Key FDA Findings on PFAS That Cosmetic Importers Should Understand
The U.S. Food and Drug Administration (FDA) has released a congressionally mandated report under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) evaluating the use of per- and polyfluoroalkyl substances (PFAS) in cosmetic products.
The report reviews available scientific data on PFAS intentionally added to cosmetics and highlights significant gaps in toxicological information, limiting the agency’s ability to make definitive safety determinations.
Key findings from the report
- FDA identified 51 PFAS used in 1,744 cosmetic formulations based on mandatory product listing data.
- The agency evaluated the 25 most frequently used PFAS, representing approximately 96% of intentionally added PFAS in cosmetics.
- Toxicological data for most PFAS remains incomplete or unavailable, restricting FDA’s ability to fully assess risk.
- Five PFAS appeared to present low safety concerns under their intended use, while one PFAS was identified as having a potential safety concern, though uncertainty remains.
- The report focuses on PFAS intentionally added as ingredients, not PFAS present as unintentional contaminants.
Regulatory context
At this time, there are no federal regulations that specifically prohibit PFAS intentionally added to cosmetic products. However, FDA noted it will take appropriate action if safety concerns arise and will continue monitoring emerging data.
The agency also indicated it will devote additional resources to addressing data gaps as part of broader efforts to reduce PFAS across food and consumer product supply chains.
What this means for importers
While this report does not introduce new restrictions, it reinforces increasing regulatory scrutiny around PFAS at the federal and state levels. Cosmetic importers should ensure:
- Ingredient disclosures are accurate and complete
- Product documentation aligns with MoCRA requirements
- Supply chain visibility is maintained as PFAS-related oversight continues to evolve
Alba will continue monitoring developments related to PFAS and cosmetic imports and share updates as regulatory expectations change.
Speak to an Alba expert for support.
Alba’s customs experts are available to help importers evaluate potential impacts on quota availability, entry timing, and duty exposure, contact us.
Reference: Per and Polyfluoroalkyl Substances (PFAS) in Cosmetics
