REGULATORY COMPLIANCE

PFAS in Cosmetics: What Formulators Need to Know in 2026

You have probably heard the term "forever chemicals." PFAS (per- and polyfluoroalkyl substances) earned that nickname because their chemistry resists natural breakdown in both the environment and biological tissue.

Though not a major ingredient in cosmetics, they have quietly made inroads in several formulations. They can be found in products that require efficacy in water resistance, spreadability and texture such as waterproof mascaras, long-wear foundations, sunscreens, lip products, and shaving creams.

Critical Takeaway

Fourteen US states have enacted strict prohibitions against intentionally added PFAS in cosmetics. For national and international brands, this patchwork functions as a de facto national ban.

What are PFAS and why are they in cosmetics?

PFAS is not an isolated ingredient—it represents a class of more than 4,700 synthetic organofluorine compounds. Every compound in this category contains carbon-fluorine bonds, one of the strongest single bonds in organic chemistry.

That extraordinary stability is precisely why formulators adopted them:

However, the very property that creates functional industrial durability also causes biological persistence. Extensive toxicological research links exposure to certain PFAS compounds with elevated cancer risks, liver damage, endocrine disruption, thyroid dysfunction, and reproductive harm. Global regulatory authorities have accelerated formal phase-outs.

Where PFAS in cosmetics are now banned

At the federal level, the United States has not yet codified a uniform ban across all cosmetics, although the FDA published a comprehensive safety evaluation under the Modernization of Cosmetics Regulation Act (MoCRA) in December 2025.

State legislatures moved rapidly to fill that void. Currently, 14 states have passed statutory prohibitions on intentionally added PFAS in cosmetics with staggered effective timelines:

State Statute / Bill Effective Date Status
CaliforniaAB 2771January 1, 2025In Effect
ColoradoHB 22-1345January 1, 2025In Effect
MarylandHB 643January 1, 2025In Effect
MinnesotaHF 2310 (Amara's Law)January 1, 2025In Effect
WashingtonHB 1047January 1, 2025In Effect
MaineLD 1537January 1, 2026In Effect
VermontS.25 / Act 131January 1, 2026In Effect
ConnecticutPublic Act 24-59July 1, 2026In Effect
OregonSB 546January 1, 2027Upcoming
New JerseyS1042January 12, 2028Enacted
New MexicoHB 2122028Enacted
IllinoisHB 25162032Enacted

International Context: Both Health Canada and the European Chemicals Agency (ECHA) are progressing toward universal horizontal restrictions under REACH that will prohibit the manufacture, import, and sale of cosmetics containing perfluorinated compounds.

What counts as "intentionally added"?

Every enacted US statute centers on the legal definition of "intentionally added PFAS." This distinction is crucial:

Which product categories face the greatest risk?

The Washington Department of Health notes that foundations, moisturizers, cleansers, nail polish, blushes, deodorants, shaving creams, shampoos, and waterproof mascaras fall under these statutory frameworks. In real formulation practice, exposure is highest in:

  1. Waterproof eye makeup (liquid eyeliners and mascaras).
  2. Transfer-resistant, matte-finish foundations.
  3. Broad-spectrum, highly water-resistant sunscreens.

Formulator Action Plan: Where to Go from Here

If your brand distributes products nationally or internationally, maintain a single global compliance standard by removing PFAS across all batches:

Screen Your Ingredient Deck for State PFAS Bans

Smart Formulator cross-references your INCI deck and CAS numbers against all 14 US state restrictions, EU REACH lists, and 45+ global registries in real time.

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