Declared versus actual presence of PFAS in cosmetic products: an INCI list analysis and critical appraisal of current regulatory frameworks

Abstract

Per- and polyfluoroalkyl substances (PFAS) are a family of over 10,000 synthetic fluorinated compounds whose persistence, bioaccumulation, and adverse health effects have placed them at the forefront of public health concerns. In cosmetics, PFAS serve multiple functional roles and are prevalent in long-wearing, water-resistant formulations, and regulatory frameworks have tightened worldwide, targeting intentionally added PFAS through defined substance lists. Yet their actual presence remains difficult to assess: declared INCI lists suggest limited use, while analytical studies detect fluorinated compounds far exceeding labeling data. We applied a keyword-based analysis to INCI ingredient lists of 1233 cosmetic and personal care products (500 makeup, 111 oral care, 622 other). We find that 19.0% of products declare at least one fluorine-containing ingredient, yet only 0.9% declare an ingredient meeting the OECD/UNEP definition of a PFAS. Ingredient-level classification shows that this gap is not evidence of concealed PFAS: almost all declared fluorine has no carbon-fluorine bond, being synthetic fluorphlogopite (134 products) or a dental fluoride salt (88). The declaration of fluorine is strongly structured by product type, from 73.0% in oral care and 28.2% in makeup to 1.9% across all other personal care products (\(\varvec{\chi }^{\varvec{2}}\varvec{(2)=355.7}\), \(\varvec{p}\varvec{<}\varvec{0.001}\)). Analytical methods for total versus specific PFAS are also compared. Deliberate use of PFAS as functional ingredients thus appears uncommon in finished formulations, and the organofluorine reported by analytical surveys likely enters through process water, manufacturing equipment or treated raw materials, routes that frameworks keyed to intentional addition do not reach.