PFAS in Cosmetics: Uses and Regulation

They are highly persistent, sometimes toxic, and no longer welcome in our cosmetic products. They are PFAS, and we’ve been hearing a great deal about them lately. And while they can still be found in some cosmetics today, that will not remain the case for much longer.

PFAS are synthetic fluorinated organic compounds. However, the presence of fluorine atoms does not automatically make a substance a PFAS. The definition used by the OECD (Organisation for Economic Co-operation and Development) is: any fluorinated substance containing at least one fully fluorinated carbon atom (a methyl or methylene group, -CF3 or -CF2), with no hydrogen, chlorine, bromine, or iodine atom attached to it. In short, any molecule containing a perfluorinated methyl or methylene group is considered a PFAS.

This definition covers a vast family of molecules (several thousand, up to 12,000 or even 15,000 depending on the source) with widely varying profiles. A distinction is made between polyfluoroalkyl and perfluoroalkyl substances (depending on the position of the perfluorinated group), and they can be either polymeric or non-polymeric. Molecule size greatly influences behavior: small, non-polymeric PFAS are more mobile, both in the environment and within organisms. Because the C-F bond is extremely stable, PFAS are highly persistent and very difficult to break down (though they are not indestructible). This is, in fact, the one characteristic PFAS share in common — beyond that, they can display a wide range of properties (and therefore uses), as well as very different toxicological profiles. It is therefore not possible to generalize about their toxicity: some are used in the medical field and are considered inert, particularly polymers.

They are found across very different sectors, including kitchenware (non-stick properties), clothing and protective equipment, aerospace, paints, medical devices, active pharmaceutical ingredients, the energy transition… and cosmetic products.

Compared to other sectors, the use of PFAS in cosmetics is relatively minor. Only 1.4% of European cosmetic products contain them, mainly in the makeup category (a little over 3.5% of products), but also in skincare, haircare, or hygiene products (under 1%, or even under 0.5%).

Under the OECD definition, 36 PFAS (polymeric or non-polymeric) have been identified in cosmetics, including the now well-known PTFE (Teflon©). They are used as emulsifiers, antistatic agents, stabilizers, or film-forming agents. Highly stable and resistant to water and oils, they also provide a glossy, smooth finish and long-lasting wear.

However, the presence of PFAS in cosmetics is not always intentional. It can result from migration out of packaging that itself contains PFAS, or from contamination via water that has not been properly purified. The problem is that conventional water treatment does not necessarily remove all PFAS, particularly the smaller molecules. Some PFAS, such as TFA (trifluoroacetic acid), are used in various chemical synthesis reactions. As a result, they can be present in certain raw materials (such as some peptides) as technically unavoidable process impurities.

The toxicity of certain PFAS, and above all their extreme persistence in the environment and their bioaccumulation, has led lawmakers to consider restricting their use. Cosmetic products are not regarded as a major route of exposure to PFAS (the main routes being food and water). However, because cosmetics are seen as less essential than other sectors, they are on track to be among the first industries to face an outright ban on PFAS use, with no exemptions — whether under the European REACH restriction proposal or under French law.

At the European level, certain PFAS have already been regulated since the 2000s, but in 2023 ECHA proposed a general restriction on PFAS, which is now in the final stage of its scientific evaluation. It aims to progressively ban the manufacture, marketing, and use of PFAS, except for uses deemed essential and difficult to substitute. The ban is expected to take effect 18 months after the text is published.

The thresholds under consideration are as follows:

• ≤ 25 ppb for each individual PFAS (excluding polymers);
• ≤ 250 ppb for the sum of PFAS (excluding polymers);
• ≤ 50 ppm of total fluorine in an article (including polymeric PFAS).

As a reminder, other cross-cutting European regulations have already addressed PFAS, including those covering water quality, food, and packaging.

French law (Law No. 2025-188, February 2025), which came into force on January 1, 2026, has gotten ahead of the curve: it is now prohibited to manufacture, export, import, or place on the market/make available cosmetic products containing PFAS, whether their presence is intentional or not. The thresholds set match those in the proposed REACH restriction.

Clarifications are still awaited from regulatory authorities regarding testing methods, as no official method has yet been confirmed (the REACH restriction proposal references recommended test methods). One European scientific committee has acknowledged that the 25 ppb threshold may not be achievable for certain PFAS with current analytical methods.

As is often the case, cosmetic products prove to be diverse and complex matrices to analyze. While methods exist for water, there are currently no harmonized analytical methods for detecting PFAS in cosmetic products. Protocols therefore need to be adapted based on risk and matrix type.

Broad-spectrum approaches assess total or adsorbable organic fluorine content, or look for PFAS fragments (CF3 or CF2 fragments). These do not allow individual compounds to be identified, and are sometimes not even specific to PFAS (fluorine). They remain in the ppm range. Targeted approaches include quantification of oxidation products (Total Oxidizable Precursor assay), targeted quantification (with the compounds sought ranging from 20 to more than 600 PFAS), and the detection and quantification of TFA. These operate in the ppb range. For now, the best testing strategy remains a combination of targeted and broad-spectrum approaches.

TFA (trifluoroacetic acid) is a genuine challenge. Even when not added as such, it can result from the breakdown of certain PFAS. More importantly, it can be a manufacturing process impurity, for example in the synthesis of certain peptides. It is not always possible to detect in a finished product, as this very small molecule can become trapped by other ingredients such as waxes, oils, or polymers. It is therefore essential to carry out proper checks with suppliers and/or to test raw materials directly.

While France has taken the lead, Europe is expected to follow suit before long: PFAS are now persona non grata in cosmetic products, whether added intentionally or not. A genuine control strategy covering the entire production chain — from raw materials to finished product, including water — must therefore be put in place to ensure ongoing compliance. Not to mention the work still needed on substituting the compounds in question, which is not necessarily straightforward.