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The cosmetics industry faces a critical, often unseen, challenge: the widespread presence of per- and polyfluoroalkyl substances (PFAS) in many products. Despite growing consumer demand for “clean beauty” and increasing industry commitments, a significant gap exists between what consumers believe they are buying and the actual chemical composition of cosmetic formulations.
The core issue lies in current PFAS testing methods. Modern PFAS analytical methods were originally developed for environmental samples like drinking water, groundwater, soil, or wastewater.
These methods were never intended or validated for the fundamentally different and far more complex chemistry of cosmetic formulations like mascara, lotions, or lipstick.2,6
This fundamental mismatch creates (1) irrelevant analyte coverage that overlooks many PFAS in cosmetics and (2) matrix incompatibility where complex ingredients thwart extraction and detection.
Standard EPA/ASTM PFAS methods focus on a narrow list of “legacy” compounds, primarily C4–C12 perfluorocarboxylic and perfluorosulfonic acids (e.g., PFOA, PFOS), which are common in drinking water contamination. However, they critically fail to target many PFAS chemistries actually used as ingredients or present as impurities in cosmetic products.5,6
This leads to dangerous “false negatives,” where a product tests “non-detect” for PFAS, but these substances are still present, simply undetected.
| PFAS Class (examples) | Found in Cosmetics? | EPA 537.1 (DW) | EPA 533 (DW) | EPA 1633 (Multi-matrix) | ASTM D7979 (NPW) | ASTM D7968 (Soil) | ASTM D8421-22 (Multi-matrix) |
|---|---|---|---|---|---|---|---|
| Perfluoroalkyl carboxylic acids (PFCAs) | Yes (impurities) | ✓ (C6–C12) | ✓ (C4–C12) | ✓ (C4–C14) | ✓ (C4–C12) | ✓ (C4–C12) | ✓ (C4–C14) |
| Perfluoroalkyl sulfonic acids (PFSAs) | Yes (impurities) | ✓ (C4, C6, C8) | ✓ (C4, C6, C8) | ✓ (C4–C10) | ✓ (C4, C6, C8) | ✓ (C4, C6, C8) | ✓ (C4–C10) |
| Fluorotelomer sulfonates (FTSAs) | Possible (impurities) | ✗ | ✓ (6:2, 8:2) | ✓ (4:2, 6:2, 8:2) | ✗ | ✗ | ✓ (4:2, 6:2, 8:2) |
| Fluorotelomer alcohols (FTOHs) | Yes (ingredient/residual) | ✗ | ✗ | ✗ | ✗ | ✗ | ✗ |
| Polyfluoroalkyl phosphates (PAPs) | Yes (ingredient) | ✗ | ✗ | ✗ | ✗ | ✗ | ✗ |
| Perfluoroalkane sulfonamides (e.g., FOSA) | Yes (impurity) | ✗ | ✓ (some derivatives) | ✓ (FOSA) | ✗ | ✗ | ✓ (some) |
| Polymeric PFAS (e.g., PTFE) | Yes (ingredient) | ✗ | ✗ | ✗ | ✗ | ✗ | ✗ |
| Fluorinated oils/ethers (e.g., perfluorodecalin) | Yes (ingredient) | ✗ | ✗ | ✗ | ✗ | ✗ | ✗ |
“DW”: drinking water method. “NPW”:Non-potable water method. “Multi-matrix”: applicable to multiple environmental media (water, soil, etc.).
As the table demonstrates, many PFAS classes commonly found in cosmetics—such as fluorotelomer alcohols (FTOHs), polyfluoroalkyl phosphates (PAPs), polymeric PFAS (e.g., PTFE), and fluorinated oils/ethers (e.g., perfluorodecalin)—are entirely outside the scope of standard EPA/ASTM methods. Even the classes that are covered, like PFCAs and PFSAs, often focus on legacy contaminants rather than the intentionally added fluorinated ingredients in modern cosmetic formulations.
This means that if a cosmetics manufacturer or contract testing lab relies solely on these standard environmental methods without modification, they may receive a report indicating “non-detect” for PFAS, yet the product could still contain significant levels of these substances that were simply not within the testing scope. This provides a dangerous sense of security and can lead to brands unintentionally misleading consumers and regulators with “PFAS-free” claims based on narrow testing.
Even with an expanded analyte list, cosmetic products present severe analytical challenges due to their inherently complex chemical matrices. Unlike the more conventional environmental matrices like soil and groundwater, cosmetics are highly varied. These intricate formulations may be composed of diverse mixtures of oils, waxes, silicones, surfactants, polymers, pigments, and other functional ingredients.2,3,6
These matrix components can significantly disrupt standard PFAS extraction. Waxes and oils can encapsulate PFAS molecules or sequester them, leading to low recoveries—meaning the method fails to extract all the PFAS from the sample.
A recent scientific study on PFAS in mascara underscored that “cosmetic products contain a variety of compounds that can interfere with the selective extraction of PFAS, leading to low recoveries.”2
In plain terms, even if a PFAS compound is truly in the product, the method may only recover a small fraction of it from a thick mascara or oily cream, yielding a falsely low result.
Beyond extraction, any non-PFAS matrix components that enter the analytical instrument can suppress or enhance the PFAS signals during detection. High organic content (e.g. lipids, antioxidants, stabilisers, etc.) can cause ionization suppression in LC-MS/MS, leading to a much weaker or absent signal for the PFAS present.4 Particulate matter (e.g., carbon black pigment from mascara or titanium dioxide from sunscreen) can artefactually deteriorate PFAS, as well as ruin equipment. This can result in underestimation of concentrations or missing low-level PFAS entirely.
To address these blind spots, a more comprehensive analytical approach is urgently needed. Total Fluorine (TF) screening methods are a vital first line of defense.
TF screening broadly detects any organofluorine content, regardless of the specific PFAS structure. This non-targeted approach acts as a crucial safety net, essential for identifying the presence of any fluorinated compounds, even those not specifically targeted by conventional methods. If a product shows no measurable total fluorine, it provides greater confidence that PFAS are truly not present at meaningful levels.4
Conversely, if total fluorine is high but targeted analysis finds nothing, it serves as a “red flag” indicating potential matrix issues or the presence of unknown PFAS.
Relying on inadequate PFAS testing methods carries significant risks across the industry:
While robust, long-term testing solutions are under development, cosmetic brands, product formulators, quality assurance teams, and regulators must act now:
Recognizing that new problems demand new tools, ALS is taking a proactive, science-led stance. By being early movers in setting robust PFAS testing standards, the industry can avoid future market fragmentation, innovation stagnation, and erosion of consumer trust. We are dedicating significant research and development to create a defensible, fully validated PFAS analytical method specifically for complex cosmetic matrices. Our commitment is to rigorous method development, ensuring any future offering meets the highest scientific standards.
Our approach includes:
The industry must upgrade its “radar” for PFAS in cosmetics. This involves adopting better approaches – including, critically, using total fluorine screening to broadly detect the unseen (acting as a wide-angle radar for any fluorinated compounds) – and insisting on validated, matrix-appropriate PFAS test methods for cosmetics to obtain reliable, specific data.
ALS is committed to continuing to update the industry as its cosmetics-specific PFAS method development progresses and invites all stakeholders to join in this critical effort. The ultimate goal is to ensure that PFAS in cosmetics are accurately identified and eliminated, thereby protecting consumers and proactively mitigating regulatory and reputational risks.
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