The beauty industry has long been a proving ground for scientific innovation. But lately, it has also become a focal point for regulatory scrutiny—particularly when it comes to per- and polyfluoroalkyl substances (PFAS), the class of chemicals often referred to as “forever chemicals.”
PFAS have drawn increasing attention from regulators, lawmakers, and consumer advocates due to their persistence in the environment and potential links to human health concerns. While historically used in a wide range of consumer products, including cosmetics, their presence has become a growing point of debate across federal agencies and state legislatures alike.
Against this backdrop, the U.S. Food and Drug Administration (FDA) recently released its “Report on the Use of PFAS in Cosmetic Products and Associated Risks.” The report—mandated by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA)—offers the most comprehensive federal assessment to date of how PFAS are used in cosmetic products sold in the United States.
Although the report stops short of concluding that PFAS in cosmetics pose a clear safety risk, it highlights significant gaps in available scientific data, raising questions about how regulators, lawmakers, and industry stakeholders will address PFAS moving forward. The report also underscores how MoCRA is already reshaping the regulatory framework for cosmetics in the United States—potentially ushering in a new era of oversight for an industry historically subject to relatively limited federal regulation.
Understanding PFAS and Their Role in Cosmetics
PFAS are a large family of synthetic chemicals prized for their unique chemical stability and resistance to oil, water, and heat. These properties make them useful in a wide variety of applications, from industrial coatings and textiles to food packaging and consumer products.
In cosmetics, PFAS may be used to improve texture, durability, and wear performance. Certain PFAS ingredients can help products spread more smoothly across the skin, resist moisture, or maintain a longer-lasting finish.
Common PFAS ingredients reported in cosmetic formulations include:
- Polytetrafluoroethylene (PTFE)
- Perfluorononyl dimethicone
- Perfluorohexylethyl triethoxysilane
- Methyl perfluorobutyl ether
These ingredients appear most frequently in products such as eye shadow, foundation, eyeliner, and face powders—categories where long wear and smooth application are particularly desirable.
Yet PFAS share a defining characteristic that has sparked concern: they do not easily break down in the environment. Their persistence has led researchers and regulators to examine whether long-term exposure—across multiple products and environmental pathways—could present risks to human health.
What the FDA’s PFAS Cosmetics Report Revealed
The FDA’s report relies heavily on product listing data submitted under MoCRA, which now requires cosmetic manufacturers to register facilities and list products with the agency.
Using this information, the FDA identified 51 PFAS ingredients appearing in approximately 1,700 cosmetic product formulations, representing roughly 0.4 percent of cosmetic products currently listed with the agency.
The agency focused its scientific assessment on the 25 most frequently used PFAS ingredients, which together account for the vast majority of intentional PFAS use in cosmetics.
What regulators ultimately found was less a clear answer than a substantial scientific gap.
Insufficient Data for Safety Determinations
For most PFAS evaluated, the FDA concluded that available data were insufficient to determine safety under typical cosmetic use conditions.
Among the 25 PFAS ingredients examined:
- Nineteen lacked sufficient safety data for meaningful evaluation.
- Five appeared unlikely to pose safety concerns based on the limited data available.
- One ingredient raised a potential concern at the highest reported concentration in a body lotion formulation.
The report also identified major limitations in existing research, including a lack of:
- Dermal absorption studies
- Chronic exposure data
- Toxicological studies specific to cosmetic use
- Reliable data on concentration levels in finished products
Because cosmetics are primarily applied to the skin, understanding dermal exposure is particularly critical, yet this remains one of the least studied areas in PFAS toxicology.
MoCRA’s Expanding Influence on Cosmetic Regulation
The PFAS report itself is a direct product of the Modernization of Cosmetics Regulation Act of 2022, which represents the most significant expansion of FDA authority over cosmetics since the 1930s.
Historically, the FDA’s oversight of cosmetics has been comparatively limited. Unlike drugs or medical devices, cosmetic products generally do not require premarket approval. Instead, manufacturers have largely been responsible for ensuring the safety of their products.
MoCRA began to change that landscape in several important ways.
Product Listing and Ingredient Transparency
For the first time, cosmetic manufacturers must now submit product listings and ingredient information to the FDA. This requirement provided the dataset that allowed the agency to conduct the PFAS analysis in the first place.
Cosmetic manufacturing facilities must also register with the FDA, improving traceability across the supply chain and enabling more robust regulatory oversight.
Safety Substantiation
Companies are now required to maintain adequate safety substantiation for cosmetic products, meaning manufacturers must possess reliable scientific evidence supporting the safety of their ingredients and formulations.
Mandatory Adverse Event Reporting
MoCRA also introduced mandatory reporting of serious adverse events, giving regulators greater visibility into potential safety concerns.
Collectively, these provisions provide regulators with a far clearer picture of the cosmetics market than existed previously—and create a regulatory infrastructure that could support more active oversight of ingredients like PFAS.
The Challenge of State-by-State Regulation
While federal regulation continues to evolve, cosmetic companies are simultaneously navigating a growing number of state-level restrictions on PFAS.
Several states—including California, Colorado, Maine, Minnesota, Oregon, Vermont, and Washington—have enacted or proposed laws restricting intentionally added PFAS in cosmetics.
Although the details vary, many of these laws impose bans beginning between 2025 and 2028.
For companies distributing products nationwide, this creates a difficult compliance environment.
Differing Definitions of PFAS
States often rely on different scientific definitions of PFAS, some covering thousands of chemicals while others focus on narrower subcategories.
National Distribution Complications
A product permitted under federal law may be prohibited in certain states, requiring companies to reformulate products or manage separate distribution channels.
Supply Chain Uncertainty
PFAS can also appear unintentionally as contaminants or manufacturing byproducts, complicating efforts to verify compliance.
The result is a regulatory patchwork that many industry stakeholders hope Congress may eventually address through federal legislation.
Potential Congressional and Regulatory Paths Forward
Although the FDA’s report did not propose immediate restrictions, it may serve as a foundation for future policy discussions.
Members of Congress have already introduced legislation—including proposals to ban intentionally added PFAS in cosmetics nationwide—in an effort to create uniform regulatory standards.
Federal agencies may also expand research efforts to address the scientific gaps identified in the report. Greater collaboration between the FDA, environmental regulators, and public health agencies could help clarify potential exposure pathways and long-term health effects.
At the same time, many cosmetic companies are proactively reformulating products to remove PFAS ingredients altogether, driven by consumer demand, retailer policies, and the desire to reduce regulatory risk.
A Regulatory Landscape Still Taking Shape
The FDA’s PFAS cosmetics report ultimately reflects a familiar theme in modern chemical regulation: the science is still evolving, while policy continues to develop in parallel.
What the report makes clear is that PFAS will remain a central focus for regulators, lawmakers, and industry stakeholders in the years ahead. Between the transparency requirements introduced by MoCRA, the emergence of state-level restrictions, and the possibility of future federal legislation, cosmetic companies are operating in a regulatory environment that is far more dynamic than it was just a few years ago.
For companies navigating this landscape, careful attention to ingredient sourcing, safety substantiation, regulatory monitoring, and supply chain transparency will be increasingly important as policymakers continue to grapple with the complex challenges posed by PFAS and other persistent chemicals.
