Per- and polyfluoroalkyl substances (PFAS) have long been prized in cosmetics and personal care formulations for their ability to create smooth textures, long-lasting water resistance, and durable finishes. Foundations, mascaras, lipsticks, blushes, and setting sprays have routinely contained PFAS—most commonly as perfluorooctyl triethoxysilane (POTS), polyperfluoromethylisopropyl ether (trade name Profluorid), and various fluoropolymers. The dermal absorption pathway, combined with daily repeated application and the potential for PFAS to enter waterways through cosmetic rinse-off, has made cosmetics one of the highest-profile PFAS product categories for regulators globally.
California: First US State to Ban PFAS in Cosmetics (January 2025)
California’s PFAS-Free Cosmetics Act (Assembly Bill 2771) made California the first U.S. state to prohibit the manufacture, sale, delivery, holding, or offering for sale of any cosmetic product containing intentionally added PFAS, effective January 1, 2025. The law covers a broad definition of cosmetics including skincare, makeup, hair care products, nail polish, and fragrances. Enforcement is administered by the California Department of Public Health (CDPH) in coordination with the California Department of Toxic Substances Control (DTSC). Given California’s status as the world’s fifth-largest economy and one of the largest cosmetics markets globally, the law has effectively set a national standard—major cosmetic brands have reformulated their California-sold product lines rather than maintain separate PFAS-containing product variants.
France: January 2026 Cosmetics Ban with Criminal Enforcement
France’s Law No. 2025-188, effective January 1, 2026, prohibits the manufacture, import, export, and sale of any cosmetic product containing intentionally added PFAS in France. France’s approach is more comprehensive than California’s in one critical respect: it includes an industrial emissions levy of 100 euros per 100 grams of PFAS discharged into water by manufacturing facilities, creating a financial incentive for cosmetics manufacturers to eliminate PFAS from their production processes as well as their formulations. Customs authorities enforce import controls, and the market surveillance body (DGCCRF) conducts domestic product audits.
EU Cosmetics Regulation: Restrictions Already in Force
Under the EU Cosmetics Regulation (EC) No. 1223/2009, specific PFAS compounds have been progressively restricted in cosmetics based on safety evaluations by the Scientific Committee on Consumer Safety (SCCS). PFOS and PFOA are already prohibited in EU cosmetics. The European Commission is evaluating additional PFAS restrictions, and the broader REACH restriction proposal—if finalized—would cover cosmetics as a product category. Several PFAS used as lubricants in spray cosmetics (under names such as Perfluorodecalin, Perfluorononyl Dimethicone, and Perfluorooctyl Triethoxysilane) remain in use under current EU rules but face increasing scrutiny as the REACH process advances.
The Spreading US State Landscape
Following California’s lead, a significant number of additional U.S. states enacted or advanced PFAS cosmetics legislation in 2024 and 2025. Colorado, Maryland, Minnesota, New York, Vermont, and Washington all enacted cosmetics PFAS bans that take effect between 2025 and 2027. The variation in effective dates, covered product categories, and PFAS definitions creates compliance complexity for brands selling across state lines—but the cumulative effect is a de facto national phase-out of intentionally added PFAS in cosmetics for brands that sell into multiple major state markets. The Personal Care Products Council, representing large cosmetic manufacturers, has acknowledged that reformulation is the only viable commercial strategy given the breadth and pace of state legislation.
Reformulation Challenges and Alternative Ingredients
Cosmetic formulators face genuine technical challenges in replacing PFAS-derived properties. The extreme hydrophobicity and low surface energy of fluorinated compounds are difficult to replicate with hydrocarbon-based or silicone-based alternatives without sacrificing performance. Mascara products that relied on fluoropolymers for smudge resistance, foundations that used PFAS for a matte finish, and setting sprays that used fluorinated compounds for extended wear are undergoing intensive reformulation programs. Plant-derived waxes, modified silicones, and novel polymeric emulsifiers are being evaluated as substitutes. Several major cosmetics conglomerates have committed to complete PFAS-free formulation portfolios by 2026, with independent brands following at varying speeds.
Water Treatment Connection: Cosmetics Manufacturing and Rinse-Off
The cosmetics industry contributes to PFAS water contamination through two pathways: manufacturing process wastewater from facilities producing PFAS-containing formulations, and rinse-off from consumer use of PFAS-containing skincare, shampoo, and wash-off cosmetics that discharge to municipal wastewater systems. As cosmetics PFAS bans take effect, the manufacturing source pathway will diminish—but wastewater treatment plants processing influent from densely populated urban areas will continue to detect cosmetics-derived PFAS from historical product stockpiles until they are fully depleted. Point-of-use water treatment systems that address emerging PFAS compounds including fluoropolymers and short-chain PFAS substitutes will need to demonstrate performance against a broader compound suite than just PFOA and PFOS as the cosmetics-sourced PFAS profile in drinking water evolves.