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PFAS, also known as per- and polyfluoroalkyl substances, are becoming one of the most heavily scrutinized chemical groups in the global cosmetic industry.
Historically used in a great variety of products to enhance high-performance formulations, PFAS are now facing growing regulatory pressure due to concerns related to environmental persistence, bioaccumulation, and potential health risks.
Between 2025 and 2027, cosmetic brands may face:
- Product bans
- Reformulation pressure
- Supplier documentation requests
- Reporting obligations
- Increased scrutiny of fluorinated ingredients and impurities
This article explains how PFAS cosmetic regulation is evolving across Europe, the United States, Canada, and the United Kingdom, including the key deadlines and compliance risks cosmetic companies should monitor.
What are PFAS in cosmetics?
PFAS are a broad group of fluorinated chemicals used across multiple industries due to their resistance to water, oil, heat, and degradation.
In cosmetics, PFAS have historically been used to improve:
- Water resistance
- Long-lasting performance
- Product adhesion
- Texture and smoothness
- Film-forming properties
These substances have often been associated with products such as waterproof mascaras, long-wear foundations, transfer-resistant lipsticks, primers, eyeliners, sunscreens, and some hair styling products.
PFAS may appear intentionally added in cosmetic formulations or unintentionally through impurities, contaminated raw materials, manufacturing equipment, or packaging components.
Some fluorinated compounds may be identified through INCI names containing terms such as:
- PTFE
- Perfluoro-
- Polyperfluoro-
- Fluoro-
- C9-15 Fluoroalcohol Phosphate
However, identifying PFAS is not always straightforward, particularly when trace contamination or indirect supply chain sources are involved.
Why PFAS are becoming a major regulatory issue
PFAS are often referred to as “forever chemicals” because many of these substances degrade extremely slowly in the environment.
Growing scientific and regulatory concern is linked to:
- Environmental persistence
- Bioaccumulation potential
- Water contamination
- Human exposure concerns
- Increasing toxicological scrutiny
At the same time, analytical testing capabilities continue improving, allowing regulators and laboratories to detect fluorinated substances at increasingly low levels.
PFAS scrutiny is also expanding far beyond cosmetics. Environmental agencies, public health authorities, consumer organisations, and litigation trends are increasing pressure on manufacturers across multiple sectors.
As a result, cosmetic companies are facing growing expectations to evaluate not only intentionally added PFAS, but also potential contamination risks originating from raw materials manufacturing processes, packaging, or supply chains.
Europe: increasing pressure toward PFAS restrictions
The European Union is moving toward one of the most ambitious PFAS regulatory frameworks globally. Although cosmetics are not yet fully banned at the EU level, PFAS remain under continuous review through REACH restriction proposals coordinated by ECHA.
The ongoing discussions aim to progressively restrict PFAS use across multiple industries, including cosmetics, particularly where safer alternatives may exist.
Even before a final EU-wide restriction enters into force, many cosmetic companies are already:
- Reformulating products
- Requesting PFAS-free supplier declarations
- Reviewing waterproof and long-lasting formulations
- Increasing analytical testing
- Strengthening supply chain documentation
France became the first major European country to adopt a direct PFAS cosmetic ban.
From January 1, 2026, cosmetics containing PFAS can no longer be manufactured, imported, exported, or placed on the French market.
Existing stock manufactured before that date may still be sold off until 1 January 2027, after which any remaining PFAS-containing cosmetic stock must be withdrawn and destroyed as hazardous waste.
This development may significantly influence the wider European cosmetic market, as many brands prefer maintaining a single formulation strategy across Europe instead of managing country-specific products.
USA: state-level PFAS cosmetic restrictions are expanding
The United States currently does not have a single federal PFAS cosmetic ban under FDA cosmetic legislation.
However, state-level PFAS regulation is evolving rapidly.
Several U.S. states are introducing:
- Restrictions on intentionally added PFAS
- Reporting obligations
- Ingredient disclosure requirements
- Product bans for specific applications
States increasing PFAS scrutiny include California, Maine, Minnesota, and Washington. This creates a fragmented regulatory environment where products may comply federally while still failing to comply at state level.
PFAS scrutiny in the United States extends far beyond cosmetics alone. Environmental investigations, litigation trends, and growing political pressure continue increasing expectations for manufacturers to demonstrate stronger control over fluorinated substances and potential contamination sources.
Brands selling waterproof mascaras, transfer-resistant makeup, long-wear foundations, or high-performance cosmetic products should pay particular attention to evolving state legislation.
Canada: growing PFAS regulatory attention
Canada is also increasing scrutiny of PFAS through broader environmental and chemical management initiatives.
Although Canada has not yet introduced a direct cosmetic PFAS ban comparable to France’s, Health Canada and environmental authorities continue to expand assessment, monitoring, and risk evaluation activities regarding fluorinated substances.
Canada’s broader chemicals management strategy suggests that PFAS restrictions may continue to strengthen over the coming years, particularly as international alignment and scientific pressure increase.
Cosmetic brands exporting internationally should avoid assuming that Canada will remain less restrictive long-term.
UK: PFAS scrutiny is increasing after Brexit
The United Kingdom continues evaluating PFAS through UK REACH and broader environmental policy frameworks.
Although the UK has not yet introduced a specific PFAS cosmetic ban equivalent to France, scientific bodies and environmental authorities continue pushing for stronger controls on fluorinated substances.
One important challenge for cosmetic brands is the growing possibility of regulatory divergence between:
- EU PFAS requirements
- Great Britain regulations
- Northern Ireland alignment with EU rules under the Windsor Framework
Over time, this may create different compliance obligations depending on where products are sold within Europe.
For companies operating across both EU and UK markets, monitoring regulatory divergence will become increasingly important for formulation strategy and supply chain management.
Timeline: key PFAS cosmetic regulatory dates
The regulatory landscape is evolving rapidly across multiple jurisdictions. These are some of the key PFAS cosmetic regulatory milestones cosmetic brands should monitor between 2025 and 2027.
2023: EU REACH PFAS Restriction Proposal Published
2025: Expansion of U.S. state-level PFAS cosmetic restrictions and reporting obligations
January 1, 2026: France’s PFAS cosmetic ban applies
2026: Continued EU PFAS restriction discussions under REACH
2026: New Zealand begins introducing PFAS cosmetic restrictions
January 1, 2027: Deadline to sell off existing French PFAS-cosmetic stock manufactured before the ban; remaining stock must be withdrawn and destroyed.
2027 and Beyond: Potential wider harmonised PFAS restrictions across additional jurisdictions
How cosmetic brands should prepare
Cosmetic brands should already begin evaluating the potential impact of PFAS restrictions across their portfolios.
Preparation may include the review of raw materials and formulations and starting to request supplier declarations. Strengthening supply chain traceability is the best option to start the screening for fluorinated compounds, as it is the first step for the evaluation of contamination and impurity risks.
If your products are placed in the US, monitoring state-level U.S. legislation is a must, and if your strategy involves different regions, prepare reformulation strategies, prioritising high-risk waterproof and long-lasting products.
Many companies underestimate how difficult PFAS traceability can become when contamination originates from indirect sources rather than intentional formulation choices.
Early preparation may help reduce reformulation pressure, supply chain disruptions, and future market limitations.
How cosmetic brands should prepare
Cosmeservice helps cosmetic brands evaluate PFAS-related regulatory risks across international markets, supporting companies with formulation reviews, supplier documentation assessment, regulatory screening, and market-specific compliance strategies.
Our regulatory support covers:
- EU cosmetic regulation
- UK cosmetic compliance
- USA regulatory requirements
- Canadian cosmetic obligations
- Ingredient and formulation reviews
- PFAS compliance screening
- Regulatory risk assessment
- Supplier documentation review
As PFAS regulation continues evolving globally, early preparation can significantly reduce compliance risks and support smoother international market access.
For tailored support, complete our contact form or contact us at info@cosmeservice.com
FAQs
What are PFAS in cosmetics?
PFAS are fluorinated chemicals sometimes used in cosmetics to improve water resistance, long-lasting performance, texture, and film-forming properties. They have historically been associated with waterproof makeup, transfer-resistant products, and certain skin care formulations.
Why are PFAS called “forever chemicals”?
PFAS are often referred to as “forever chemicals” because many degrade extremely slowly in the environment, leading to concerns regarding environmental accumulation, water contamination, and long-term exposure.
Which cosmetic products may contain PFAS?
PFAS have historically been associated with waterproof mascaras, long-wear foundations, transfer-resistant lipsticks, primers, eyeliners, certain sunscreens, and some hair styling products. However, PFAS may also appear unintentionally through impurities or contaminated raw materials.
How can cosmetic brands identify PFAS ingredients?
Some PFAS-related substances may appear in the INCI list through terms such as PTFE, Perfluoro-, Polyperfluoro-, or Fluoro-. However, identifying PFAS is not always simple because trace contamination and indirect fluorinated materials may also contribute to PFAS presence. Supplier documentation and analytical assessments are often necessary.
Are PFAS banned in cosmetics in Europe?
PFAS are not yet fully banned across the European Union as a group. However, France introduced a national PFAS cosmetic ban effective January 1, 2026, while broader EU restrictions continue being discussed under REACH.
Which U.S. states are restricting PFAS in cosmetics?
Several states are increasing PFAS cosmetic restrictions or reporting obligations, including California, Maine, Minnesota, and Washington. Requirements may differ significantly depending on the jurisdiction.
Can PFAS appear as impurities in cosmetics?
Yes. PFAS may sometimes appear unintentionally through contaminated raw materials, manufacturing equipment, processing aids, or packaging components. This is becoming an increasingly important regulatory concern.
Will PFAS restrictions affect waterproof makeup?
Potentially yes. Waterproof and long-lasting cosmetic products are among the categories most frequently associated with historical PFAS use due to their performance characteristics.
Is the UK following EU PFAS restrictions?
Not automatically. Since Brexit, Great Britain follows its own UK REACH framework, while Northern Ireland continues aligning with certain EU rules under the Windsor Framework. This may lead to regulatory divergence over time.
How should cosmetic brands prepare for PFAS regulation?
Brands should begin reviewing formulations, supplier documentation, contamination risks, and future reformulation needs as early as possible. Monitoring international PFAS regulatory developments is becoming increasingly important for companies operating globally.
