The Personal Care PFAS Exposure Pathway
PFAS are widespread in personal care and cosmetic products, where they function as film formers, texture modifiers, emulsifiers, and water-resistance agents. Studies by Environmental Working Group (EWG), the Silent Spring Institute, and academic researchers have identified PFAS in foundations, mascaras, lipsticks, sunscreens, shampoos, moisturizers, and dental floss—with some products containing PFAS at concentrations exceeding 100 parts per million. Unlike drinking water exposure, personal care PFAS exposure involves direct dermal contact and, for lip products, oral ingestion—making regulatory action on this pathway increasingly urgent.
The Dental Floss Finding and Teflon-Coated Products
A 2019 Silent Spring Institute study found PFAS in Oral-B Glide dental floss at concentrations of 100–2,000 ng/g—and discovered that women who used Glide floss had significantly higher blood levels of PFHxS than those who didn’t. The study highlighted that PTFE-coated products marketed as “glide” or “smooth” are a PFAS exposure source distinct from environmental contamination. Procter & Gamble reformulated Glide in response to consumer and regulatory pressure. PTFE-coated threads in dental floss, surgical sutures, and similar applications represent a regulatory grey area—PTFE polymers are generally excluded from PFAS definitions, but fragmentation to smaller PFAS during use and environmental degradation is a documented concern.
EU Cosmetics Regulation PFAS Action
The EU Cosmetics Regulation (EC 1223/2009) restricts substances in cosmetic products based on safety assessments. The EU Scientific Committee on Consumer Safety (SCCS) completed opinions on several PFAS used in cosmetics in 2022–2023, finding PFOA and PFOS as well as several fluoropolymers to present concern at realistic use levels. The EU Commission is preparing an amendment to the Cosmetics Regulation to restrict PFAS-based film formers and texture agents—expected to enter into force in 2025–2026 with an 18-month transition period. Simultaneously, the EU Chemicals Strategy for Sustainability (CSS) envisions a comprehensive restriction on PFAS in cosmetics under the universal REACH restriction, which would supersede and strengthen the Cosmetics Regulation action.
US State Laws: California and Colorado Lead
California’s Toxic-Free Cosmetics Act (AB 2762, enacted 2020) banned 13 substances from cosmetics including PFOA and PFOS—but did not cover the broader class of PFAS. California’s Safer Consumer Products program has designated PFAS in cosmetics as a Priority Product under SCP regulations, triggering alternatives assessment requirements. Colorado enacted HB 23-1055 in 2023 prohibiting PFAS-intentionally added cosmetics effective January 2024—one of the first state-level bans on the broader PFAS class in cosmetics. Maryland, Minnesota, and Vermont have passed similar measures effective 2025–2026. This state-level action is creating de facto national market standards ahead of anticipated federal FDA action.
FDA Regulatory Authority and Modernization Act
FDA’s cosmetics regulatory authority was significantly strengthened by the Modernization of Cosmetics Regulation Act (MoCRA), signed into law in December 2022. MoCRA requires mandatory registration, facility listing, serious adverse event reporting, and expanded FDA inspection authority for cosmetics manufacturers—foundational requirements needed before FDA can implement targeted ingredient restrictions. FDA has not yet proposed specific PFAS limits in cosmetics but has flagged the issue in its regulatory priorities. Industry groups expect FDA PFAS cosmetics action by 2025–2026, likely beginning with voluntary phase-out guidance followed by formal rulemaking for specific PFAS compounds with the strongest safety concerns.
Personal care PFAS regulation is following the well-established trajectory of drinking water and food contact materials—moving from scientific concern to voluntary industry action to mandatory regulation on an accelerating timeline.