FDA Finds "Significant Data Gaps" For PFAS Used In Cosmetic Products

As required under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), on December 29, 2025, the U.S. Food and Drug Administration (FDA) published a Report on the Use of PFAS in Cosmetic Products and Associated Risks. The scope of the report is limited to per- and polyfluoroalkyl substances (PFAS) intentionally added to cosmetic products as ingredients and does not include PFAS that may be present in the final product as contaminants. According to the report, "[c]ertain PFAS are intentionally added as ingredients to some cosmetic products, such as lipsticks, eyeshadows, moisturizers, nail polish and enamel, blushers and rouges, and cleansers." The report states that there are currently no federal regulations specifically addressing the use of PFAS in cosmetic products in the United States and that intentionally added PFAS are not currently prohibited in cosmetic products and do not, based on presence alone, render the cosmetic product adulterated or misbranded. FDA notes that "this position may be subject to change as new scientific evidence emerges."

FDA's analysis found that 51 PFAS are intentionally added to 1,744 cosmetic products sold in the United States as of August 31, 2024. According to FDA, these products represent 0.41 percent of the total products registered as of August 2024. Eye shadows, face and neck products (leave-on), eyeliners, face powders, and foundations were the top five product categories and constitute approximately 56 percent of PFAS-containing cosmetic products. FDA prioritized the 25 PFAS most often used for a safety review. FDA states that for 19 of the PFAS, it could not definitively determine the safety due to the lack of critical toxicological data. FDA concluded that five PFAS were considered to pose low safety concerns in cosmetic products under intended use conditions. FDA identified one PFAS as having a potential safety concern when used in body lotion at the highest use level (i.e., the concentration of an ingredient in a final product).

FDA notes that its assessment "is subject to significant uncertainties, including limited data on use level, lack of dermal and oral absorption data, and mechanistic information, as well as the absence of dermal toxicity data." As further data become available, FDA could refine its assessments to provide a more accurate evaluation of the safety and potential risks associated with their use in cosmetic products. FDA states that it "will continue to monitor emerging data on PFAS to ensure the continued safety of cosmetic products."

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