PFAS: The Great Zero-Fluorine Challenge in the Cosmetics Sector

PFAS, often called "forever chemicals," are changing the cosmetics industry. With new regulations already in effect in France and broader European restrictions on the horizon, brands need to prepare. In this episode, we'll explore what these changes mean for cosmetic formulations, testing, and regulatory compliance. Don't miss this timely discussion on one of the beauty industry's biggest challenges.

Speakers:

• Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris
• Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

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Transcript

00:14 --> 01:43
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

 Hello everyone, and welcome to this new episode of Assurance in Action!  Today, we are opening a technical and regulatory investigation topic that is shaking the global beauty industry in this year 2026. We are going to talk about PFAS, those chemical compounds that the media often refer to as "forever chemicals."

While PFAS impact many sectors such as textiles, food packaging, and even the medical field, our focus here is on cosmetics. They are used in cosmetics for skincare texture or long-wear makeup, and these extremely resistant compounds accumulate in the environment and living organisms without ever degrading. The regulatory response has been immediate: regulation has been effective in France since January 1st, 2026 and PFAS are about to be banned by the European REACH regulation by the end of the year.

So, how can this colossal challenge be addressed in terms of formulation, quality control, and compliance? How are laboratories adapting to guarantee products that are both high-performing and completely safe?

Today we are joined by Franny, Regulatory Affairs Manager. Hello, Franny!

01:43 --> 02:00
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Hi Valentine, and hello to all our listeners. It is a pleasure to have the opportunity to shed some scientific light on this highly complex subject, where chemical rigor must be combined with industrial agility.

02:00 --> 02:16
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Franny, let's start by laying down the scientific basics. Behind the acronym PFAS, we are talking about a huge family of compounds. What are they, chemically speaking, and why do we call them "forever chemicals"?

02:16 --> 03:06
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

The term PFAS stands for Per- and Polyfluoroalkyl Substances. They belong to a vast family of synthetic chemical compounds comprising between 4,000 and 15,000 substances, characterized by an indestructible carbon-fluorine bond. One telling example are fluoropolymers used in cosmetics to texture and to waterproof makeup from volatile PFAS (used in packaging). Because of their absolute stability due to this carbon-fluorine bond which only breaks down above 1,000 °C they show very little degradation in the environment, that’s why they are called "forever chemicals."

03:06 --> 03:13
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

And yet, the cosmetic industry found them highly useful. What exactly were they used for?

03:13 --> 04:00
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

As the matter of fact, in cosmetics, formulators used PFAS. You are probably familiar with PTFE, which is basically polytetrafluoroethylene, the famous Teflon, or fluorinated siloxanes. To put it simply, these ingredients have three major functions. First, they provide a soft and homogeneous texture. Secondly, they have a smooth and shiny effect, both on the skin and on the hair. And finally, they resist water and sebum, which is why they are used in long-wear makeup: I am thinking of lipsticks, waterproof mascaras, but also sunscreens.

04:00 --> 04:13
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

It’s true that on paper, it looked almost like the must-have ingredient for formulations. But as is well known today, the downside is significant, especially for our environment.

04:13 --> 04:53
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Absolutely Valentine. On the ecological front, the facts are clear: in 2020, there were already more than 270,000 tons of PFAS accumulated in the European Economic Area, with an additional 70,000 tons emitted every year, including about 30,000 tons from the cosmetics sector. As mentioned earlier, PFAS degrade very little and can seep in everywhere: into the air, soil, and groundwater due to their high mobility.

04:53 --> 05:05
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Faced with these risks, 2026 marks a major regulatory turning point. France has taken the lead in addressing the issue.

05:05 --> 07:08
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

That’s right! France wants to reduce population exposure to PFAS through three levers. Number one, banning the commercialisation of some products, number two, strengthening health controls on drinking water, and number three, reducing industrial discharge at the source.

With the Law No. 2025-188 which has been applied since January 1st, 2026, France, via 2 decrees, bans the manufacturing and importation of cosmetics containing PFAS for various sectors, including cosmetics. The ban applies without distinction between intentional presence and unintentional contamination, making it one of the strictest regulations in the world.

Decree No. 2025-1376 of December 28, 2025, sets tiny limits which means that for any PFAS measured by targeted analysis, excluding polymers, the threshold is set at 25 parts per billion; for the total sum of measured PFAS, the threshold is 250 parts per billion; and for PFAS including polymers, the threshold is 50 parts per million. In terms of the timeline, cosmetics manufactured before January 1, 2026, can still be placed on the market and exported until December 31, 2026.

Decree No. 2025-1287 mandates water control for cosmetic production by analyzing the presence of 22 troublesome PFAS in order to guarantee safety.

07:08 --> 07:48
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

That is a very strict regulation. Regarding Europe, which does not impose a general ban on PFAS in cosmetics to date, it is deploying a progressive and very strict strategy. Some families of PFAS are thus restricted by Cosmetic Regulation 1223/2009 such as PFOS, which has been added to Annex II. Furthermore, the classification of some PFAS as CMR now requires immediate vigilance.
 
 And, what about upcoming restrictions in Europe?

07:48 --> 09:03
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

In January 2023, 5 Member States submitted a proposal to ECHA to restrict all PFAS under REACH, representing about 10,000 substances. The thresholds proposed in the initial dossier are identical to the French decree and remain under discussion today.

In March 2026, the RAC (ECHA's Committee for Risk Assessment) confirmed the need for a European restriction on PFAS due to their persistence, their accumulation in water and soil, and health risks. In parallel, the SEAC (Committee for Socio-economic Analysis) concluded that no derogation was justified for cosmetics, given the existence of viable alternatives. The European Commission is therefore expected to vote on this global restriction in 2027, leaving manufacturers with a transition period of only 18 months to completely reformulate their products.

09:03 --> 09:13
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Okay, that is very clear. We have covered the strict regulation of PFAS in France and Europe, but what about the rest of the world?

09:14 --> 10:14
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Absolutely. In the United States, we are facing heavy restrictions as well. At the federal level, the EPA (Environmental Protection Agency) has required reporting history since 2011 but excludes unintentional PFAS (traces, impurities). However, several states like California, Colorado, or Washington are tightening their laws and are already completely banning PFAS in cosmetics.

And finally, global regulations are becoming stricter: New Zealand will ban cosmetics with PFAS by the end of 2026, Japan has been strengthening its health standards since April 2026, and the Stockholm Convention is continuously expanding its bans internationally.

10:14 --> 10:43
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

We can easily see that the movement is global. But this is where the real challenge lies for cosmetics manufacturers: how do they concretely achieve full compliance when PFAS can invisibly slip in at every stage?

To help manufacturers navigate these restrictions, we have mapped out the transition in the form of a clear 5-step roadmap: The first key step is Formulation!

10:43 --> 11:10
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

This is the first step. Finished product manufacturers must review their entire catalog through a rigorous INCI audit. They must check supplier technical documentation for any ingredients containing the terms "fluoro" or "perfluoro", such as polytetrafluoroethylene or Perfluorodecalin, and launch substitution programs.

11:10 --> 11:15

Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

That’s so very well, but what do we replace these molecules with?

11:15 --> 11:37
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Green chemistry offers excellent alternatives to replace PFAS. For the waterproof and long-wear effect, there are plant oil esters or natural film-formers. The key challenge now is to validate through stability tests that these alternative formulas maintain all of their performance.

11:37 --> 11:48
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

I get it. Once the formula is secured, the second step concerns the choice of packaging. Because the risk of contamination also lies in the packaging!

11:48 --> 12:21
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Absolutely. We must permanently ban bottles that have undergone a fluorination treatment (like some HDPE plastics treated to seal the container), as the fluorine gas generates free PFAS that migrate into the formula. The solution is to strengthen documentary verification and prioritize packaging not coated with fluorinated polymers, or to turn to glass or recycled material bottles.

12:21 --> 12:33
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

The third pillar of our roadmap concerns an essential and major resource in our formulas: Water Quality.

12:33 --> 12:59
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Water often makes up 60 to 80% of cosmetic formulas. If the incoming water at the plant is contaminated by soil infiltration, traces of PFAS will remain in the finished product, and this, especially since conventional purification processes do not guarantee their total elimination. We must therefore master water traceability.

12:59 --> 13:14
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Indeed, this refers to Environmental Decree No. 2025-1287. The fourth theme then concerns the manufacturing process within our factories.

13:14 --> 13:39
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Quite right. Even with a clean formula and good packaging, the product could be contaminated during manufacturing. Factories must perform an audit to identify potential sources of PFAS: non-stick coatings on tanks or piping (often made of PTFE or Viton) which can release micro-traces through friction in the mixing tanks.

13:39 --> 13:46
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

And finally, the last pillar, which validates the entire process: Integrating analytical testing.

13:46 --> 14:07
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Yes, the real challenge today is that there are no official or standardized testing methods yet, nor is there an exhaustive list of all regulated PFAS. So, we have to combine broad approaches, like measuring Total Organic Fluorine, with targeted analyses.

14:07 --> 14:51
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

That's exactly it! And to build on that, you should know that Intertek's LaComed laboratory is already able to perform these analytical tests. I suggest we take the time to decrypt this technical topic together in an upcoming podcast!

In the meantime, remember that at Intertek, we offer comprehensive regulatory and strategic support to secure every step of your development.

A huge thank you, Franny, for shedding light on this PFAS topic. What we will remember most is that the transition is already well underway, and concrete solutions are already available to support the cosmetic industry.

14:51 --> 15:01
 Speaker 1 – Franny Montador, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

Thank you, Valentine. Ultimately, it’s proof that science is constantly moving forward to help us offer products that are always safer and more transparent.

15:01 --> 15:13
 Speaker 1 – Valentine Chauchat, Regulatory Affairs Specialist – Fragrance, Intertek Assuris

And on that note, this episode of Assurance in Action comes to an end. A huge thank you to all of you for listening, and we will see you very soon for a new breakdown!