PFAS Functions in Cosmetic Formulations
PFAS serve multiple functions in cosmetics and personal care products: they provide smooth texture and spreadability in foundations and lipsticks, water resistance in mascaras and sunscreens, long-lasting adhesion in lip products, and conditioning properties in hair care. The estimated 3,000+ personal care products containing PFAS represent a significant daily dermal exposure source for regular users.
Studies analyzing popular cosmetic brands have found PFAS in 56% of foundations, 48% of lip products, and 47% of mascaras tested — often without disclosure on product labels. High concentrations of PFAS have been detected in waterproof mascara and long-wear liquid lipstick, products applied near sensitive mucous membranes.
EU Cosmetics Regulation PFAS Restrictions
The EU Cosmetics Regulation restricts substances that are banned under REACH or designated as SVHCs from use in cosmetics. Several PFAS including PFOA and PFOS are prohibited in EU cosmetic formulations. The proposed universal PFAS restriction under REACH would, if adopted, prohibit virtually all PFAS in cosmetics — a major departure from the current compound-by-compound approach.
European cosmetics brands have generally been more proactive than U.S. counterparts in reformulating to eliminate PFAS, in part due to EU regulatory pressure and in part due to consumer preferences in European markets.
U.S. FDA Authority and Ongoing Developments
The FDA regulates cosmetics under the Federal Food, Drug, and Cosmetic Act, which historically provided limited pre-market safety review authority. The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) strengthened FDA’s authority to require safety substantiation and to mandate facility registration and product listing — creating a foundation for future PFAS-specific cosmetic regulations.
Several states including California have enacted laws requiring disclosure of PFAS in cosmetics, with California’s AB 2771 prohibiting intentionally added PFAS in cosmetics beginning January 2025. Consumer testing services and advocacy organizations have published databases of PFAS-containing cosmetic products to support informed consumer choice.