I Use Waterproof Mascara. Here’s How the FDA’s PFAS-in-Cosmetics Report Hit Me.
By Noelle DeStefano, National PFAS Sector Lead
I’ve been wondering about PFAS in cosmetics for a long time for a pretty personal reason: I use the products every day (well, most days). Waterproof mascara, long-wear eyeliner— the stuff that’s designed to stay put.
What finally pushed me to stop wondering and actually dig deeper into the science was the FDA’s recently published report on the intentional addition of PFAS to cosmetic products:
FDA News Release: FDA Finds Insufficient Data to Determine Safety of PFAS in Cosmetic Products
Reading it was a mix of relief (someone finally compiled this) and frustration (how many gaps are still there). I’m not a toxicologist and I’m not giving product advice here. I’m sharing what I took from the FDA’s work, what it does and doesn’t say, and why I think it matters.
What did the FDA identify?
Using mandatory cosmetic product listing data submitted to FDA under the Modernization of Cosmetics Regulation Act (MoCRA), FDA identified 51 PFAS intentionally added as ingredients across 1,744 cosmetic product formulations (as of August 30, 2024). FDA reported these PFAS-containing formulations represent 0.41% of the total cosmetic products registered in the listing database as of August 2024.
The top product categories included eye shadows, face and neck leave-on products, eyeliners, face powders, and foundations. That alone explains why eye-area products keep coming up in this conversation.
FDA then prioritized a safety review of the 25 most frequently used PFAS, which accounted for a little over 96% of PFAS uses in the listing data.
Did FDA consider exposure routes like dermal, ingestion, and ocular?
Yes, explicitly.
FDA describes dermal contact as the primary route for most cosmetics, but it also calls out other pathways depending on product type, including incidental ingestion (for lip products), incidental inhalation (for powders), and ocular contact (for eye makeup).
I wanted to confirm that before saying anything publicly, because a lot of online takes collapse everything into “skin contact,” even though eye and lip products are a different exposure scenario than, say, a lotion on your forearm.
What did the FDA conclude?
The headline is: the FDA found major data gaps.
They stated there is insufficient publicly available data to determine safety for most PFAS used as cosmetic ingredients, and pointed to gaps that make risk assessment difficult, including limited toxicity information, limited data on use levels, and limited absorption information for many of the ingredients reviewed.
A few were described as low concern under intended conditions of use. One ingredient, (perfluorohexylethyl triethoxysilane), was flagged as a potential safety concern with uncertainty, and for most, the FDA could not make a definitive safety determination based on what’s available.
If you’re a consumer, that can feel unsatisfying. But it’s also the most honest outcome: “we can’t conclude” is not the same thing as “safe,” and it’s not the same thing as “dangerous.” It usually means the dataset isn’t strong enough to answer the question people are actually asking.
Stay ready with The PFAS Wire: From Lab Bench to Legislation
Regular insights on PFAS requirements and testing implications delivered straight to your inbox.
Where can I add value to the conversation?
This isn’t my discovery, and I’m not trying to re-litigate the FDA’s work. The value I can add from my seat is helping translate what this means in practical terms.
Here are the takeaways I think are fair:
- The question is shifting from “is PFAS present?” to “which PFAS are intentionally added, in what product types, and what do we actually know about the relevant exposure routes?”
- Eye-area products are part of the focus for a reason. FDA’s product listing data puts eye categories among the most common PFAS-containing types, and the FDA explicitly includes ocular contact as a pathway to consider for eye makeup.
- The most important output of this report may be the map of what’s missing. If we want clearer answers, the path runs through better use-level transparency and better absorption and toxicity datasets for the PFAS ingredients used in modern formulations.
The big picture? States (and Congress) are moving anyway.
Even with scientific uncertainty, the policy landscape is already changing, and much of it is happening at the state level. Even while the science catches up, policy is already shaping what ends up on shelves, which is why this matters beyond academic debate. FDA notes that multiple states have passed laws restricting intentionally added PFAS in cosmetics with effective dates rolling out between 2025 and 2028.
A few examples to make it concrete (not exhaustive):
California – AB 2771: Under the state’s PFAS restrictions, cosmetics are prohibited from containing intentionally added PFAS, with the ban taking effect January 1, 2025.
Minnesota – Amara’s Law: Under the state’s PFAS phase-out framework, cosmetics are classified as an early product category, meaning the sale of products containing intentionally added PFAS is prohibited beginning January 1, 2025.
Maryland – HB 643: Under the state’s PFAS restrictions, cosmetics are prohibited from containing certain intentionally added ingredients, including a defined list of PFAS, with the ban taking effect January 1, 2025.
Maine: Under the state’s PFAS phase-out framework, sales prohibitions expand to include cosmetics containing intentionally added PFAS, with the restriction taking effect January 1, 2026.At the federal level, there has also been proposed legislation, including the No PFAS in Cosmetics Act (H.R. 6519). Whether that specific bill advances or gets reintroduced in a new Congress, the direction is clear: states are already setting the pace, and brands are being pulled toward reformulation and stronger supply-chain documentation.
Where do I land, personally and professionally?
Personally, I’m not posting this to tell anyone what to buy, or to start a panic purge of makeup bags. I’m posting because I use these products too, and it was genuinely frustrating to see how much uncertainty still exists for ingredients that show up in everyday items.
Professionally, what I’m watching is less about headlines and more about what comes next: better exposure-relevant datasets, clearer use-level information, and clearer definitions around “intentionally added” versus what’s technically unavoidable. Those details are where both consumer confidence and compliance decisions start to live.
If you use waterproof or long-wear cosmetics, was the FDA report new to you, or have you been following the PFAS-in-cosmetics conversation for a while? And if you work in manufacturing, compliance, or research, what feels like the biggest bottleneck right now: ingredient disclosure, testing, defining PFAS consistently, or something else?
Before you go...
If you are interested in in articles like these, I recommend subscribing to my newsletter, The PFAS Wire: From Lab Bench to Legislation.
It's my way of delivering insights like these straight to your inbox, at the most, once a month.
Sources
FDA: FDA Finds Insufficient Data to Determine Safety of PFAS in Cosmetic Products
Established in 2019, Metiri Group has focused on using full-service environmental laboratories to deliver testing services to inform the decisions that improve the lives of people and the planet.
In addition to its analytical capabilities, Metiri Group aims to deliver exceptional value to a range of clients, from industrial and corporate clients, municipal water systems, environmental consultants and engineers, and local, state and federal government. Metiri Group continues to strive to be the first choice for environmental analytical laboratory services.
