PFAS are anthropogenic chemicals with approximately several thousand different structures, all of which share a common carbon-fluorine bond. The C-F bond is extremely strong, which makes nearly all PFAS persistent or only degradable to other different persistent PFAS. Some PFAS have been shown to be bioaccumulative and some could be related to health effects, such as different kinds of cancer, liver, and cholesterol effects, reproductive and other hormonal effects.
This study started off as a contracted assignment by the Swedish Chemicals Agency (KEMI) to gather data on the occurrence and emissions of PFAS from cosmetics as part of their preparatory work on the broad PFAS restriction proposal under REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). The scientific publication was done independently of KEMI.
— We have shared the work among our two organisations, we planned and conducted the sampling and the experimental design together, Shahla Namazkar, PhD student in the Department of Environmental Science at Stockholm University, and Kerstin Pütz, environmental researcher, consultant, and project leader at IVL Swedish Environmental Research Institute, say. They continue:
— We worked towards providing an overview of the occurrence of PFAS in cosmetic products on the EEA market, including PFAS structures, functions, product shares, and market trends. Secondly, we quantified PFAS concentrations in products available on the Swedish market and evaluated the use of different analytical methods. Based on all information gathered and assumptions made, we calculated the total emissions of PFAS after the use of cosmetics within the EEA region, which makes this study the first of its kind.
What was the most challenging when creating it?
— From a chemical analysis perspective, that cosmetic products listed a diverse range of PFAS structures that were not possible to quantify using common extraction or quantification methods, says Namazkar. In addition to this, some cosmetics contained a mixture of PFAS ingredients, making them analytically difficult to determine. Another challenge was the, by several orders of magnitude, varying concentrations between the listed PFAS ingredients and the PFAS impurities in cosmetic samples.
— Sampling for products containing PFASs for our chemical analysis was time consuming and challenging. We identified about 170 PFAS ingredients among the ingredient database, CosIng, of the European Commission, which can potentially occur in cosmetics. Ingredient names are not easily identifiable as PFAS, as names did partly not even contain ’polyfluoro’ or ’perfluoro’, Pütz explains.
— For several products, she continues, it is also questionable how well companies comply to the labelling requirement of cosmetics within the cosmetics regulation, when ingredient list prints were having font sizes smaller than one can read, or were covered by barcodes, theft alarm stickers, or sterility or hygiene banderols.
A big challenge, according to Pütz, was to gather all information that were needed to calculate the emissions.
— We learned that no one, including cosmetic associations and agencies, seemed to know the production volumes or amounts of cosmetics. We had to make several assumptions and consult other data to deduct the production volume, which is of course a key parametre to calculate emissions. This could be made more transparent in future.
The most surprising part? The huge variety of PFASs that occurred in the products, ranging from polymers to highly volatile neutral substances, to water soluble acids.
— Their chemical properties are very divers, which makes PFASs and their behaviour and potential risks extremely hard to predict. We were also surprised to find some of the already banned PFASs exceeding European limits, the duo say.
How big of a problem is it in the beauty industry? And what are the reasons for using it?
— PFASs are intentionally used in cosmetics products, for instance as conditioners, film formers, solvents, surfactants or emulsifiers, viscosity controllers, and stabilizers, Namazkar and Pütz explain. Our analysis showed that 1.4% of the cosmetic products in the CosmEthics database contained PFAS, which was very similar to the 1.3% among the current cosmetic products in the Kemiluppen database. This indicates that using PFAS in cosmetics is non-essential, as the majority does not contain PFAS and can be replaced with other chemicals.
— PFAS is mostly used as in ingredient in decorative cosmetics (3.67% of the products), followed by skincare, haircare and toiletries products — 0.78%, 0.65% and 0.27% respectively — according to our market share analysis among the CosmEthics database.
— In our sampling campaign, we found products listing PFAS as an ingredient in the entire price range. Purchasing costlier products does certainly not guarantee for a PFAS free product. PFAS also occurs as residuals, or unintentional ingredients, in cosmetics.
Are they more common in certain markets?
— Our study focus was the products’ availability on and PFAS release from the EEA market, says Pütz. For our investigations, we also consulted the CosmEthics database, which claims to be the biggest machine-readable cosmetic ingredient database worldwide and, back then, had more than 300.000 EU users. The product scanning hit rate at times was approximately 77% from within the EU, according to CosmEthics.
— Among other data, we even considered the country code from the barcode, which indicates where the cosmetic manufacturer is registered. We could see a higher share of cosmetic products containing PFAS (1.9%) for non-EU/EEA registered manufactures compared to 1.1% for EU/EEA country registered manufactures. All products that we bought for chemical analysis to determine PFAS concentrations were purchased at Swedish retail stores. We did not chemically analyse or investigate any products from the free online market — it would be interesting to see which kinds of PFASs and concentrations one would find in these products.
You mentioned it but what can we replace PFAS with?
— Yes, in cosmetics, PFASs are replaceable, which we can say due to the sheer fact that most cosmetics throughout all cosmetic categories are PFAS free, the duo say. This is based on our searches within the CosmEthics database, in which 1.4% of all the products contained PFAS, considering the INCI names identified as such. The replacement would require a reformulation of the products. There might be a whole range of ingredients that could replace PFAS as ingredients and it depends on its intended function in the product, which can be various.
How has the feedback on the report been after publishing?
— Positive, both after the KEMI report that we authored and our scientific article. Our study was used as part of the scientific background within the restriction proposal for PFAS in cosmetics, Pütz shares, continuing,
— In January this year, a broad PFAS restriction proposal including around 10.000 PFASs was submitted by the Danish, Dutch, German, Norwegian, and Swedish authorities for consideration by the European Chemicals Agency (ECHA). Currently, the proposal is open for a six months public consultation and scientific evaluation, which ends at the end of September. Thereafter, ECHA’s scientific committee will prepare their opinion documents that will be send to the European Commission for decision.
— The major concern and reason for PFASs to be restricted is their persistence, which leads to constantly increasing concentrations in the environment that eventually pose a risk to human and environmental health.
And what about the industry players? Kerstin Pütz also explains that the research team has been in contact with a cosmetics producer, that was interviewed for the report.
— Several beauty brands are working or at least claim to work on PFAS-free cosmetic products. According to information from the Swedish Society for Nature Conservation (SSNC), among these were 57 different brands of nine different companies.
— Generally, I feel that all industry sectors are alert and knew about the preparatory work that several EU countries conducted to gather the information for the broad PFAS restriction proposal dossier. Risking being overly clear here, the proposal comprises several more sectors than cosmetics only. Further, the public awareness about PFAS increases, which puts pressure on the brands and producers as well to work towards PFAS-free products.
Pütz explains that her general recommendation is to use as little cosmetics as possible.
— The reason is, that it is even hard for me to tell by the ingredient name if something is PFAS or not unless I consult my INCI list, as the ingredient names not necessarily contain perfluoro or polyfluoro.
— Generally, we should feel safe, as we, with the EU chemicals regulation REACH, certainly have among the strongest chemical’s legislation worldwide, if not the strongest. However, chemicals and their human and environmental health risks have to be constantly reconsidered with increasing knowledge and research data. Therefore, chemicals might become restricted after a while when closing the data gaps. That is how the current REACH process works.
— I am not as familiar with the cosmetic products regulation, but an update of the cosmetic product safety report is also required in case of new relevant knowledge, even after a product has been placed on the market. Cosmetics sold on the EU market certainly must not contain chemicals that are prohibited in the cosmetics regulation. Generally, the EU cosmetics legislation prohibits the use of substances that are carcinogenic, mutagenic or reproduction toxic, although it has exceptional cases.
— The legislation and regulations themselves might change and will improve over time as well. Currently, as part of the EU chemicals strategy for sustainability, the cometic products regulation is under revision to better protect environmental and human health. I am in favour of this, as the current cosmetics regulation does not take environmental impacts into account at all, but rather relies on chemicals with environmental hazards to be restricted under REACH. Further, the control of products obeying existing regulations could be improved.
— The markets that are not necessarily as safe are the online market and the out-side EU market, where our EU regulations can be bypassed or simply do not apply. As a consumer, you should trust that the experts and regulations do their job. They cannot foresee the amount, number, and kind of products one applies though, because consumer behaviour is very different. Generally, it applies that the more you consume the more chemicals you are exposed to and the bigger is your impact on the environment. So, to me personally, moderation is the key rather than complete avoidance, Pütz concludes.
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