In December 2025, the U.S. Food and Drug Administration (FDA) released a congressionally mandated assessment examining the intentional use of per- and polyfluoroalkyl substances (PFAS) in cosmetic products—and the agency’s conclusion is clear: the available data are insufficient to determine safety for most PFAS currently used in cosmetics. FDA’s PFAS research will surely continue, however, so the report results should not be taken as “case closed” by companies, particularly cosmetics industry companies.

The report, Report on the Use of PFAS in Cosmetic Products and Associated Risks, was required under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). Importantly, the FDA’s review was narrowly focused on PFAS intentionally added as cosmetic ingredients, not PFAS that may be present as trace contaminants.

According to the FDA, 51 PFAS are used across 1,744 cosmetic formulations. More than half of those formulations fall into five product categories: eye shadows, leave-on face and neck products, eyeliners, face powders, and foundations. The agency evaluated the 25 most frequently used PFAS—representing approximately 96 percent of PFAS intentionally added to cosmetic products.

Of those 25 substances, the FDA concluded that toxicological data were insufficient for 19, leaving the agency unable to make a safety determination. Five PFAS were assessed as posing low safety concern when used as intended. One compound—perfluorohexylethyl triethoxysilane—was identified as presenting a potential safety concern when used in body lotion at the highest reported use levels, although the FDA emphasized that this conclusion is subject to substantial uncertainty.

Notably, there is currently no federal prohibition on the intentional use of PFAS in cosmetic products. The FDA has published general guidance on PFAS-related health and environmental risks and maintains PFAS-focused resources on its website. However, several states have already enacted, or are actively considering, restrictions or bans on intentionally added PFAS in cosmetics—creating a rapidly evolving and fragmented regulatory landscape. The FDA also made clear that enforcement action remains on the table should future evidence establish safety concerns.

For cosmetic manufacturers, brand owners, and their counsel, the message is unmistakable: regulatory uncertainty does not equate to regulatory inactivity. Companies should be proactively assessing ingredient disclosures, supply chain representations, state law compliance, and potential litigation exposure as PFAS scrutiny continues to intensify. Cosmetics companies in particular must stay vigilant on all PFAS issues and findings, especially as consumer fraud and greenwashing litigation continues to proliferate.