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:
- Waterproof mascaras stay locked in place under high humidity.
- Long-wear foundations resist natural facial sebum and oil breakthrough.
- Mineral and chemical sunscreens spread with uniform, hydrophobic film formation.
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 |
|---|---|---|---|
| California | AB 2771 | January 1, 2025 | In Effect |
| Colorado | HB 22-1345 | January 1, 2025 | In Effect |
| Maryland | HB 643 | January 1, 2025 | In Effect |
| Minnesota | HF 2310 (Amara's Law) | January 1, 2025 | In Effect |
| Washington | HB 1047 | January 1, 2025 | In Effect |
| Maine | LD 1537 | January 1, 2026 | In Effect |
| Vermont | S.25 / Act 131 | January 1, 2026 | In Effect |
| Connecticut | Public Act 24-59 | July 1, 2026 | In Effect |
| Oregon | SB 546 | January 1, 2027 | Upcoming |
| New Jersey | S1042 | January 12, 2028 | Enacted |
| New Mexico | HB 212 | 2028 | Enacted |
| Illinois | HB 2516 | 2032 | Enacted |
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:
- Intentional Use: Ingredients deliberately included to provide film formation, lubricity, oil resistance, or water repellency (e.g., PTFE powders, fluorinated polymers). These are strictly banned.
- Incidental Contamination: Trace residues introduced through non-stick manufacturing equipment, raw material processing aids, or fluorinated packaging leaching. While not classified as intentional additions, individual state departments of environmental protection are formulating guidance on testing thresholds.
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:
- Waterproof eye makeup (liquid eyeliners and mascaras).
- Transfer-resistant, matte-finish foundations.
- 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:
- Review INCI Lists for Camouflaged PFAS: Fluorinated compounds often disguise themselves behind complex polymer terminology such as polytetrafluoroethylene (PTFE), perfluorooctyl triethoxysilane, or fluorinated acrylate copolymers.
- Screen Drop-in Replacements: High-performance natural and synthetic wax matrices, alkyl silicones, and clean film-formers (such as pullulan, hydrogenated rosinates, or polyhydroxystearic acid) can achieve comparable film uniformity and slip.
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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