Environmental Forensic Investigation of PFAS in Consumer Cosmetic Products and Dermal Exposure Assessment
Project Overview
RoseyFields conducted an environmental forensic investigation evaluating the occurrence of per- and polyfluoroalkyl substances (PFAS) in consumer cosmetic and personal care products marketed with health, safety, clean beauty, or skin protection claims. The project combined laboratory analytical testing, product ingredient evaluations, regulatory review, toxicological literature review, and exposure assessment to determine whether products advertised as safe or beneficial contained intentionally added PFAS compounds or PFAS-related contaminants. The investigation further evaluated whether dermal exposure from these products could represent a meaningful pathway for human PFAS exposure and how existing scientific literature compares dermal exposure with established drinking water exposure guidance.
The project focused on nationally recognized cosmetic and personal care manufacturers whose products or corporate messaging emphasized health, safety, ingredient quality, or consumer protection. Product categories included facial moisturizers, foundations, pressed powders, mascaras, eye shadows, sunscreens, shaving products, lotions, and anti-aging skincare formulations. In addition to evaluating ingredient disclosures, the investigation compared analytical laboratory results with published toxicological studies and evolving federal and state PFAS regulations to better understand potential exposure risks associated with everyday consumer products.
A significant objective of the investigation was to evaluate whether cosmetic products containing fluorinated ingredients or PFAS-related compounds could contribute to chronic PFAS exposure despite the absence of comprehensive federal regulations governing PFAS in cosmetics. The project integrated environmental chemistry, exposure science, toxicology, analytical chemistry, regulatory review, and environmental forensic analysis to evaluate contaminant occurrence, exposure pathways, and the consistency between product marketing claims and chemical composition.
Chemicals of Concern
The investigation focused on per- and polyfluoroalkyl substances (PFAS), a large class of persistent synthetic fluorinated compounds widely used for their water resistance, oil repellency, durability, and chemical stability. Particular emphasis was placed on compounds identified through analytical testing and ingredient review, including perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHxS), perfluorononanoic acid (PFNA), perfluorobutanoic acid (PFBS), perfluorohexanoic acid (PFHxA), GenX (HFPO-DA), fluorotelomer compounds, perfluorononyl dimethicone, perfluorodecalin, perfluorohexane, and polytetrafluoroethylene (PTFE). The investigation also evaluated fluorinated ingredients capable of acting as precursor compounds that may degrade into more persistent PFAS species during manufacturing, product use, or environmental degradation.
Because many PFAS compounds are not routinely disclosed on cosmetic ingredient labels or may be present as manufacturing impurities, the project considered both intentionally added fluorinated ingredients and analytically detected PFAS compounds identified through laboratory testing. The investigation also evaluated published toxicological literature regarding dermal absorption, systemic bioavailability, immunotoxicity, and human health effects associated with repeated PFAS exposure.
Methods
RoseyFields developed a structured product evaluation methodology to identify consumer products with frequent skin, eye, or mouth contact that also contained fluorinated ingredients or were marketed using health and safety claims. Products were screened using publicly available ingredient databases, manufacturer ingredient disclosures, and product formulation information before being selected for laboratory analysis. Particular attention was given to products containing PTFE, perfluorononyl dimethicone, perfluorodecalin, and perfluorohexane because of their widespread use in cosmetic formulations and their association with PFAS chemistry.
Representative products from major cosmetic manufacturers were purchased using contamination control procedures designed to minimize cross-contamination during handling. Products were photographed, documented, reviewed for ingredient composition, assigned study identification numbers, and submitted under documented chain-of-custody procedures for laboratory analysis of multiple PFAS compounds. Chain-of-custody documentation was maintained throughout sample collection, shipment, and laboratory receipt to ensure analytical integrity.
Analytical results were integrated with an extensive review of published toxicological studies evaluating dermal absorption, skin penetration, immunotoxicity, bioaccumulation, and systemic uptake of PFAS compounds. Existing federal guidance, EPA drinking water health advisories, FDA statements regarding PFAS in cosmetics, and state regulatory standards were evaluated to establish scientifically supported comparison values for interpreting measured concentrations. Because no federal dermal exposure standards currently exist for PFAS in cosmetics, the investigation compared estimated dermal exposure doses with available drinking water health-based guidance and published toxicological studies.
The investigation also reviewed corporate marketing materials and public statements emphasizing product safety, healthy ingredients, clean beauty, and consumer protection. These statements were evaluated alongside laboratory analytical results and ingredient disclosures to assess consistency between product marketing and chemical composition.
Results
The investigation demonstrated that PFAS-related compounds and fluorinated ingredients were identified in numerous cosmetic and personal care products manufactured by nationally recognized consumer brands. Frequently identified fluorinated ingredients included PTFE, perfluorononyl dimethicone, perfluorodecalin, and perfluorohexane, all of which are used to improve water resistance, durability, texture, or product performance. Cosmetic categories with repeated identification of fluorinated ingredients included foundations, pressed powders, mascaras, eye shadows, sunscreens, moisturizers, anti-aging creams, and shaving products.
Laboratory analytical testing identified multiple PFAS compounds in sampled cosmetic products, including detections of PFOA, PFNA, PFHxA, PFBS, and other PFAS analytes. Exposure comparisons performed during the investigation indicated that estimated daily dermal exposure from certain cosmetic products substantially exceeded equivalent daily exposure associated with existing drinking water health advisory concentrations for several PFAS compounds. Although drinking water standards are not intended to regulate cosmetic exposure, these comparisons provided a useful health-based benchmark in the absence of established dermal exposure criteria.
The regulatory review further determined that no comprehensive federal regulations currently govern PFAS concentrations in cosmetic products, despite increasing scientific evidence demonstrating dermal absorption potential, systemic bioaccumulation, and adverse human health effects associated with PFAS exposure. Federal agencies have acknowledged the need for additional research regarding PFAS absorption through the skin, while regulatory efforts have primarily focused on drinking water rather than consumer product exposure.
The investigation also found that many cosmetic manufacturers publicly promote product safety, ingredient quality, skin health, or clean beauty while marketing products containing fluorinated ingredients associated with PFAS chemistry. Several fluorinated ingredients commonly identified in cosmetic formulations may also serve as precursor compounds capable of degrading into more persistent PFAS species or may contain residual manufacturing contaminants such as PFOA. These findings highlight the complexity of evaluating PFAS exposure from consumer products using ingredient labels alone.
Conclusions
This investigation demonstrates that consumer cosmetic and personal care products represent a potentially important pathway for chronic PFAS exposure through repeated dermal contact. While current regulatory efforts have largely focused on drinking water contamination, the investigation highlights the need to consider consumer products as an additional source of cumulative PFAS exposure. The absence of comprehensive federal regulations governing PFAS in cosmetics underscores the importance of integrating analytical chemistry, toxicology, exposure assessment, and regulatory science when evaluating potential health risks associated with these products.
The project further demonstrates the value of combining laboratory analytical testing with ingredient review, toxicological literature, regulatory guidance, and environmental forensic analysis to evaluate PFAS occurrence in consumer products. By integrating chain-of-custody documentation, analytical laboratory methods, published scientific studies, and product marketing evaluations, RoseyFields reconstructed the relationship between product formulation, PFAS occurrence, dermal exposure potential, and evolving regulatory standards.
This investigation was conducted under the direction of Dr. Paul Rosenfeld, an environmental scientist and environmental forensic expert with extensive experience in PFAS occurrence, contaminant fate and transport, exposure assessment, consumer product investigations, regulatory analysis, and environmental litigation. Through RoseyFields LLC, Dr. Rosenfeld provides technical evaluation of PFAS-containing consumer products, source identification, environmental exposure assessment, regulatory review, human health risk evaluation, and expert witness services involving emerging contaminants and complex environmental exposures.
References
Abraham, K., et al. (2022). Study of PFOA absorption in human skin.
Franko, J., et al. (2011). PFOA Penetration Potential.
Shane, H., et al. (2020). PFOA Immunotoxicity Summary.
U.S. Environmental Protection Agency. PFAS Strategic Roadmap: EPA’s Commitments to Action 2021–2024.
U.S. Environmental Protection Agency. Technical Fact Sheet: Drinking Water Health Advisories for PFOA, PFOS, GenX Chemicals, and PFBS (2022).
U.S. Food and Drug Administration. Per- and Polyfluoroalkyl Substances (PFAS) in Cosmetics.
Whitehead, H. D., et al. (2021). Fluorinated Compounds in North American Cosmetics. Environmental Science & Technology Letters.
Environmental Working Group (EWG). Skin Deep® Cosmetics Database.
RoseyFields Environmental. PFAS Product Analysis: Dermal Absorption Regulations & Scientific Studies.
RoseyFields Environmental. PFAS Product Analysis Methodology.
RoseyFields Environmental. PFAS Cosmetics Notes.