Explore FDA GRAS Rule 2026 updates, key compliance changes, and the shift toward transparency. Learn how it impacts food ingredients and GRAS submissions.
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PFAS in Cosmetics are being banned worldwide. Explore health risks, environmental impact, and global regulations driving the shift to PFAS-free beauty products.
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PFAS in Cosmetics: Why a Global Regulatory Shift Is Redefining the Beauty Industry
The beauty industry is undergoing a significant global transformation. Across the United States, multiple states are moving to restrict or ban PFAS (Per- and Polyfluoroalkyl Substances)—commonly known as “forever chemicals”—from cosmetic products. In parallel, Japan has implemented a major regulatory measure under its Chemical Substances Control Law (CSCL), banning 138 PFAS in cosmetics effective January 10, 2025. The regulation prohibits the manufacture, import, and use of these substances in cosmetic formulations, except where specific exemptions apply.
As consumer expectations evolve toward cleaner and safer beauty products, regulators are increasingly targeting ingredients associated with long-term environmental persistence and potential health risks. This raises a critical question: why are PFAS being systematically phased out of cosmetics globally?
Understanding the Concern: Why PFAS Are Used—and Why They’re Controversial
PFAS comprise a large class of more than 10,000 synthetic chemicals valued for their exceptional resistance to water, oil, and heat. These properties have made them widely used in long-wear cosmetics such as foundations, mascaras, lipsticks, and other “smudge-proof” formulations.
However, the same chemical stability that makes PFAS useful also makes them highly problematic. Their strong carbon-fluorine bonds prevent them from breaking down easily in nature or in the human body, leading to persistence in the environment and potential accumulation over time.
Research has associated PFAS exposure with several health concerns, including:
• Immune system disruption
• Hormonal imbalance
• Increased risk of certain cancers
Because exposure can build up cumulatively, repeated use of PFAS-containing cosmetics raises concerns about long-term internal exposure.
Regulatory Action Is Accelerating Worldwide
Regulatory bodies are increasingly taking proactive steps to limit or eliminate PFAS in cosmetics. In the United States, several states—including Connecticut, Maine, and Vermont—are introducing phased restrictions beginning in 2026.
These measures include:
• Full or partial bans on cosmetics containing intentionally added PFAS
• Mandatory reporting requirements for manufacturers
• Labeling requirements to disclose PFAS presence in products
Some jurisdictions are focusing on transparency, while others are moving toward outright prohibitions. Together, these approaches are driving rapid reformulation across the cosmetics industry.
This regulatory momentum is not limited to beauty products. PFAS restrictions are also expanding into cookware, textiles, and children’s products. However, cosmetics remain a key focus due to their direct and frequent application to sensitive areas such as the skin, lips, and eyes.
Why the Shift Toward PFAS-Free Beauty Matters
The global movement to eliminate PFAS from cosmetics is driven by two core priorities: protecting human health and reducing environmental persistence.
For manufacturers, this shift creates both a challenge and an opportunity—to innovate with safer, high-performance alternatives that do not rely on persistent synthetic chemicals.
For consumers, PFAS-free beauty offers:
• Greater transparency in product ingredients
• Reduced long-term exposure risk
• Increased trust in cosmetic safety standards
Conclusion: A Structural Shift in Beauty Compliance
The tightening global regulatory landscape signals a broader structural change in the cosmetics industry. PFAS are being phased out not only because of their persistence, but because safer alternatives and better scientific understanding now make their use less justifiable.
As regulations evolve, compliance is becoming inseparable from innovation. Companies that anticipate these changes and adapt early will be better positioned to maintain market access and consumer trust in an increasingly regulated environment.
The transition toward PFAS-free beauty is not just a regulatory requirement—it is a long-term shift toward safer, more transparent, and more sustainable product development.
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PFAS in Cosmetics: Uses, Risks, and Regulatory Impact
Per- and polyfluoroalkyl substances (PFAS) are a large group of over 10,000 synthetic chemicals known for their resistance to water, oil, and heat. Their unique properties come from strong carbon–fluorine bonds, which also make them highly persistent in the environment—earning them the term “forever chemicals.”
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Why PFAS Are Used in Cosmetics
In the cosmetics industry, PFAS are valued for enhancing product performance. They help formulations become:
• Long-lasting
• Smooth and easily spreadable
• Resistant to smudging, oil, and moisture
According to the U.S. FDA’s MoCRA-mandated report, PFAS are most commonly found in:
• Eye shadows
• Eyeliners
• Mascaras
• Foundations
• Face powders
• Leave-on facial products
These substances improve texture, conditioning, and wear time—making them particularly useful in high-performance cosmetic products.
Common PFAS used in cosmetics include PTFE and other fluorinated compounds that create silky finishes or form protective films on the skin. FDA data shows that 51 intentionally added PFAS are used across 1,744 cosmetic formulations, representing approximately 0.41% (as of August 2024) of all registered cosmetic products—indicating targeted use rather than widespread application.
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Why PFAS Raise Concerns
Despite their benefits, PFAS are under increasing scrutiny due to:
• Environmental persistence
• Bioaccumulation potential
• Widespread presence in water, soil, and ecosystems
Scientific studies have linked certain PFAS to potential health risks, including:
• Immune system effects
• Endocrine disruption
• Increased cancer risk
However, significant data gaps remain. The FDA notes that toxicological data is incomplete for 76% of commonly used cosmetic PFAS, highlighting uncertainty and the likelihood of future regulatory action. Currently, only a small number of PFAS are classified as having “low safety concern” under intended cosmetic use conditions.
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Regulatory Landscape and Industry Implications
Regulatory pressure on PFAS is rapidly increasing:
• Several U.S. states have introduced bans or reporting requirements for intentionally added PFAS
• Global regulators are evaluating broader restrictions across industries
• Demand for ingredient transparency is growing
For cosmetic companies, this means:
• Reassessing formulations for PFAS content
• Strengthening supplier transparency and traceability
• Preparing for evolving compliance obligations
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Why This Matters for Cosmetic Brands
Understanding PFAS—what they are, how they function, and their risks—is essential for navigating today’s evolving regulatory landscape.
As “clean beauty” expectations rise and regulations tighten, brands must take proactive steps to:
• Reformulate products where necessary
• Ensure regulatory compliance
• Communicate risks effectively
• Protect brand reputation
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Conclusion
PFAS provide clear performance benefits in cosmetics, but their persistence and potential health impacts are driving increased regulatory scrutiny.
Forward-thinking organizations are already taking action to reduce PFAS reliance, address data gaps, and align with emerging global standards—ensuring long-term compliance and consumer trust.
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How Freyr Can Support
Freyr offers end-to-end regulatory support to help cosmetic companies stay ahead, including:
• PFAS assessments and risk evaluation
• Reformulation strategies
• MoCRA compliance support
• U.S. state-level and global regulatory reporting
Partner with Freyr to navigate PFAS regulations confidently and lead in the evolving clean beauty landscape.
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SDS Update Triggers: Ensuring Accuracy, Compliance, and Safety
A Safety Data Sheet (SDS) is not a static document—it must evolve as new information becomes available. This is where SDS update triggers play a vital role.
An SDS update trigger is any event, change, or new information that requires reviewing and updating an SDS to ensure it remains accurate, compliant, and reliable.
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Definition: SDS Update Trigger
An SDS update trigger refers to a specific condition that signals the need to revise an SDS so that it reflects the most current:
• Hazard information
• Chemical composition
• Regulatory requirements
• Safety and handling instructions
These triggers are defined by global regulations and industry best practices.
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Why Are SDS Update Triggers Important?
SDS update triggers ensure that:
• Workers receive accurate and up-to-date hazard information
• Organizations remain compliant with global regulations
• Supply chain partners rely on correct safety data
• Emergency responders have current and reliable guidance
Without clearly defined triggers, SDSs can quickly become outdated—leading to safety risks and compliance gaps.
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Key SDS Update Triggers
1. Changes in Chemical Composition
Any modification in formulation, such as:
• Addition or removal of ingredients
• Changes in concentration levels
These changes can directly impact hazard classification and require an SDS update.
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2. New Hazard or Toxicological Data
When new scientific data becomes available, including:
• Updated toxicity studies
• Newly identified health or environmental hazards
The SDS must be revised to reflect the latest findings.
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3. Regulatory Updates
Changes in global or regional regulations often trigger SDS updates, such as:
• Updates to GHS classification criteria
• Revisions under OSHA Hazard Communication requirements
• EU REACH requirements or CLP Adaptations to Technical Progress (ATPs)
These changes may affect:
• Hazard classifications
• Label elements
• Exposure limits
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4. Changes in Risk Management Measures
Updates to safety practices, including:
• Personal Protective Equipment (PPE) recommendations
• Safe handling, storage, or disposal practices
must be incorporated into the SDS to ensure safe use.
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5. New Exposure Scenarios or Uses
If a product is used in new applications or industries, the SDS may need to be updated to include:
• New exposure scenarios
• Revised safety precautions
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6. Supplier or Raw Material Changes
Changes in suppliers or raw material specifications can introduce:
• New impurities
• Altered hazard profiles
This requires SDS reassessment and potential updates.
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7. Identified Errors or Inconsistencies
Any inaccuracies in the SDS—such as:
• Incorrect classifications
• Missing data
• Mismatch with labels
must be corrected promptly.
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When Should an SDS Be Updated?
Regulatory frameworks mandate timely updates whenever new information becomes available:
• EU REACH: SDSs must be updated without delay when new hazard or risk information is identified
• OSHA Hazard Communication Standard: SDSs must be updated within 90 days of new hazard information
Updated SDSs must also be communicated to downstream users, typically those who received the product within the past 12 months.
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Best Practices for Managing SDS Update Triggers
To effectively manage SDS updates, organizations should:
• Establish clear internal trigger criteria
• Integrate SDS updates into change management processes
• Use digital systems for version control and tracking
• Continuously monitor regulatory developments
• Maintain strong communication with suppliers and customers
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Conclusion
SDS update triggers are more than just a compliance requirement—they are a critical mechanism for maintaining safety, accuracy, and trust across the chemical value chain.
By proactively identifying and responding to these triggers, organizations can ensure their SDSs remain accurate, relevant, and aligned with global standards—minimizing risks and strengthening compliance.
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How Freyr Can Help
Freyr supports organizations with end-to-end SDS regulatory compliance services, including:
• SDS authoring and updates
• Regulatory monitoring and impact assessment
• Change management integration
• Global compliance support
Partner with Freyr to stay ahead of SDS update requirements and prevent compliance gaps and safety risks.
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