PFAS are becoming one of the most closely monitored substance groups in the cosmetics industry.
While no broad federal ban currently applies to PFAS intentionally added to cosmetics in the United States, several states are already introducing significant restrictions.
For cosmetic brands, this creates a complex regulatory landscape where state-level requirements may become more important than federal cosmetic rules.
What are PFAS?
PFAS (Per- and Polyfluoroalkyl Substances) are a large group of synthetic chemicals used for their water-resistant, long-lasting, and film-forming properties.
In cosmetics, PFAS may be found in products such as:
- Foundations
- Mascaras
- Long-wear makeup
- Primers
- Waterproof products
Certain PFAS have raised concerns due to their persistence in the environment and potential health impacts.
Federal FDA approach: still limited
At the federal level, the FDA has not introduced a general ban on PFAS in cosmetics.
In December 2025, the FDA published its “Report on the Use of PFAS in Cosmetic Products and Associated Risks.”
The agency concluded that:
- Available data remain insufficient to fully determine the safety of PFAS in cosmetics
- No federal prohibition currently applies to intentionally added PFAS
However, the FDA also indicated that enforcement action could be taken if safety concerns emerge.
State laws are moving faster
While federal regulation remains limited, several US states have already adopted stricter measures.
California
California continues expanding ingredient restrictions through state legislation, including substances considered harmful to health or the environment.
Washington State
Washington’s Toxic-Free Cosmetics Act restricts intentionally added PFAS in cosmetics sold within the state.
Other states
Additional states are considering or developing PFAS-related legislation, contributing to an increasingly fragmented regulatory landscape.
Why this matters for cosmetic companies
For brands and manufacturers, the main challenge is operational.
A product may technically remain compliant at the federal level while becoming non-compliant in certain states.
This creates several risks:
- Portfolio inconsistencies
- Distribution limitations
- Reformulation costs
- Supply chain complexity
- Increased regulatory monitoring needs
Companies using a single US formulation strategy may face growing difficulties.
PFAS identification is not always straightforward
Another major challenge lies in ingredient identification.
PFAS can appear under various chemical names or as part of raw material compositions, making detection and verification difficult.
Companies increasingly need:
- Detailed supplier documentation
- Stronger raw material traceability
- Internal ingredient screening processes
A broader regulatory trend
PFAS illustrate a larger shift in the US cosmetic market.
State-level regulations are becoming increasingly influential, particularly for ingredients associated with:
- Environmental concerns
- Persistence and bioaccumulation
- Endocrine disruption
- Consumer safety perception
For many companies, monitoring state legislation is now becoming as important as monitoring federal FDA updates.
What companies should do now
To reduce future compliance risks, companies should consider:
- Identifying PFAS-related substances in formulations
- Reviewing supplier documentation carefully
- Monitoring state-level legislation continuously
- Anticipating potential reformulation needs
- Structuring ingredient data more efficiently
Early assessment is becoming a competitive advantage.
Key takeaway
PFAS regulation in cosmetics is no longer only a federal question in the United States.
State laws are increasingly shaping market expectations and compliance strategies.
For cosmetic companies, proactive monitoring and ingredient transparency are becoming essential to maintain long-term compliance.
Going further
If you need support reviewing ingredient restrictions or assessing PFAS-related risks across markets, our regulatory team can assist you.
👉 Contact us | 👉 Subscribe to the newsletter
PFAS are becoming one of the most closely monitored substance groups in the cosmetics industry.
While no broad federal ban currently applies to PFAS intentionally added to cosmetics in the United States, several states are already introducing significant restrictions.
For cosmetic brands, this creates a complex regulatory landscape where state-level requirements may become more important than federal cosmetic rules.
What are PFAS?
PFAS (Per- and Polyfluoroalkyl Substances) are a large group of synthetic chemicals used for their water-resistant, long-lasting, and film-forming properties.
In cosmetics, PFAS may be found in products such as:
- Foundations
- Mascaras
- Long-wear makeup
- Primers
- Waterproof products
Certain PFAS have raised concerns due to their persistence in the environment and potential health impacts.
Federal FDA approach: still limited
At the federal level, the FDA has not introduced a general ban on PFAS in cosmetics.
In December 2025, the FDA published its “Report on the Use of PFAS in Cosmetic Products and Associated Risks.”
The agency concluded that:
- Available data remain insufficient to fully determine the safety of PFAS in cosmetics
- No federal prohibition currently applies to intentionally added PFAS
However, the FDA also indicated that enforcement action could be taken if safety concerns emerge.
State laws are moving faster
While federal regulation remains limited, several US states have already adopted stricter measures.
California
California continues expanding ingredient restrictions through state legislation, including substances considered harmful to health or the environment.
Washington State
Washington’s Toxic-Free Cosmetics Act restricts intentionally added PFAS in cosmetics sold within the state.
Other states
Additional states are considering or developing PFAS-related legislation, contributing to an increasingly fragmented regulatory landscape.
Why this matters for cosmetic companies
For brands and manufacturers, the main challenge is operational.
A product may technically remain compliant at the federal level while becoming non-compliant in certain states.
This creates several risks:
- Portfolio inconsistencies
- Distribution limitations
- Reformulation costs
- Supply chain complexity
- Increased regulatory monitoring needs
Companies using a single US formulation strategy may face growing difficulties.
PFAS identification is not always straightforward
Another major challenge lies in ingredient identification.
PFAS can appear under various chemical names or as part of raw material compositions, making detection and verification difficult.
Companies increasingly need:
- Detailed supplier documentation
- Stronger raw material traceability
- Internal ingredient screening processes
A broader regulatory trend
PFAS illustrate a larger shift in the US cosmetic market.
State-level regulations are becoming increasingly influential, particularly for ingredients associated with:
- Environmental concerns
- Persistence and bioaccumulation
- Endocrine disruption
- Consumer safety perception
For many companies, monitoring state legislation is now becoming as important as monitoring federal FDA updates.
What companies should do now
To reduce future compliance risks, companies should consider:
- Identifying PFAS-related substances in formulations
- Reviewing supplier documentation carefully
- Monitoring state-level legislation continuously
- Anticipating potential reformulation needs
- Structuring ingredient data more efficiently
Early assessment is becoming a competitive advantage.
Key takeaway
PFAS regulation in cosmetics is no longer only a federal question in the United States.
State laws are increasingly shaping market expectations and compliance strategies.
For cosmetic companies, proactive monitoring and ingredient transparency are becoming essential to maintain long-term compliance.
Going further
If you need support reviewing ingredient restrictions or assessing PFAS-related risks across markets, our regulatory team can assist you.
👉 Contact us | 👉 Subscribe to the newsletter
