PFAS Testing in Cosmetics: Gaps in Common Methods

In brief

• EPA 537.1, EPA 533, EPA 1633, and ASTM D7979/D7968/D8421 were never designed for cosmetics.
• These tests skip PFAS classes common in cosmetic formulas, like PAPs, FTOHs, polymeric PFAS, and fluorinated oils.
• A long analyte list from these methods does not mean relevant coverage for PFAS in cosmetics.
• Gaps lead to false “PFAS-free” claims, compliance risk, and lost trust.
• The only way to get meaningful results is with cosmetics-validated methods.

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Many cosmetic PFAS are invisible to environmental testing

PFAS turn up in more than half of tested cosmetics, even without being listed on labels. They’re in film formers, texture agents, and surface modifiers. The problem isn’t only the ingredients—it’s the testing. Environmental methods were designed for samples like drinking water and wastewater. Cosmetic matrices—dense pigments, waxes, silicones—defeat those extraction and detection steps. “Non-detect” often means “not targeted” rather than “absent.”

Why environmental methods don’t fit cosmetic products

Cosmetic product matrices such as pigments, waxes, and silicones interfere with conventional PFAS methods, leading to incomplete or misleading results.

• Poor recovery in pigment-rich, waxy, or silicone-heavy products, causing incomplete PFAS profiles.
• Focus on legacy perfluoroalkyl acids, missing PAPs, FTOHs, polymeric PFAS (including PTFE), and fluorinated oils.
• No detection for PFAS classes outside the target list, leaving unknowns unreported.

Use this instead: Total fluorine screening detects the presence of fluorinated material, even when specific PFAS aren't named in the method. When paired with cosmetics-relevant targeted methods, it provides a defensible path forward.

Missing coverage across key PFAS classes

Don’t mistake “non-detect” with “PFAS-free”

When test panels exclude PFAS actually present in cosmetics, companies face real exposure, even if results say “none detected.”

• Brand exposure – PFAS may still be present in “PFAS-free” products.
• Compliance gaps – State and retailer rules often target PFAS outside these panels.
• Reformulation delays – Late discovery of PFAS in production cycles.
• Testing waste – Budgets spent on panels irrelevant to cosmetics.

Cosmetic-validated PFAS testing should deliver:

• Matrix-specific validation on finished cosmetics.
• PFAS target lists aligned to actual cosmetic usage.
• Recovery and interference data for complex formulations.
• Paired total fluorine screening + targeted confirmation.
• Clear separation of “not tested” from “not detected.”

Effective PFAS testing in cosmetics requires proof it works in real formulations, not just in water or soil samples.

Regulatory pressure makes the gap urgent

Regulation around PFAS in cosmetics is tightening. Environmental methods give a false sense of security, slow the removal of PFAS from products, and leave companies unprepared when laws change. The industry needs to match the test to the matrix and the PFAS in use—now, not after the next round of restrictions.

For the full technical breakdown

The full report includes expanded method comparisons, validation results, and guidance for building defensible PFAS testing programs for cosmetics.