We’d Been Waiting Forever: FDA Issues Congressionally Mandated Report on Use of PFAS in Cosmetics

Key Takeaways

• FDA delivered its first assessment of PFAS in cosmetics. Issued on December 29, 2025, the statutory deadline under MoCRA, the report is the first federal assessment of PFAS in cosmetic products and establishes a federal baseline on the intentional use of “forever chemicals” in cosmetics.
• The report provides prevalence data, but limited safety conclusions. Using data collected under MoCRA’s new reporting requirements, FDA identified 51 PFAS intentionally used in 1,744 cosmetic products. The agency evaluated the 25 most frequently used PFAS, finding low safety concern for five substances, potential concern for one, and insufficient data to reach conclusions for the remainder.
• The report underscores where regulatory pressure is likely to come from next.
  FDA emphasized data gaps that limit near-term federal action and confined its analysis to the intentional use of PFAS, ignoring issues related to unintentional PFAS contamination. State-level bans, retailer standards, and consumer expectations will continue shaping compliance decisions.

With zero days to spare, the Food and Drug Administration released its “Report on the Use of PFAS in Cosmetic Products and Associated Risks” examining per- and polyfluoroalkyl substances (“PFAS”) — also known as “forever chemicals” — intentionally added to cosmetic products.¹ Section 3506 of the Modernization of Cosmetics Regulation Act of 2022 (“MoCRA”) required the report to be issued no later than December 29, 2025.

The report represents the first comprehensive federal assessment of PFAS in cosmetic products.² It provides industry, consumers, and other stakeholders with a federal baseline on the intentional use of PFAS in cosmetics that may shape future conversations around ingredient disclosure, safety substantiation, and regulatory compliance. At the same time, the report acknowledges “significant uncertainties, including limited data” related to use, dermal and oral absorption, mechanistic information, and dermal toxicity. FDA “will continue to monitor emerging data on PFAS to ensure the continued safety of cosmetic products.”

History Behind PFAS in Cosmetics

In the most significant update to federal cosmetics regulation in decades, MoCRA expanded FDA’s oversight of cosmetic products and directed the agency to examine emerging ingredient-related issues, including forever chemicals. PFAS are a class of synthetic compounds known for their waterproofing, non-stick, and grease and stain resistant properties. They are characterized by strong carbon-fluorine bonds that resist degradation in the environment, leading to long persistence in soil, water, and biological systems. As a result, PFAS have been the subject of increasing regulatory and public health attention.

Report Findings

The report acknowledges that PFAS are prevalent in cosmetics because they can improve product performance in ways that appeal to both formulators and consumers, such as enhancing spreadability, creating smooth or silky textures, increasing water and wear resistance, and helping products form uniform, long‑lasting films on skin and hair. These functional benefits have led to the use of PFAS across a range of categories, including makeup, lotions, and other leave‑on products, where longer wear time and specific sensory properties are commercially valuable.

MoCRA established a biennial requirement to register cosmetics manufacturers and processers. Manufacturers, packers, and distributors must update FDA annually on the products they market, including detailed ingredient lists. From this data, the report identifies 51 different forever chemicals used intentionally as ingredients in 1,744 cosmetic formulations. PFAS-containing products “represent 0.41% of the total products registered as of August 2024.” 56% of these products come from five product categories: “eye shadows, face and neck products (leave-on), eyeliners, face powders, and foundations.”

The report focuses on the 25 PFAS most frequently used in cosmetics. These 25 compounds account for about 96% of all PFAS intentionally added to cosmetics. For further data, the report provides detailed tables on the prevalence of each PFAS compound.

FDA found that five of the 25 frequently used PFAS currently present a “low safety concern” under their intended use. One compound, perfluorohexylethyl triethoxysilane used in body lotion, may present a safety concern; it is among the five most prevalent PFAS in FDA’s product‑listing database. For the remaining 19 chemicals, FDA could not reach a safety conclusion because important toxicology and exposure data were not available.

AGG Observations

Data Gaps. For 19 of the 25 frequently used PFAS studied in the report, FDA could not establish risk profiles because of insufficient toxicological data. The agency claims it will “continue to monitor emerging information on the cosmetic use and safety of PFAS.” Gaps in available data will continue to impede regulation at the federal level. FDA Commissioner Makary acknowledged as much in a release about the report, stating that “lack of reliable data demands further research.”[1] Whether and how that research materializes — and how quickly it informs regulatory action — remains an open question.

Impact From State-Level Legislation. Intentional use of PFAS in cosmetics has declined in recent years as states move ahead with their own bans and restrictions. Several states, including California, Colorado, Maryland, Minnesota, Oregon, and Washington, have enacted prohibitions with compliance dates beginning as early as January 1, 2025, and additional bans phased in through 2026-2027. Companies must account for this expanding patchwork of state-by-state legal requirements. For further information regarding state-level PFAS legislation applicable to cosmetics, please reach out to the authors.

Consumer Expectations. Shifting consumer expectations toward “PFAS‑free” or “clean” beauty offerings are reflected increasingly in retailer standards, private-label requirements, and third-party certifications, which may impose obligations beyond those required by law.[2] As a result, companies face heightened scrutiny of marketing claims and greater pressure to substantiate “PFAS-free” representations, particularly as definitions and testing standards continue to evolve.

Unintentional PFAS Use. Notably, FDA limited its analysis to PFAS intentionally added to cosmetic products. It does not address PFAS that may be present unintentionally, such as through impurities or manufacturing processes. FDA explained that unintentional PFAS presence raises separate considerations and was outside the scope of the statutory mandate. For industry, the omission makes clear that unintentional PFAS remains an open question.

Taken together, while the report provides a long-awaited baseline on the intentional use of PFAS in cosmetics, FDA also makes clear that significant research and data gaps constrain regulatory action. In the absence of federal standards regulating PFAS use in cosmetics, companies should pay close attention to state actions, retailer requirements, and consumer expectations to shape compliance and risk. For now, the report marks a starting point for FDA and leaves many questions unresolved, though hopefully not forever.

[1] The Report, issued on December 29, 2025, can be accessed here.

[2] The Report does not consider unintentional use of PFAS in cosmetic products.

[3] The Press Release for the Report, including the Commissioner’s statement, can be accessed here.

[4] A June 2023 white paper commissioned by the Consumer Product Safety Commsion provides an overview of PFAS in a broad range of consumer products and can be accessed here.