PFAS In Cosmetics: State-Led Regulatory Surge Demands Proactive Compliance

Highlights

• States are rapidly enacting and implementing bans and reporting requirements for per- and polyfluoroalkyl substances (PFAS) in cosmetics, creating a complex and evolving compliance environment for manufacturers, distributors, packers, importers and retailers. The federal government, while moving forward with studies and proposed legislation, has yet to enact a comprehensive ban or uniform reporting standard for PFAS in cosmetics, leaving companies to navigate a patchwork of state laws.
• Enforcement and litigation risks are rising, with state attorneys general and private plaintiffs increasingly targeting PFAS in consumer products. Companies face heightened supply chain scrutiny and must ensure transparency and documentation regarding PFAS content in raw materials and finished goods.