Regulatory Trends and Compliance Strategies for PFAS in Cosmetics

Per- and polyfluoroalkyl substances (PFAS) are increasingly becoming a focal point of global concern due to their potential long-term impacts on the environment and human health. As a class of synthetic chemicals characterized by high stability and widespread applications, PFAS are facing increasingly stringent regulatory scrutiny in the cosmetics sector.

This article explores the physicochemical properties and potential health risks of PFAS, and systematically reviews the evolving global regulatory landscape related to their use in cosmetics. It aims to help cosmetic enterprises gain a comprehensive understanding of regulatory requirements, mitigate compliance risks, enhance product safety, and strengthen competitiveness in global markets.

Physicochemical Properties and Potential Health Risks of PFAS

PFAS are a class of highly stable synthetic organic compounds. Due to their exceptional thermal resistance, hydrophobic and lipophobic properties, and chemical inertness, they are widely used across various sectors, including industrial manufacturing, food packaging, and cosmetics. However, it is precisely these "virtually non-degradable" characteristics that enable PFAS to persist in the natural environment for extended periods. They can enter the food chain through air, water, and soil, and accumulate in the human body, potentially leading to a range of health risks such as endocrine disruption, immune system impairment, developmental toxicity, and certain types of cancer. For these reasons, PFAS are often referred to as “forever chemicals”.

Global Regulatory Landscape and Restriction Trends of PFAS in Cosmetics

In recent years, the environmental and health impacts of PFAS have drawn significant attention from regulatory authorities worldwide. Within the cosmetics sector, a growing number of countries and regions have introduced legislation aimed at restricting the use of PFAS in cosmetic products.

France: Ban on the Manufacture, Import, Export, and Sale of PFAS-containing Cosmetics Effective from January 1, 2026

On February 20, 2025, the French National Assembly officially passed the Act to Protect the Public from the Risks Associated with PFAS, which aims to mitigate the long-term environmental and public health risks posed by PFAS through stringent restrictions on their use in consumer products and industrial emissions. Under this legislation, France will implement a comprehensive ban on the manufacture, import, export, and sale of cosmetics containing PFAS, effective January 1, 2026.

United States: Nearly 70% of States Have Enacted Regulations on PFAS in Cosmetics

In the United States, approximately 70% of states have introduced regulatory measures concerning the use of PFAS in cosmetics. For example, California, as the first major jurisdiction to comprehensively ban all PFAS in cosmetics, passed relevant legislation in September 2022, with enforcement to begin on January 1, 2025. Minnesota and Colorado will prohibit the sale, offering for sale, or distribution of cosmetics containing intentionally added PFAS starting January 1, 2025. Maine has stipulated a ban on the sale of PFAS-containing cosmetics effective from 2026. Connecticut will prohibit the manufacture, sale, and distribution of cosmetics with intentionally added PFAS starting January 1, 2028. Washington State will ban the sale of cosmetics containing intentionally added PFAS, among eight restricted substances or substance classes, starting January 1, 2026.

New Zealand: Comprehensive Ban on the Import and Manufacture of PFAS-Containing Cosmetics Effective from December 31, 2026

The New Zealand Environmental Protection Authority (EPA) has announced that, effective from December 31, 2026, the import and manufacture of cosmetics containing PFAS will be prohibited. Beginning December 31, 2027, the sale or supply of such products within New Zealand will also be banned. By June 30, 2028, all PFAS-containing cosmetics must be fully disposed of.

China: Gradual Strengthening of PFAS-Related Regulations

Currently, China has not yet enacted dedicated or systematic legislation specifically targeting PFAS. However, through a series of policy documents, standards, and technical guidelines, China has been gradually strengthening the management of PFAS substances, reflecting a high level of concern for their environmental and health risks. To fulfill its international obligations under the Stockholm Convention on Persistent Organic Pollutants (POPs), the Ministry of Ecology and Environment (MEE) issued the Notice on Banning the Production, Circulation, Use, and Import/Export of Lindane and Other POPs in 2019. Effective from March 26, 2019, the notice imposed a comprehensive ban on the production, circulation, use, and import/export of perfluorooctane sulfonic acid (PFOS), its salts, and perfluorooctane sulfonyl fluoride, except for acceptable uses.

In the List of Priority Controlled New Pollutants (2023 Edition) published by the MEE, PFOS-related substances, PFOA-related substances, and PFHxS-related substances were explicitly included as key controlled pollutants. Their production, processing, and use are prohibited except for specific exempted purposes. Additionally, the List of Toxic Chemicals Strictly Restricted in China (2023) also classified PFOS and its salts and sulfonyl fluoride, as well as PFOA and its salts and related compounds, as strictly restricted chemicals, further reinforcing control over these core PFAS substances.

Safeguarding Future Health: Strictly Managing PFAS Risks

Due to their high chemical stability, hydrophobic and oleophobic properties, low surface tension, and excellent film-forming capabilities, PFAS are widely used across various industrial and consumer product sectors, including cosmetics. Currently, PFAS are commonly found in a variety of cosmetic products such as lotions, facial cleansers, nail polishes, shaving creams, foundations, lipsticks, eyeliners, eyeshadows, and mascaras. However, given their potential health risks, companies are encouraged to actively implement PFAS risk management strategies in response to tightening regulatory trends.

CIRS Testing is a wholly owned subsidiary of CIRS Group. Drawing on its nearly two decades of expertise in chemical risk assessment, along with its CNAS/CMA-accredited laboratories and global technical network, CIRS Testing is proud to introduce its PFAS-free Full-process Assessment Service, empowering companies to take the lead in compliance. CIRS Testing will guide you through every step – from precise testing and scientific evaluation to regulatory insights, compliance strategy, and final certification. This end-to-end service is designed to help your products overcome trade barriers and build lasting customer trust.

• Full Product Category Coverage: Our service supports PFAS testing across a wide range of product types, including food contact materials (e.g., packaging paper, and coated tableware), textiles (e.g., waterproof jackets, and outdoor gear), cosmetics (e.g., waterproof makeup), plastic products, and electronic device casings. This ensures precise alignment with PFAS regulatory requirements across diverse industries and application scenarios.
• High-Precision Testing: Equipped with a comprehensive suite of advanced international analytical instruments such as LC-MS/MS and GC-MS/MS, we offer detection limits as low as parts per billion (ppb). Our methods enable the accurate identification of a wide spectrum of high-risk PFAS substances, including PFOA, PFOS, PFHxS, PFNA, and PFBS, ensuring the scientific integrity and reliability of “non-detect” results.
• Customized Compliance Solutions: In response to major global regulatory frameworks-such as the EU’s REACH Annex XVII PFAS restrictions, the U.S. EPA’s PFAS Action Plan, China’s List of Priority Controlled New Pollutants, and Japan’s Chemical Substances Control Law (CSCL) – we provide an end-to-end service chain encompassing testing, regulatory interpretation, and risk assessment. This helps enterprises mitigate compliance risks arising from regulatory differences across regions.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.