS in cosmetics
PFAS may be present in cosmetics for intentional or unintentional reasons. PFAS are water soluble, colorless, tasteless, and odorless.
Formulators may intentionally add PFAS directly to achieve the performance benefits described above. However, PFAS can also enter cosmetics unintentionally through:
Impurities in raw materials
Some PFAS form as by‑products during the manufacturing process. Non-polymer PFAS can be present as impurities in fluoropolymer-containing products because these PFAS are used as processing aids in chemical production.
Contamination in the complex global supply chain
- Raw materials may be processed on equipment treated with PFAS‑based lubricants
- Packaging materials may contain fluorinated coatings
- Water used in manufacturing may contain trace PFAS
Degradation of precursor compounds
Some PFAS precursors can degrade into more persistent PFAS under certain conditions.
What the research shows
The scale of unintentional presence became clearer following a 2021 study by Whitehead et al., which screened 231 North American cosmetic products for fluorinated compounds. All 29 products selected for targeted PFAS analysis contained multiple PFAS, with fluorotelomer alcohols, methacrylates, and phosphate esters most commonly detected. Only 3% had any PFAS listed as ingredients, underscoring the extent to which unintentional contamination can go undetected and unreported.
Regulatory attention and industry response
PFAS use in cosmetics is increasingly scrutinized by regulators and policymakers on a global basis.
European Union
The EU Chemicals Strategy for Sustainability identifies PFAS as a priority for phase‑out unless essential.
- A proposed EU-wide PFAS restriction under REACH (submitted by five countries in 2023) would significantly limit PFAS use across sectors, including cosmetics.
- Several PFAS, including PFOA and PFOS, are already restricted under the POPs Regulation.
- France adopted a national PFAS law in February 2025 banning the manufacture, import, export, and sale of PFAS-containing cosmetics, taking effect from 2026.
- Under Article 15 of the EU Cosmetics Regulation, PFAS classified as CMR (carcinogenic, mutagenic, or toxic for reproduction) substances are already prohibited, with Omnibus VII updates published in May 2025 reinforcing the automatic ban of newly classified CMR substances.
United States
- Multiple US states including California, Colorado, Minnesota, and Maine have enacted or proposed bans on intentionally added PFAS in cosmetics.
- The FDA has been expanding its research on PFAS in consumer products, but there is currently no federal ban. While specific prohibitions are not yet in place, regulatory oversight has increased through the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). This law strengthens the FDA’s authority by requiring cosmetic manufacturers to register their facilities, list their products, report serious adverse events, and maintain evidence demonstrating product safety. It also introduces stricter labeling requirements and, for the first time, grants the FDA the power to mandate recalls of unsafe cosmetic products.
Canada
- Canada is assessing PFAS as a class under its Chemicals Management Plan and has signaled future restrictions.
Industry initiatives
- Several major cosmetics companies have announced voluntary phase‑outs of PFAS.
- Suppliers are developing fluorine‑free alternatives for film‑forming and long‑wear performance.
- Retailers such as Sephora and Credo have added PFAS to their restricted substances or clean beauty lists, with both programs now covering formulation ingredients and packaging materials.
Looking ahead
We can expect an increasing focus on PFAS in consumer products. Key trends include:
- Reformulation efforts to replace PFAS with safer, high‑performance alternatives
- Greater supply chain transparency, including traceability of raw materials
- Analytical testing to detect trace PFAS
- Broader integration of clear reporting methods
For compliance and product safety professionals, the direction of travel is clear: greater scrutiny, stricter requirements, and a growing expectation of transparency across the supply chain.
PFAS in cosmetics FAQs
What does “intentionally added PFAS” mean in a regulatory context?
Intentionally added PFAS are those incorporated into a product formulation by design, to deliver a specific function such as water resistance, durability, or texture. This is an important distinction in regulation because many restrictions — including several US state laws — apply specifically to intentionally added PFAS rather than to trace amounts present as impurities or contaminants. Understanding this distinction matters for compliance, because a product may contain detectable PFAS without any having been deliberately used.
If a product doesn’t list PFAS as an ingredient, can it still contain them?
Yes. As the 2021 Whitehead study found, only 3% of cosmetic products in which PFAS were detected had any PFAS listed as ingredients. PFAS can enter products unintentionally through raw material impurities, manufacturing contamination, fluorinated packaging, or the degradation of precursor compounds — none of which would typically appear on an ingredient label. This is one reason analytical testing is increasingly important alongside ingredient declaration.
Which cosmetic product categories are most likely to contain PFAS?
Products marketed for long wear, water resistance, or transfer resistance have historically been most associated with PFAS use, including foundations, mascaras, eyeliners, and lip products. However, PFAS have been detected across a broader range of categories than expected, including some products where intentional use would be unlikely, suggesting unintentional contamination is widespread.
What is the regulatory position on PFAS in cosmetics in the United States?
The US does not currently have a federal ban on PFAS in cosmetics, but action at state level has been significant. California, Colorado, Minnesota, and Maine are among the states that have enacted or proposed restrictions on intentionally added PFAS in cosmetics. At federal level, the FDA’s authority over cosmetics was significantly strengthened by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), which introduced facility registration, product listing, and adverse event reporting requirements for the first time. While MoCRA does not specifically ban PFAS, it creates a framework for greater oversight and safety substantiation that is likely to bring additional scrutiny to PFAS-containing formulations. With state-level restrictions continuing to expand, companies selling across multiple US markets face an increasingly complex patchwork of requirements.
Are PFAS in cosmetics currently banned in the EU?
Not comprehensively, but restrictions are tightening. PFAS substances classified as CMR (carcinogenic, mutagenic, or toxic to reproduction) are already prohibited under the EU Cosmetics Regulation, with updates in 2025 reinforcing the automatic ban of newly classified substances. A broader PFAS restriction under REACH, proposed by five countries in 2023, remains under consideration. At national level, France has moved ahead independently, banning PFAS-containing cosmetics from 2026.
How can manufacturers test for PFAS in their products?
Several analytical methods are used depending on the level of detail required. Total fluorine screening — such as particle-induced gamma-ray emission spectroscopy (PIGE) — can indicate whether fluorinated compounds are present. More targeted methods such as LC-MS/MS and GC-MS can identify and quantify specific PFAS. As regulatory requirements develop, having a clear testing strategy in place, including screening raw materials and finished products, is becoming an important part of supply chain due diligence.
What should companies do now to prepare for upcoming PFAS restrictions?
The most important steps are understanding where PFAS may be present in your products and supply chain, and monitoring the regulatory landscape across all relevant markets. This means auditing raw materials and suppliers, considering analytical testing where there is uncertainty, and tracking developments in key jurisdictions including the EU, US states, and national measures such as France’s 2026 ban. Enhesa’s PFAS Tracker provides a single resource for monitoring PFAS regulations across global markets as requirements continue to evolve.
