PFAS in cosmetics

Compared with the earlier draft reviewed and commented on by industry stakeholders, the final decree maintains the three threshold values defining non-compliance, aligned with current discussions at the European level:

• 25 ppb for PFAS detected through targeted analysis
• 250 ppb for the sum of PFAS detected through targeted analysis
• 50 ppm for total PFAS (including polymeric PFAS)
   

The decree confirms the legal application date of 1 January 2026, as set by Law No. 2025 188.

However, it introduces a 12 month sell through period for products manufactured before 1 January 2026. These products may remain on the market until 31 December 2026.

For the record, the ban applies to finished cosmetic products, covering:

• PFAS intentionally added as ingredients, and
• PFAS present unintentionally, given the sensitivity of the thresholds.

This second aspect represents the greatest compliance challenge for the cosmetics sector. PFAS contamination may arise from raw materials, processing aids, manufacturing environments, or packaging interactions - making analytical verification and supply chain control essential.

Importantly, the French threshold values and compliance principles set out in the implementing decree are identical to those currently envisaged under the forthcoming European PFAS restriction. France is therefore acting as a regulatory forerunner, anticipating at national level the framework that is expected to apply across the European Union in the coming years.

In August 2025, the European Chemicals Agency (ECHA) published an updated version of the PFAS restriction proposal. This revised text was prepared by the five Member States behind the initial restriction intention (Germany, the Netherlands, Denmark, Sweden and Norway), following an in-depth assessment of the comments received during the public consultation.

The updated proposal includes an expanded and revised list of derogations. However, no derogation is foreseen for cosmetic products, as the substitution of PFAS in cosmetics had already been assessed as both technically and economically feasible. Proposed derogations mainly concern:

• The manufacture of PFAS for certain specific downstream uses,
• The use of PFAS based solvents in industrial applications, potentially up to 13.5 years after the regulation enters into force,
• Certain applications in the energy sector and other strategic industries.
   

As of 25 September 2025, it was confirmed that the preliminary opinions of ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio Economic Analysis (SEAC) are expected to be available in March 2026. These draft opinions will then be opened to public consultation for a period of two months.

The final RAC and SEAC opinions are expected by the end of 2026, in line with earlier announcements.

Following the adoption of the final opinions, the restriction proposal will be discussed at European Commission level. If endorsed, it will be translated into a regulation amending Annex XVII of REACH.

Based on the current indicative timeline, publication of the REACH amendment could be envisaged in 2027, marking the formal entry into force of a harmonised European PFAS restriction, including cosmetics, closely mirroring the regime already implemented in France.

Companies that ensure compliance with the French PFAS thresholds, analytical requirements and supply chain controls today will be well positioned to meet future European obligations tomorrow. In this context, proactive raw material screening, robust supplier engagement, and validated analytical strategies are no longer optional, they are becoming foundational elements of regulatory compliance in the European cosmetics market.