Forever...For Now, Part II: How A Potential Ban on PFAS Could Impact the Cosmetics and Personal Care Products Industries
A potential ban on the production, import, and sale of PFAS, a.k.a. "Forever Chemicals", in the European Union could have varied impacts on numerous industries worldwide.
In this Q&A we’re focusing on PFAS and the Cosmetics and Personal Care Products industries.
Specifically, we’ll address:
- how and why PFAS are used in cosmetic and personal care products
- the potential PFAS risks and supply chain concerns for cosmetic companies and consumers
- unique challenges the cosmetics industry will face if a European ban on PFAS is enacted
- solutions to avoid compliance issues and liabilities associated with PFAS
To learn more about the history, uses, health risks, and environmental impacts of forever chemicals, as well as emerging regulations aimed at banning them, please read our comprehensive PFAS overview, "Forever...For now".
A note on terminology: throughout this article, we’ll be referring to the "cosmetics industry" because that is the terminology used by European regulators, but we’re including all forms of cosmetics and personal care products in this umbrella term.
What are PFAS?
PFAS stands for "per- and polyfluoroalkane substances", also known as "forever chemicals". There are more than 10,000 different kinds. These chemicals are incredibly stable due to the strong carbon-fluorine bond and last longer in the environment than any other known type of synthetic chemical. We don’t have any way (yet) of breaking down these chemicals so in practical terms they really are "forever". PFAS are known to be toxic for reproduction and can cause damage to unborn children. They have also been linked to certain cancers, reduced vaccine efficacy in children, and liver problems, among others.
What types of cosmetic products are PFAS typically found in?
PFAS are used in a wide range of cosmetics and personal care products, including but not limited to: skin care, toiletries, hair care, perfumes/fragrances, and decorative/color cosmetics. They’re more common in longwearing products like waterproof mascara and liquid lipsticks but are also found in skin and hair care products.
Why are PFAS used in cosmetic and personal care products?
PFAS found in cosmetics and personal care products perform a variety of functions. They're used for skin conditioning, film forming, as solvents, and as surfactants. Some PFAS are essential to a product’s basic functions. For example, film formers are critical in sunscreens to provide effective sun protection, which in turn prevents skin cancer.
Long-wearing cosmetics also play an important role in consumers’ lives. They lead busy lives and have demanding personal and professional commitments. Whether it’s a student with a busy class schedule, or a doctor who’s on their feet all day seeing patients, or a busy parent caring for their family, many of them depend on long-lasting cosmetics to help them feel confident. So, formulating long-wearing cosmetics without PFAS is important.
How prevalent are PFAS in cosmetics and personal care?
It’s important to note that not all cosmetics contain PFAS. Nor do all cosmetic manufacturers use PFAS. In Europe, approximately 1,574 cosmetic and personal care products contain PFAS, according to the European Chemicals Agency, which represents 1.4% of all such products sold in Europe. In North America, however, a study conducted by researchers at the University of Notre Dame found 52% of 217 cosmetic products they tested (200 from the U.S. and 17 Canada) contained PFAS. In many cases, PFAS were not directly listed on those product labels. Thus, manufacturers may not even be aware their products use PFAS since they’re sometimes added to other ingredients (e.g. silicones, Mica) without being disclosed.
What are the risk of PFAS in cosmetics?
Because cosmetics are applied directly to the skin, the risk of direct exposure to PFAS is a significant concern. Another concern is that, unlike many other products containing PFAS, cosmetics are used frequently, if not daily. Some are reapplied multiple times a day. Others, like long-wearing lipstick and waterproof mascara that use PFAS, can enter the body through the mouth or eyes. The specific impacts of PFAS types and levels used in cosmetics, however, are still being studied. In general, elevated levels of PFAS are known to cause serious health problems and have been linked to many others. The big picture concern, regardless of the industry, is that because PFAS persist forever, their ongoing production and accumulation in places like water supplies and food sources will only cause their levels in humans to rise.
What unique challenges is the cosmetics industry facing when it comes to PFAS?
One challenge is that the cosmetics and personal care industry will most likely have a very short timeline (18 months from when the restriction becomes law) to make the necessary changes or lose access to the European market. ECHA considers there to be "technically and economically feasible alternatives" to the use of PFAS in this industry so will not be providing an extended timeline to substitute.
Another challenge is the high expectations of consumers – if a waterproof mascara is reformulated and its performance is reduced, consumers will notice!Finally, PFAS are not necessarily added deliberately by the formulator but rather are additives to common ingredients like silicones. For example, mica and talc (found in powders and eyeshadows) are sometimes treated with certain PFAS to improve durability. Cosmetics ingredients can have complex international supply chains which makes it more difficult to identify where PFAS may be added. For instance, child labor is a known issue in mica mining that has proven difficult to eradicate, so finding where PFAS are being added will be even more challenging!
How is Actalent uniquely qualified to help companies address PFAS challenges in the cosmetics industry?
Actalent has experience with technically challenging substitution programs involving complex supply chains and manufacturing processes. We also know that companies are more cost-conscious than ever. That’s why we approach substitution programs with an eye toward reducing costs and improving performance wherever possible. In addition, we’ll strengthen and streamline your compliance programs to align with best practices.
Overall, Actalent has unrivaled scientific and engineering technical expertise and talent that -- when combined with our project coordination, complex supply chain, and manufacturing process capabilities — makes us a great partner for any cosmetics and personal care products manufacturer.
