Expert laboratory testing for PFAS in cosmetics, including short-chain PFAS such as trifluoroacetic acid (TFA), supporting product development, quality and safety.
PFAS in cosmetics are gaining more focus due to their potential health risks. PFAS are a range of chemicals known for their exceptional stability and water-repellent properties due to strong carbon-fluorine bonds. These characteristics have made them ideal ingredients for use in various consumer products, including cosmetics, where they serve as emulsifiers, stabilizers, and texture enhancers.
Among PFAS, short-chain substances such as trifluoroacetic acid (TFA) are of increasing concern. TFA can be formed as a by-product of industrial processes and may be present in cosmetic raw materials, particularly synthetic peptides, as a residual counter-ion after solid-phase peptide synthesis. Although not intentionally added to finished cosmetic products, trace levels of TFA can remain in ingredients and formulations, contributing to overall PFAS exposure.
Regulatory Developments on PFAS and TFA in Cosmetics
Europe: The European Chemicals Agency (ECHA) is actively pursuing comprehensive restrictions on PFAS, including in cosmetics. France has already enacted stringent regulations banning PFAS in cosmetics effective from 2026, setting a precedent for broader EU-wide measures expected in the coming years.
USA: The Modernisation of Cosmetics Regulation Act of 2022 empowers the FDA to evaluate the safety of PFAS in cosmetics thoroughly. By December 2025, it is expected that the FDA will publish a safety assessment report on PFAS, enhancing regulatory oversight and consumer protection.
In addition to broad PFAS restrictions, regulatory attention is increasingly turning to specific short-chain PFAS such as trifluoroacetic acid (TFA). Evolving regulations in the United States, the European Union, and other regions underscore the importance of detecting the presence of TFA in peptide raw materials and finished cosmetic products.
The European Chemicals Agency (ECHA) has proposed classifying TFA as a substance toxic for reproduction (CLP / Reprotoxic Category 1B), and European authorities are considering tightening controls on PFAS sources that may generate TFA. If TFA is ultimately classified as a CMR (reprotoxic) substance, this would have a direct impact on the cosmetics sector, as Regulation (EC) No. 1223/2009 prohibits the use of certain CMR substances in cosmetic products.
Focus on Trifluoroacetic Acid (TFA) in Peptide-Based Ingredients
Peptides are increasingly used in cosmetic products for anti-ageing, skin barrier repair, hydration and brightening benefits. Many of these ingredients are manufactured using solid-phase peptide synthesis (SPPS), where the peptide chain is built on a resin and later cleaved using trifluoroacetic acid (TFA).
As a result, TFA may be present as a residual impurity in peptide raw materials (solutions, powders, complex matrices) and, consequently, in finished cosmetic formulations. TFA is a strong acid and a persistent environmental contaminant belonging to the PFAS family, and its potential classification in Europe as a reprotoxic substance (CLP / Reprotox Category 1B) is attracting regulatory attention.
For cosmetic brands and ingredient manufacturers, it is therefore essential to:
- Screen peptide raw materials and finished products for residual TFA
- Assess regulatory compliance in light of evolving PFAS and CMR restrictions
- Manage supplier and process risk, particularly for biotech and peptide-based innovations
Testing and Screening for PFAS in Cosmetics
We use sensitive analytical techniques such as Liquid Chromatography with Tandem Mass Spectrometry (LC-MS/MS) to detect PFAS in cosmetics. These methods offer high precision and sensitivity, detecting PFAS at concentrations as low as parts per billion (ppb), or lower depending on sample matrix. Our scientists are experienced in screening, identification and determination of levels of PFAS even though complex sample matrices can present challenges to analytical methods.
For short-chain PFAS such as TFA, specific analytical strategies are required due to their high polarity and very low expected levels. Intertek laboratories, including our LaCoMeD laboratory in France, have developed robust LC-MS/MS methods to:
- Detect TFA in peptide raw materials, process water and finished products
- Achieve trace-level quantification in the low ppb range
- Adapt sample preparation to complex cosmetic matrices (solutions, glycerine bases, powders, etc.)
These targeted methods provide reliable data to:
- Demonstrate regulatory compliance with PFAS and potential CMR restrictions
- Support cosmetic product safety assessments
- Document supplier control and process optimization for peptide-based cosmetics.
The regulation of PFAS in cosmetics marks a pivotal step towards mitigating environmental contamination and safeguarding public health. Ongoing efforts in Europe and the USA underscore a global commitment to reducing PFAS exposure through stringent regulatory frameworks and advanced analytical methodologies. Given the diversity of PFAS compounds and their potential presence as impurities, including residual TFA in biotech or peptide ingredients, understanding the risks associated with PFAS in cosmetics will become increasingly important and meeting evolving regulatory restrictions will be critical to compliant and safe products.
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