Intentionally Added PFAS in Cosmetics: What Manufacturers Need to Know

The FDA Has Been Paying Attention — And So Should You

Per- and polyfluoroalkyl substances aren't new to cosmetic formulations. But the regulatory environment around them is changing fast, and a specific category is now at the center of that shift: intentionally added PFAS — substances deliberately selected by manufacturers for the functional benefits they deliver, including water and oil resistance, durability, and texture enhancement.

These are not trace contaminants. They are ingredients. And that distinction is what makes them a compliance priority.

The FDA's recent review confirmed just how widely used they are: 51 PFAS were identified as intentionally added ingredients across 1,744 cosmetic and personal care formulations currently on the U.S. market.

What the FDA Found When It Looked Closer

Focusing on the 25 most prevalent PFAS ingredients, the FDA categorized them based on available toxicological evidence into three groups:

Lower Safety Concern — PTFE, Perfluorodecalin, HC Yellow No. 13, Perfluorohexane, and Tetrafluoropropene currently present relatively low risk under typical use conditions.

Potential Safety Concern — Perfluorohexylethyl Triethoxysilane raises concern at higher concentrations, particularly in leave-on products like body lotion, and warrants active formulation oversight.

Insufficient Data — The largest group by far. 19 of the 25 ingredients reviewed — including Perfluorononyl Dimethicone and Trifluoroacetyl Tripeptide-2 — lack the toxicological data needed for a definitive safety conclusion.

That last category deserves particular attention. Regulators are increasingly treating data gaps not as neutral ground, but as grounds for precaution.

Why "Intentionally Added" Is the Phrase That Matters

Regulations targeting PFAS are multiplying — and most of them are written specifically around intentional use. The logic is straightforward: when a manufacturer chooses to include a PFAS ingredient, that is a deliberate decision, and regulators expect accountability for it.

Across the U.S., Minnesota, Maine, New Mexico, Washington, and Connecticut have already enacted reporting and notification requirements for intentionally added PFAS in consumer products. More states are in the pipeline. Globally, similar frameworks are advancing in parallel.

The direction of travel is clear: compliance expectations are moving beyond ingredient lists toward formulation-level accountability — requiring brands to know not just what is in their products, but why, and what the regulatory obligations around those choices are.

Where Manufacturers Should Focus

Brands that use PFAS-containing ingredients need to get ahead of this — not respond to it after the fact. That means conducting thorough formulation audits, mapping exposure against current and emerging state requirements, building documentation that supports regulatory transparency, and evaluating reformulation where ingredients fall into flagged or data-gap categories.

The regulatory window is open. But the pace of new legislation means it will not stay that way for long.