In 2021, researchers at the University of Notre Dame screened 231 cosmetic products purchased from US retailers — drugstore brands and prestige brands alike. They found high-fluorine indicators consistent with PFAS contamination in 56% of foundations, 48% of lip products, and 63% of mascaras. And 88% of those products didn’t list a single PFAS-related ingredient anywhere on the label.
That gap between what’s in your makeup bag and what’s disclosed on the packaging? That’s exactly what regulators and consumer advocates have spent the last four years trying to close — with only partial success.
What PFAS Are (And Why “Forever Chemical” Is Actually Accurate)
PFAS — per- and polyfluoroalkyl substances — is an umbrella term for a group of more than 12,000 synthetic chemical compounds. What they all share is a carbon-fluorine bond, one of the strongest bonds in organic chemistry. That structural stability is what earns them the “forever chemical” label: they resist breaking down in the environment, in water, in soil, and inside the human body.
Most people first encounter PFAS through non-stick cookware. Teflon is a PFAS compound — polytetrafluoroethylene, or PTFE — and it’s been commercially produced since the 1940s. But PFAS also appear in food packaging, firefighting foam, performance clothing, industrial coatings, and — far less famously — your daily beauty routine.
They’re not in cosmetics because someone made a careless mistake. They’re there because they work. PFAS provide water resistance and staying power in waterproof mascaras and eyeliners. They give foundations a silky, spreadable feel and help pigments bond to skin. In long-wear lip products, they prevent feathering and fading. From a formulation standpoint, they genuinely perform. And until very recently, using them in cosmetics was completely legal in the US with zero disclosure requirements.
Why the Regulatory Gap Existed for So Long
The FDA’s authority over cosmetic products was governed, until 2022, by a law from 1938. That’s not a typo — the Federal Food, Drug, and Cosmetic Act gave the FDA remarkably limited tools to regulate personal care products, and PFAS weren’t even invented when that law was written.
Congress passed the Modernization of Cosmetics Regulation Act (MoCRA) in December 2022, which significantly expanded FDA’s oversight of cosmetics for the first time in 84 years. MoCRA requires facilities to register with the FDA, mandates adverse event reporting, and gives the FDA authority to order recalls. But it doesn’t specifically ban PFAS. That work has fallen, unevenly, to individual states.
California moved first. Under AB 2771, intentionally added PFAS in cosmetics became illegal to sell in the state beginning January 1, 2025. Maryland, Minnesota, Colorado, Hawaii, Vermont, and several others followed with similar legislation. As of mid-2026, at least 12 states have enacted some form of restriction.
But there’s a critical qualifier buried in all of these laws: intentionally added. PFAS can also appear in finished products as contaminants — residue from manufacturing processes, carry-over from raw material supply chains, or breakdown products of other compounds. Those incidental traces typically aren’t covered by the bans. It’s a meaningful loophole, and it’s one the laws haven’t fully addressed.
What Independent Testing Actually Found
The Notre Dame study, published in Environmental Science & Technology Letters, used particle-induced gamma-ray emission (PIGE) spectroscopy to detect total fluorine across all 231 products. High total fluorine is a reliable proxy for PFAS presence. The breakdown by product category is worth sitting with:
- 82% of waterproof mascaras showed high fluorine levels
- 63% of foundations
- 62% of eye products broadly
- 55% of lip products
When researchers sent a subset of the highest-fluorine products for more detailed chemical analysis, they confirmed specific PFAS compounds — including PTFE and several perfluoroalkyl carboxylic acids. And again: 88% of those products carried no PFAS-related ingredient on their label.
That last number is the one that should change how you think about label-reading. Scanning an ingredient list for suspicious entries is a reasonable starting point, but it’s not a reliable screen. Independent testing that uses total-fluorine detection is the only method that captures both intentionally added and incidentally present PFAS.
How to Spot PFAS on an Ingredient Label — When They’re Listed at All
When PFAS compounds are disclosed, they appear in INCI (International Nomenclature of Cosmetic Ingredients) language. The names aren’t always intuitive. Here’s what to look for:
- PTFE — polytetrafluoroethylene, used as a skin-smoothing “slip” agent in foundations and powders
- Perfluorodecalin — marketed in some products as an “oxygen-boosting” ingredient
- Polyperfluoromethylisopropyl ether — found in some spray-format products
- Any ingredient containing the prefix “fluoro-” or “perfluoro-”
If you want a faster search approach, the Environmental Working Group’s Skin Deep database and the Campaign for Safe Cosmetics product portal both flag known PFAS-containing ingredients. Neither database is perfectly comprehensive — they rely on disclosed formulations — but they’re useful first stops.
The honest caveat: given the Notre Dame findings, label-checking alone catches maybe 12% of the problem. It’s still worth doing. Just don’t mistake it for a complete safety screen.
The Health Concern the Research Hasn’t Resolved Yet
The EPA classifies certain PFAS compounds as likely carcinogenic to humans. Specific associations in epidemiological research include thyroid disruption, immune suppression, altered reproductive hormone levels, and elevated risk of kidney and testicular cancers — primarily at occupational or high-dose exposure levels. The picture at lower cosmetic-use exposures is less settled, though more studies are emerging.
What makes cosmetic exposure specifically worth paying attention to is route and frequency. Lip products are partially ingested. A 2015 analysis estimated that women who regularly wear lip cosmetics ingest roughly 87 milligrams of product per day — enough to be toxicologically relevant for cumulative PFAS exposure. Skin absorption is a secondary route, particularly for daily-use products like foundation applied over large surface areas for years.
One compound worth a specific mention: PFOA (perfluorooctanoic acid). It was voluntarily phased out of US manufacturing by 2015 under an EPA stewardship program. But “phased out of manufacturing” doesn’t mean it disappeared from product inventories overnight. If you have long-wear cosmetics that have been sitting in your bathroom cabinet since before 2016 or 2017, the formula may predate that phase-out. Worth checking.
What You Can Actually Do About It
The goal here isn’t to throw out your entire makeup collection — that’s neither practical nor proportionate to current evidence. Here’s a more realistic approach.
Prioritize by frequency and application area. Waterproof mascara you apply and remove daily is higher priority than an eyeshadow palette you use twice a month. Lip gloss you reapply throughout the day is higher priority than a contour product you dust on occasionally. Reformulate selectively, starting with what you use most.
Look for third-party verified PFAS-free claims. EWG Verified and Made Safe certifications both explicitly prohibit PFAS. A brand stating “PFAS-free” without independent verification is harder to trust — some are accurate, many aren’t. Certification is the difference between a marketing claim and a tested assertion.
Follow California compliance as a proxy. Products reformulated to meet California’s AB 2771 ban and sold through large national retailers (Sephora, Target, Ulta) typically apply those cleaner formulations across all markets, because producing separate state-specific versions is expensive. Niche brands and online-only sellers are less predictable.
Request testing data when it matters. According to testing data from Qalitex Laboratories, PFAS screening in cosmetic matrices typically uses EPA Method 533 or Method 537.1 adapted for solid-phase extraction — the same methodology applied to drinking water testing. Some advocacy organizations run periodic screening campaigns where consumers can submit product samples. It’s worth watching for those.
The Honest State of Things in 2026
Here’s the complicated truth: the regulatory environment is genuinely improving. State bans are accumulating. Brands are reformulating. Major retailers are using their purchasing power to push suppliers toward PFAS-free formulations. MoCRA, however modest, gives the FDA tools it didn’t have four years ago.
But the system still relies heavily on manufacturer self-reporting, and “intentionally added PFAS” bans don’t address the full contamination picture. The gap between what’s in products and what appears on labels hasn’t fully closed.
What you can do, right now, is stop treating a clean-looking ingredient list as proof of a clean product. Ask for third-party verification. Prioritize certified products where they’re available. And when brands make vague “clean beauty” claims without backing them up, treat that as a red flag rather than a green light.
The fact that 88% of PFAS-positive products in an independent study listed nothing on their label isn’t evidence that the brands were hiding something in bad faith. Many probably didn’t know. But not knowing what’s in your own formulation — and therefore not being able to tell your customers — is its own kind of problem.
Written by Nour Abochama, Host & Quality Control Expert, Nourify & Beautify. Learn more about our team
Have questions about product safety? Talk to our experts. Contact us
Related from our network
- How Cosmetic Safety Testing Actually Works, Start to Finish — Qalitex Laboratories breaks down the analytical methods behind PFAS screening, heavy metal testing, and finished-product safety assessments.
- Raw Material Supplier Qualification: Why Your Cosmetic Formula Is Only as Safe as Its Inputs — Ayah Labs explains how PFAS and other contaminants enter cosmetic supply chains at the raw ingredient stage — and how rigorous supplier testing catches them before formulation.
