PFAS Testing for Cosmetics

Per- and polyfluoroalkyl substances are a class of several thousand synthetic compounds defined by carbon-fluorine bonds, the strongest single bond in organic chemistry, which make them resistant to heat, water, oil and degradation. Those properties made them useful in cosmetics: fluorinated ingredients give long-wear foundations their transfer resistance, waterproof mascaras their water resistance, and lipsticks and powders their slip. The same properties make them persistent in the environment and in the body. Regulators in the EU, the United States and elsewhere have moved, on different timescales and with different definitions, from restricting a handful of named compounds to prohibiting the class.

Oxford Biosciences assesses cosmetic products and raw materials for PFAS in three stages: a review of the formulation against the current regulatory definitions, a total organic fluorine screen, and targeted quantification of individual PFAS by liquid chromatography-tandem mass spectrometry. The report states whether the product meets each limit that applies in the markets it is sold in, and, where a “PFAS-free” claim is intended, whether the evidence supports it.

What counts as a PFAS

The definition matters because it determines which ingredients are caught. The OECD definition adopted in 2021, and used by the EU in the universal PFAS restriction proposal and by most US state laws, is any substance containing at least one fully fluorinated methyl (CF₃) or methylene (CF₂) carbon atom, without any hydrogen, chlorine, bromine or iodine attached to it. Under that definition, the following cosmetic ingredients are PFAS:

• Polytetrafluoroethylene (PTFE), used as a slip agent and texture modifier in powders, foundations and skin care
• Perfluorononyl dimethicone, perfluorononylethyl carboxydecyl PEG-10 dimethicone and other fluorinated silicones, used for wear and water resistance
• C9-15 fluoroalcohol phosphate, used in transfer-resistant colour cosmetics
• Perfluorooctyl triethoxysilane, used to treat pigments for hydrophobicity
• Perfluorodecalin and perfluorohexane, used as oxygen carriers and emollients in skin care
• Polyperfluoromethylisopropyl ether and polyperfluoroethoxymethoxy difluoroethyl PEG phosphate, used as emollients and film formers
• Perfluorobutyl methyl ether, perfluoroperhydrophenanthrene and other perfluorinated solvents and emollients

Hydrofluoroolefin propellants such as HFO-1234ze are excluded from some state definitions and included in others, and the report addresses the point where a product is an aerosol.

The second category is PFAS that nobody added: perfluorooctanoic acid (PFOA) and other perfluoroalkyl acids present as residues of the manufacture of fluorinated polymers, PFAS migrating from packaging with fluorinated coatings, and PFAS arriving in water, in mineral raw materials and in processing aids. A product with no fluorinated ingredient on its INCI list can still contain measurable PFAS, and the state laws that prohibit “intentionally added” PFAS are in several cases accompanied by trace exemptions that require the brand to show the presence is technically unavoidable.

Regulatory basis

EU and Northern Ireland

REACH Annex XVII, entry 79. Commission Regulation (EU) 2024/2462 restricts undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances, which are substances containing a linear or branched perfluoropentyl (C₅F₁₁) or perfluorohexyl (C₆F₁₃) group. In cosmetic products the restriction applies from 10 October 2026: a product may not be placed on the market if it contains PFHxA and its salts at 25 ppb or more, or PFHxA-related substances at 1,000 ppb or more, in each case as a sum. The 6:2 fluorotelomer compounds that replaced the earlier C8 chemistry in many cosmetic raw materials are PFHxA-related, so the restriction reaches the fluorinated silicones and fluoroalcohol phosphates currently in use, not only a legacy contaminant.

POPs Regulation (EU) 2019/1021. PFOA, its salts and PFOA-related compounds are prohibited in substances, mixtures and articles at concentrations at or above 0.025 mg/kg for PFOA and its salts and 1 mg/kg for the sum of PFOA-related compounds, with effect from 4 July 2020. PFOS and its derivatives are prohibited at 0.025 mg/kg. PFHxS, its salts and related compounds were added with effect from 28 August 2023 at the same limits. These apply to cosmetics as mixtures placed on the market.

Universal PFAS restriction. The proposal submitted to ECHA by Denmark, Germany, the Netherlands, Norway and Sweden in January 2023 would restrict the manufacture, placing on the market and use of PFAS as a class under REACH, with cosmetics among the uses for which no derogation was proposed. The opinion of ECHA’s Committees for Risk Assessment and Socio-economic Analysis is in progress and the Commission’s decision follows it. The date of application for cosmetics is not yet fixed and is monitored under our Regulatory Watch service.

Cosmetics Regulation. No PFAS is named in Annexes II or III of Regulation (EC) No 1223/2009 as such; PFOA is captured through its harmonised CMR classification under CLP and Article 15. The safety assessor’s obligation under Article 3 and Annex I to assess every ingredient and impurity applies regardless.

Great Britain

UK REACH has not, at the date of this page, adopted an equivalent to entry 79, and the GB position on the universal restriction is being developed separately by the Health and Safety Executive. The retained POPs Regulation applies, so the PFOA, PFOS and PFHxS limits are in force in Great Britain. A product sold in both markets is assessed to the EU requirements, which are the stricter.

United States

At federal level, section 3506 of the Modernization of Cosmetics Regulation Act of 2022 required the FDA to assess the use of PFAS in cosmetics and their safety and to publish a report by 29 December 2025. No federal prohibition follows automatically from the report.

State law is where the prohibitions are. Bans on cosmetic products containing intentionally added PFAS took effect on 1 January 2025 in California (AB 2771), Colorado (HB 22-1345), Maryland (HB 643, which names thirteen specific PFAS), Minnesota (HF 2310, “Amara’s Law”) and Washington (HB 1047); on 1 January 2026 in Maine and Vermont; and, with a notification and labelling regime from 1 July 2026 and a full prohibition later, in Connecticut. Oregon’s prohibition applies from 1 January 2027 and New Mexico’s from 2028. The definitions of “PFAS” and “intentionally added” differ between states, several provide an exemption for technically unavoidable trace quantities, and Minnesota separately requires reporting of intentionally added PFAS in all products. A brand selling into the United States needs the formulation review before anything else, because the prohibitions attach to the ingredient list, not to a measured concentration.

Other markets

New Zealand’s Environmental Protection Authority prohibits PFAS in cosmetic products from 31 December 2026 under the Cosmetic Products Group Standard. Canada published its final State of PFAS Report in March 2025 and proposed adding the class to Schedule 1 of the Canadian Environmental Protection Act, with cosmetics identified among the uses to be addressed. The dates and scope in each market are monitored under Regulatory Watch.

How the assessment is done

Stage 1: formulation review

Every ingredient in the formulation is checked against the OECD structural definition and against the definitions in each applicable state law, using the INCI name, the CAS number and the supplier’s specification. This identifies intentionally added PFAS with certainty and is the assessment that the state prohibitions turn on. It also identifies raw materials with a plausible route to unintentional PFAS: fluorinated polymers, which carry perfluoroalkyl acid residues from their manufacture; pigments that may have been surface-treated; and packaging with fluorinated barrier coatings. Where the formulation contains no fluorinated ingredient and no such raw material, the review may be sufficient, and the report says so and explains why.

Stage 2: total organic fluorine screen

Targeted analysis measures the individual PFAS it is calibrated for and nothing else. A fluorinated polymer such as PTFE, a perfluoropolyether or a fluorinated silicone does not appear in a targeted LC-MS/MS analysis at all. A screen for total fluorine is therefore run first where the formulation review leaves any doubt.

A weighed portion of the product is combusted at approximately 1,000 °C in a stream of oxygen and water vapour, converting every fluorine atom, whether in a small molecule or a polymer, to hydrogen fluoride. The gas is absorbed in an aqueous solution and the fluoride is quantified by ion chromatography with conductivity detection. To separate organic fluorine from the inorganic fluoride present in some raw materials, the sample can be extracted into an organic solvent first and the extract combusted, giving extractable organic fluorine. The limit of quantification for organic fluorine in the product is in the low milligram per kilogram range.

A result below the limit is strong evidence that the product contains no fluorinated ingredient and no significant PFAS contamination, and is the appropriate substantiation for a “PFAS-free” claim. A result above it does not identify the compounds and does not by itself show an exceedance of any limit; it shows that targeted analysis is needed.

Stage 3: targeted analysis by LC-MS/MS

A weighed portion of the product is extracted with methanol, with sonication, and the extract is cleaned by solid-phase extraction on a weak anion exchange cartridge that retains the acidic PFAS and lets the bulk of the matrix through. A mixture of stable-isotope-labelled analogues of the target PFAS is added before extraction, so that losses during preparation and suppression of the signal in the mass spectrometer are corrected compound by compound.

The extract is separated by reversed-phase liquid chromatography on a C18 column with a methanol-water gradient buffered with ammonium acetate, and detected by tandem mass spectrometry with electrospray ionisation in negative mode. Each compound is identified by its retention time and by two specific precursor-to-product ion transitions in multiple reaction monitoring, and quantified against a calibration prepared from certified reference standards. A delay column between the pump and the injector traps PFAS leaching from the instrument’s own fluoropolymer components so that they do not appear as a background in the sample.

The standard panel comprises the perfluoroalkyl carboxylic acids from C4 to C14, the perfluoroalkyl sulphonic acids from C4 to C10, the fluorotelomer sulphonates and alcohols relevant to 6:2 and 8:2 chemistry, and the specific compounds named in Maryland’s HB 643, and it is extended where the formulation review indicates a particular raw material. Limits of quantification are in the range of 1 to 5 ng/g per compound, below the 25 ppb PFHxA limit and the 25 µg/kg PFOA limit with room to spare. Each batch includes a method blank, a matrix spike, a duplicate and a continuing calibration check.

Interpreting the result

The report presents three conclusions separately, because the questions are separate.

Does the product contain intentionally added PFAS? Answered by the formulation review. If yes, the product cannot be sold in the states listed above regardless of concentration, and, if the ingredient is PFHxA-related, it will exceed the 1,000 ppb limit in the EU from 10 October 2026 by orders of magnitude. The resolution is reformulation, and our formulation team advises on replacements for the fluorinated ingredient.

Does the product meet each numerical limit? Answered by the targeted analysis. The sum of PFHxA and its salts, the sum of PFHxA-related substances, PFOA and its salts, the sum of PFOA-related compounds, PFOS and PFHxS are each reported against their limit.

Where did it come from? Where PFAS is found in a product with no fluorinated ingredient, the report identifies the likely source by analysing the suspect raw material, the water and the packaging, so that the brand can demonstrate technical unavoidability where an exemption depends on it and remove the source where it can be removed.

PFAS-free claims

A “PFAS-free” claim is a claim that the product contains no PFAS, and under Regulation (EU) No 655/2013 in the EU and UK it must be truthful and supported by evidence. The evidence is the formulation review showing no fluorinated ingredient, and the total organic fluorine screen showing no measurable fluorine, and where the brand wants the claim to survive a challenge, the targeted analysis showing the named compounds below quantification. The Commission’s Technical Document on Cosmetic Claims treats “free from” claims with particular care where the substance is prohibited anyway, and the report addresses whether the claim is one the product can make.

What the report contains

• Sample identification, form, batch and date of receipt
• Formulation review: every ingredient assessed against the OECD definition and each applicable state definition, with the conclusion on intentional addition
• Total organic fluorine and, where determined, extractable organic fluorine, in mg/kg with the limit of quantification
• Targeted results for every compound on the panel in ng/g, with limits of quantification and the sums required by each regulation
• Quality control summary
• Comparison with each applicable limit and prohibition in the markets the product is sold in
• Source identification where required
• Conclusion on any intended “PFAS-free” claim

What to send

20 g or mL of product in its final packaging, from a single batch, and a second sample in glass or polypropylene if the final packaging is a fluorinated or unknown plastic. Raw materials suspected of carrying PFAS should be sent separately, 5 g each. The full formulation with percentages, CAS numbers and supplier specifications is required for the formulation review, which is the first stage and cannot be skipped. State every market the product is sold in, including US states, because the applicable definitions depend on it.

How it fits with the CPSR

PFAS findings support the impurities and traces section of Annex I, Part A, Section 2, the Article 15 and Article 17 reasoning where a CMR-classified PFAS is found as a trace, and the toxicological assessment in Part B. Where we prepare the CPSR, the formulation review is part of every assessment, and analysis is ordered where the review indicates it. Where a product is enrolled in Regulatory Watch, the entry 79 date, the universal restriction and each state prohibition are tracked against the product’s formulation and the brand is told when a change affects it.