Clean Skin Care and the Growing Ban on PFAS

PFAS in Skin Care: Are Polyfluoroalkyl Substances Dangerous?

Per and Polyfluoroalkyl Substances

Numerous ingredients in skincare and cosmetic products face restrictions or bans due to concerns about their toxicity, safety, or hazard potential. Often referred to as the “dirty dozen,” these supposedly toxic chemicals extend beyond a mere twelve, encompassing a broader array of ingredients that warrant caution and avoidance.

Amidst this landscape, Per- and Polyfluoroalkyl Substances (PFAS), known as “forever chemicals,” have become pervasive in cosmetics, valued for their water-resistant and durable characteristics. However, heightened awareness among consumers regarding potential health risks and environmental persistence has prompted regulatory action. Under the Modernization of Cosmetics Regulation Act (MoCRA), the FDA is actively engaged in evaluating and regulating PFAS in cosmetic products, reflecting a proactive response to emerging concerns.

This exploration unravels the multifaceted dimensions of PFAS in cosmetics, delving into regulatory dynamics, associated risks, state interventions, and industry responses within the evolving landscape of “clean skincare.”

PFAS, widely used to enhance the texture and longevity of cosmetic products, have raised concerns due to their persistence in the environment and potential health risks. Despite their utility, the long-term accumulation of PFAS in the body has prompted calls for stringent regulation and their removal from consumer products.

Dangers of PFAs

Studies conducted by the U.S. Environmental Protection Agency have established a link between PFAS exposure and elevated risks of cancer, developmental delays in children, organ damage (such as liver and thyroid), increased cholesterol levels, and compromised immune functions, particularly in young children. Vermont’s proposed legislation, known for its stringent stance on PFAS, extends beyond cosmetics to include a broad spectrum of products, ranging from apparel to outdoor items designed for severe wet conditions, athletic turf, ski wax, and textiles like upholstery, draperies, towels, and bedding intentionally containing PFAS.

FDA’s Expansive Oversight Through MoCRA

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) represents a landmark expansion of the FDA’s regulatory authority over cosmetics, marking the most significant since the Federal Food, Drug, and Cosmetic Act of 1938. This law aims to enhance the safety of daily-used cosmetic products. MoCRA mandates the FDA to assess the use of PFAS in cosmetics, evaluating scientific evidence and potential risks. Additionally, it requires collaboration with the National Center for Toxicological Research for a comprehensive safety assessment. By December 29, 2025, the FDA is obligated to publish a report on its website, summarizing the outcomes of the safety assessment of PFAS in cosmetic products. This forward-looking initiative aims to bolster the safety of cosmetics used daily by millions.

Regulations and Prohibitions

New Zealand has taken a groundbreaking step by announcing a ban on the use of so-called “forever chemicals” in cosmetics, effective from 2026. The Environmental Protection Authority (EPA) in New Zealand has specifically prohibited perfluoroalkyl and polyfluoroalkyl substances (PFAS) in cosmetics, citing concerns about the potential health and environmental risks associated with these virtually indestructible chemicals.

The ban is part of a broader initiative by the EPA to safeguard against PFAS exposure, encompassing environmental testing and the phased-out use of PFAS-containing firefighting foams. While the EPA acknowledges that PFAS were found in a limited number of cosmetic products, the precautionary approach reflects a commitment to minimizing potential risks. The move positions New Zealand at the forefront globally in addressing PFAS-related concerns, drawing praise from environmental, health, and science specialists.

A growing number of state legislatures are taking decisive actions to address the presence of perfluoroalkyl and polyfluoroalkyl substances (PFAS) in cosmetics and consumer products.

California was the first major jurisdiction to ban all PFAS in cosmetics, in September 2022, with a transitional period for enforcement after 1 January 2025.

Vermont achieved a significant milestone as the state Senate granted final approval to legislation aimed at prohibiting the sale or distribution of cosmetics and menstrual products containing PFAS and other harmful chemicals. The list of affected products includes shampoo, makeup, deodorant, sunscreen, hair dyes, and more. Similar restrictions on cosmetics have been passed in Colorado, and Maryland, set to be effective in 2025. Moreover, various states, including Washington, Oregon, Illinois, Rhode Island, and Georgia, are actively considering similar proposals.

Navigating clean skin care ambiguities

Navigating “Clean Skincare” Ambiguities

“Clean skincare” refers to products without harmful ingredients, but the term lacks a standardized definition , leading to confusion. Reputable companies avoid harmful substances, but the criteria for “clean beauty” vary, making it challenging to discern. California’s Proposition 65 and Hawaii’s sunscreen ban highlight diverse regulations. Dermatologists prefer terms like “safe” over “clean” due to the lack of a scientific definition. Despite 1/3 of beauty products labeled as “clean,” the term’s ambiguity is acknowledged. A standardized definition, using terms like “hazardous” and “safe,” is proposed.

Millions of Americans may be unknowingly exposed to “forever chemicals” known as PFAS from cosmetics and personal care products. A study (2) found that over half of the tested cosmetics products contained PFAS, with most not listing these compounds on their labels. PFAS, linked to various health risks, are intentionally added to products like dental floss, lotion, makeup, and more. The lack of disclosure raises concerns about unintentional exposure, prompting calls for increased regulation and a proposed ban on PFAS in cosmetics. The findings highlight the need for standardized definitions and regulations in the “clean skincare” industry.

(PFAS) has prompted a paradigm shift in regulatory landscapes, risk assessments, and industry practices. As we unravel the multifaceted dimensions of PFAS in cosmetics, it becomes evident that heightened awareness and legislative actions are shaping the trajectory of “clean skincare.” From the FDA’s expansive oversight through the Modernization of Cosmetics Regulation Act (MoCRA) to New Zealand’s groundbreaking ban on “forever chemicals” and state-level interventions in the United States, the industry is at a crossroads. The call for standardized definitions and transparent labeling resonates louder than ever, urging stakeholders to prioritize consumer safety and environmental well-being in this evolving narrative of cosmetic regulation.

A Dermatologist’s Perspective on PFAs in Skincare

PFAs may be banned in skincare soon so reputable companies are already working to remove them from their products. This is my perspective as a dermatologist on the issue.

Skincare Products with PFAs

PFAS are found in various consumer products that come into prolonged contact with human skin, including cosmetics, sunscreens, and water-repellent clothing. PFAS are commonly found in a wide range of skincare and cosmetic products, particularly in items designed to be water-resistant, such as sunscreen, foundation, and moisturizers. Their inclusion enhances product durability against sweat and water.

Can PFAs Absorb Into Skin?

There is evidence to suggest that PFAS can penetrate the skin barrier, particularly when applied topically in cosmetics. (10) The extent of absorption and its implications require further study to fully understand the potential risks.

Risks of PFAs

The concern surrounding PFAS extends beyond individual health risks, including hormonal disruption and increased cancer risk, to broader environmental and ecological impacts. These chemicals are persistent in the environment, posing potential threats to wildlife and ecosystems.

PFAS can accumulate in the human body over time due to their resistance to breakdown, potentially leading to various health issues such as thyroid disease, increased cholesterol levels, and effects on the immune system. The long-term health implications are still being studied, but evidence suggests a link to several chronic conditions.

PFAs on Product Labels

Always read product labels to look for toxic ingredients in your skincare products. You can identify products containing PFAS by looking for ingredients that include terms like “fluoro” or “perfluoro.” Many organizations and environmental groups also publish lists of PFAS-free products. Alternatives to PFAS-containing products include those labeled as clean, organic or natural, though it’s important to verify their certifications and ingredient lists for transparency.

can PFAS absorb into the skin?

INCI Names of PFAs in Skincare

Here are some of the PFA containing ingredients in cosmetics:

Ammonium Perfluorobutane Sulfonate

Diethanolamine Perfluorohexanoate

Perfluoroalkylethyl Phosphate

Perflurodecalin

Perfluoromethylcyclopentane

Perfluorooctane Sulfonamide

Perfluorooctanoic Acid

Perfluorooctyl Triethoxysilane

Perfluorobutane Sulfonic Acid

Sodium Perfluorobutane Sulfonate

Perfluorononanoic Acid

Perfluorodecalin

Perfluorodecalin is a commonly used PFA in skincare that is used for its unique oxygenation properties, which are particularly beneficial in formulations aimed at revitalizing and rejuvenating the skin. Found in oxygenating facial creams and specific types of makeup, this compound helps to enhance oxygen delivery to the skin, promoting better circulation and supporting the skin’s natural healing processes. Its inclusion in cosmetic products leverages the ability to provide a breathable, protective layer, thereby improving the overall appearance of the skin by making it look healthier and more vibrant.

DQH Can I use salicylic acid first and then vitamin C? It’s easy to create a skincare routine, but knowing how to use it is another thing entirely. In most cases, if you’re not getting the desired skin results, it could be due to the layering of conflicting ingredients. So, is it possible that salicylic acid and vitamin C are such ingredients? Or are these active ingredients the duo that’s been missing from your skincare routine? If you want answers, stick around because today we are going to explain the benefits of salicylic acid and vitamin C and how they can be used in your daily life. What are the benefits of salicylic acid for skin? Salicylic acid is one of the most commonly used beta hydroxy acids and is favored by many people with oily, acne-prone skin. This acid is derived from willow bark, and unlike its water-soluble relatives (called alpha-hydroxy acids), salicylic acid is oil-soluble, which means it can penetrate deeper into the lower layers of the skin. Once it reaches the lower layers, it can help unclog pores of excess sebum, dirt, bacteria, debris, and impurities. This results in clearer skin tones and greater definition. Not only does salicylic acid benefit the underlying layers, but the outer surface of the skin benefits as well. When applied to the skin, salicylic acid removes the buildup of dead skin cells. This is accomplished by breaking the bonds that hold dead cells to the surface. Over time, this can cause the complexion to look dull and prone to acne, blackheads, and other blemishes. If you’d like to learn more about salicylic acid and how it can improve your skin, check out this dedicated blog post from a beauty insider. What are the benefits of vitamin C for skin? Vitamin C is considered one of the most powerful antioxidants, which means it is very effective at fighting free radicals and preventing them from causing further skin damage. Examples of free radicals include pollution, central heating, UV rays and harsh climate. They attack proteins, fats and cell membranes as soon as they come into contact with the skin, causing signs of premature aging such as fine lines and wrinkles as well as hyperpigmentation, flaky patches of skin and loss of elasticity. Many people usually prefer to use vitamin C in their morning routine as this ingredient gives the complexion a radiant glow. You’ll also find that vitamin C can target areas of hyperpigmentation, plumping the skin and reducing the appearance of fine lines and wrinkles. The thing about vitamin C is that there are a lot of outdated studies going back to the 1950s that describe vitamin C as an unstable skin component. Thanks to improvements in modern technology, this is no longer the case as all products now contain a stable form of vitamin C. Visit The Beauty Insider to learn more about vitamin C. So please check out our blog post. Can I use salicylic acid first and then vitamin C? Yes, you absolutely can. In fact, it’s thought that using salicylic acid before using vitamin C ensures it penetrates faster and works faster. This is an efficient way to utilize two power sources, and the reason has to do with pH. For example, the skin’s natural pH is about 4.7, making it slightly acidic. Salicylic acid and vitamin C are also both acidic, and you’ll find that vitamin C is absorbed quickly into the skin. Therefore, using salicylic acid beforehand can increase the acidity of the skin and allow vitamin C to penetrate into the skin faster. While this is considered an effective way to combine two powerful ingredients, you need to be aware of your skin type and how it reacts to certain active ingredients. Even people with perfect, normal skin can experience skin sensitivity and irritation. Therefore, always consult a doctor or dermatologist before using any new products on your skin. It’s also important to follow skin application rules. In this case, you need to use the product correctly to ensure you get the best results for your skin. If you’re not sure what I mean, the basic rule for skin is to start with the thinnest consistency and work your way up to the thickest consistency. This prevents a barrier from forming on the surface, preventing other active ingredients from penetrating the skin. Can I use salicylic acid at night and vitamin C in the morning? Yes, absolutely, this is considered the most effective way to get returns without any adverse side effects. This is because there is enough time between applications to ensure that the skin’s pH levels return to balance. You’ll also find that Vitamin C is rich in antioxidants and is perfect for use in the morning to ensure your skin is protected and looking its healthiest. Due to the small size of salicylic acid molecules, it is an acid that is able to reach the deepest parts of the skin. While this is effective at keeping skin clear, it also increases the risk of irritation and photosensitivity. Therefore, many people prefer to use powerful BHAs in their evening routine without exposure to UV rays, pollution, or harsh weather. Warning: If you avoid using sunscreen every day, none of these ingredients will do what your skin needs. The combination of chemical peels and powerful ingredients increases the risk of further damage to the skin’s surface. Use SPF 50 every day to keep your skin protected and your lipid barrier healthy, even on cloudy days, keeping your skin in top condition.

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