PFAS in your cosmetics: what the October 2026 deadline means for indie brands — and why France is already different

May 26
4 min read

Most indie beauty brands have heard of PFAS. Fewer know which specific regulation applies to their products, from which date, or what the concentration thresholds actually are. This article covers what PFAS are, which ones are restricted in EU cosmetics and from when, why France already operates under a stricter regime, and what the broader PFAS landscape looks like for 2027 and beyond.

What PFAS are — and why they matter in cosmetics

PFAS — per- and polyfluoroalkyl substances — is an umbrella term covering approximately 10,000 fluorinated chemical compounds. In cosmetics, they appear most commonly in long-wear make-up, waterproof sunscreens, anti-frizz hair products, and certain skin care formulations designed to improve spreadability or water resistance.

The regulatory concern around PFAS is not primarily about acute toxicity at typical cosmetic concentrations. It is about persistence. PFAS do not break down in the environment or in the human body at meaningful rates. They accumulate over time — in water systems, in soil, and in living organisms. The result is a regulatory landscape that is moving faster and more comprehensively than most indie brands realise.

The October 2026 deadline: what it restricts and what it means

The regulation: REACH Annex XVII Entry 79 (EU 2024/2462)

The EU adopted Regulation (EU) 2024/2462 in September 2024, adding PFHxA (perfluorohexanoic acid), its salts, and PFHxA-related substances to Annex XVII of REACH. The restriction applies to cosmetics from 10 October 2026. The specific thresholds are:

PFHxA and its salts: concentration must be below 25 ppb (25 micrograms per kilogram) in the finished product.
PFHxA-related substances: concentration must be below 1,000 ppb (1,000 micrograms per kilogram).

These are very low limits. The 25 ppb value reflects the non-threshold approach adopted by ECHA’s Risk Assessment Committee, which noted that the limit should be set as low as practically achievable. It is a practical compliance ceiling, not a toxicologically safe level.

Which cosmetics are affected

The restriction applies to all cosmetic product categories. The products most likely to contain PFHxA or PFHxA-related substances are long-wear foundations, waterproof mascaras and eyeliners, waterproof sunscreens, certain anti-frizz hair treatments, and products using fluorinated polymers for texture or film-forming properties.

Importantly, PFHxA can also be present as an impurity or degradation product in ingredients that are not themselves classified as PFAS. Some fluorinated compounds break down to release PFHxA under manufacturing or storage conditions. This means a formulation audit needs to go beyond simply checking ingredient names against a PFAS list.

What you need to do before October 2026

First, request a declaration from each ingredient supplier confirming whether their materials contain PFHxA, PFHxA salts, or PFHxA-related substances, and at what concentrations. This should be explicit and referenced to REACH Annex XVII Entry 79.

Second, if any ingredient contains these substances above the threshold, assess whether reformulation is possible. For products that genuinely rely on fluorinated performance properties, alternatives exist but may require significant development time. Starting now is not early.

Third, update your Product Information File to document the compliance assessment and the supplier declarations obtained. If a product is confirmed compliant, that confirmation needs to be on file with evidence.

France: a stricter and earlier regime

Brands selling in France need to understand that the October 2026 EU deadline is not the relevant date for them. France enacted its own national PFAS restriction — Law No. 2025-188 — in February 2025. It entered into force on 1 January 2026.

The French law bans the manufacture, import, export, and sale of cosmetics containing PFAS on the French market. It is broader than the EU’s PFHxA restriction in two important ways: it covers PFAS as a class — not just PFHxA and its related substances — and it applies now, not in October.

A product that complies with the October 2026 EU regulation may still be non-compliant in France today, because it contains PFAS compounds that fall outside the EU’s PFHxA-specific restriction but inside France’s broader class ban. For brands targeting the French market, this requires a separate compliance check that goes beyond the EU-level analysis.

What’s coming after October 2026

The PFHxA restriction is not the end of the PFAS story in EU cosmetics — it is the beginning of a much larger regulatory shift. ECHA’s RAC and SEAC committees are currently assessing a comprehensive restriction proposal covering PFAS as a broad chemical class under REACH — potentially thousands of substances simultaneously. SEAC’s draft opinion was open for public consultation until 25 May 2026.

For cosmetics specifically, RAC concluded that no derogations are justified. Once SEAC publishes its final opinion — expected by late 2026 — the European Commission could propose binding rules as early as 2027.

The practical implication: a reactive approach — waiting for each restriction to land before reviewing formulations — will not be viable. The brands that will manage this transition well are those that have already mapped their PFAS exposure across their full portfolio.

The three PFAS deadlines to track right now

1 January 2026 — France national ban. PFAS as a class banned in cosmetics on the French market. Already in force.
10 October 2026 — EU REACH restriction. PFHxA and related substances in cosmetics must be below 25 ppb / 1,000 ppb. Applies across all EU markets.
2027 (expected) — Comprehensive EU PFAS restriction. All PFAS as a class, pending final SEAC opinion and Commission proposal. Not yet adopted.

If your product range includes long-wear make-up, waterproof formats, or any formulation using fluorinated ingredients, the time to start the supplier conversation is now — not September.

At Cláritas Regulatory, we help indie brands map their PFAS exposure across their full product portfolio and understand what the October 2026 deadline — and the French market’s existing ban — means in practice. If you’d like to understand your compliance position, get in touch.