REGULATIONS 55


The same chemical resistance that gives PFAS their utility, however, also contributes to their persistence in the environment and the scrutiny now surrounding their lifecycle implications. While certain PFAS are clearly recognisable


on ingredient labels, often identifiable by terms such as “fluoro-” or “perfluoro-”, others may serve more subtle, less transparent roles within the formulation, particularly when they function in the manufacture of ingredients rather than serving a primary function. A commonplace usage of PFAS in cosmetic ingredient manufacturing is in the synthesis of peptides.


PFAS use in peptide synthesis Peptides are short chains of amino acids, usually two to fifty small building block units. They are like beads on a string that serve as fundamental biological messengers throughout the body. Peptides occupy a unique space between small molecule actives and full-length proteins; they are small enough to interact with skin targets, often with the support of optimized delivery systems yet structured enough to influence biological functions. Found in virtually every cell and tissue,


peptides regulate a broad spectrum of physiological processes, including signaling pathways involved in collagen production, cellular communication, and barrier repair. Their sequences and three-dimensional conformations are well defined, which allows for well- characterized sequences enabling targeted and mechanistically understood modes of action and measurable, reproducible benefits when applied to the skin. For a cosmetic product, this translates to


demonstrated improvements in clinical studies for specific peptides and formulations through improvements in firmness, hydration, and overall skin appearance. Because peptides are derived from


components naturally present in the human body, they are generally regarded as safe, biocompatible ingredients with a low risk of irritation or sensitization. The ubiquitous presence and familiarity of peptides also contributes to their strong consumer acceptance. Peptides are perceived as high-tech yet biologically relevant ingredients that support the skin’s natural processes. Although the field continues to evolve,


particularly with innovations in delivery systems, sequence design and peptide stabilization, peptides have already established themselves as a trusted, high-performance class of cosmetic actives, making them a cornerstone of modern dermal science and formulation. Peptide synthesis further illustrates how


PFAS can enter cosmetic supply chains in ways not immediately evident to end users. During solid-phase peptide synthesis, specific PFAS compounds are routinely used, namely ultra-short-chain PFAS such as trifluoroacetic acid (TFA), to facilitate critical steps in the manufacturing process. These include aiding protonation during cleavage, enhancing solubility of hydrophobic intermediates, and enabling


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efficient separation and purification of crude peptide material. TFA may act as both a strong acid for


deprotection steps and a commonly used counterion in peptide final forms. As TFA can remain associated with peptides after purification, it may persist within the finished ingredient supplied to cosmetic manufacturers even when it is not explicitly listed on an INCI declaration. This intersection of intentional use and


unintentional presence illustrates a key challenge facing the beauty and personal-care industry: PFAS may appear in formulations not only as purposeful performance additives (e.g. film forming ingredients), but also as legacy residue of upstream synthetic processes (e.g. peptide synthesis). As definitions broaden and regulatory


expectations evolve, understanding where PFAS originate—and how they can be effectively eliminated—has become essential for brands seeking to transition toward cosmetic peptides without the intentional use of PFAS and more transparent ingredient supply chains.


PFAS in the headlines PFAS have increasingly dominated public conversation. Depending on the precise chemistry, these chemicals may be persistent in the environment and may be slow to break down in the human body. That concern intensified in December 2025, when the US Food and Drug Administration (FDA) released a report on PFAS in cosmetics. The agency identified 51 PFAS chemicals


currently used as cosmetic ingredients in the US, based on FDA product listings, and conducted safety evaluations on the 25 most commonly used species. The key takeaway from the FDA report is that toxicological data is incomplete for the overwhelming majority of PFAS assessed. Only five ingredients, PTFE, Perfluorodecalin,


HC Yellow No. 13, Perfluorohexane, and Tetrafluoropropene, showed low safety concerns under intended use conditions. For the remaining 19 substances, the FDA did not draw safety


conclusions.5


The gaps driving that uncertainty


included missing dermal and oral absorption studies, limited mechanistic data, and an absence of robust dermal toxicity information. In short: current risk assessments are far from definitive, and the FDA indicated that future evaluations may shift significantly as new data emerges.5 At the same time, state-level action across the US is accelerating reformulation pressure. Even without overarching federal restrictions, states such as Maine and Washington have already enacted bans on intentionally added PFAS in cosmetics, setting in motion a nationwide movement that is rapidly reshaping compliance expectations. As of now, 20 US states have introduced


or enacted laws restricting or prohibiting intentionally added PFAS in personal care products, with new bills advancing each legislative cycle. For brands, the message is clear: waiting is no longer an option. Regulatory divergence is quickly becoming regulatory momentum, and companies that do not adapt risk being locked out of key markets. The global picture is moving even faster. Across


Europe, PFAS in cosmetics are being phased out through increasingly stringent regulations. The EU ECHA restriction on PFHxA sets exceptionally low allowable levels for PFHxA, its salts and PFHxA- related substances (25 ppb for the sum of PFHxA and its salts, 1,000 ppb for the sum of PFHxA- related substances) effectively eliminating nearly all PFAS-containing cosmetic formulations unless only trace impurities remain. The EU’s broader PFAS restriction proposal


identifies the cosmetics sector as a whole as a target for comprehensive PFAS phaseouts. While PFAS have been more commonly identified in decorative cosmetics (often linked to longwear or water resistant functions), the proposed restriction applies across all cosmetic categories without product type derogations. France accelerated this timeline even further: its national PFAS ban took effect on January


June 2026 PERSONAL CARE MAGAZINE


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