As most cosmetic chemists know, per- and polyfluoroalkyl substances (PFAS) are a diverse group of human-made chemicals to which consumers are widely exposed. Applications range from cosmetics and personal care products (e.g., lipstick, moisturizers, nail polish, hair conditioner, etc.) to firefighting foams, water-resistant fabrics, food packaging and more. These materials have raised concern due to their slow (if any) ability to biodegrade and subsequent accumulation in the environment and individuals. While scientists are still learning about their potential effects, only certain PFAS have been linked to health issues. Still, the presence of any PFAS, period, has alarmed consumers and regulators — and two recent studies have made headlines.
Personal Care Product Use and PFAS Levels in Pregnant, Lactating Individuals
A study published in Environmental International investigated associations between personal care product use and PFAS concentrations in prenatal plasma (6 to 13 weeks’ gestation; n = 1,940) and human milk (2 to 10 weeks’ postpartum; n = 664). Participants (n = 2,001) were enrolled from 10 cities across Canada between 2008 and 2011. They reported their use of eight different personal care product types during the 1st and 3rd trimesters, 1 to 2 days postpartum, and 2 to 10 weeks’ postpartum. The eight product categories included: fragrances/perfumes, makeup, hair dyes, hair sprays, hair gels, nail care products, lotions and moisturizers.
The laboratories measured:
- PFOS, PFOA and PFHxS in plasma and
- n-PFOS (linear isomer), Sm-PFOS (branched isomer), PFOA, PFHxS, PFNA, PFBA and PFHxA in human milk.
In the first trimester, individuals who more frequently used nail care products, fragrances, makeup, hair dyes and hair sprays or gels had significantly higher plasma PFAS concentrations. Results were similar for the third trimester and breast-milk PFAS concentrations at 2 to 10 weeks postpartum. See the full open access article for each PFAS identified and its percentage in the given product types.
“While PFAS are ubiquitous in the environment, our study indicates that personal care products are a modifiable source of PFAS,” stated study co-author Amber Hall, a postdoctoral research associate in epidemiology at the Brown University School of Public Health, in a university news post. “People who are concerned about their level of exposure to these chemicals during pregnancy or while breastfeeding may benefit from cutting back on personal care products during those times.”
Hall noted that the study examined only four types of PFAS among thousands that are used in industry and commerce.
PFAS Levels in Young Adults and Sleep Disruption, Plus the Identification of Sleep-related Genes
Another study, published in Environmental Advances, investigated potential associations between PFAS levels in young adults and disrupted sleep — a critical component of health. Between 2014 and 2018, 136 young adults were assessed, 76 of whom were re-assessed between 2020 and 2022. Subjects' plasma was evaluated for eight PFAS: PFDA, PFHpS, PFHxS, PFNA, PFOA, PFOS and PFPeS, as well as a PFAS mixture. Sleep duration was self-reported at both visits, along with sleep disturbances and sleep-related impairments, which were validated instrumentally.
Results indicated:
- PFDA, PFOA and PFHxS were associated with shorter sleep duration and
- PFOS was associated with higher sleep disturbances and sleep-related impairment.
Following this, computational toxicology and mediation analyses identified genes associated with sleep-wake disorder and PFAS. The involvement of metabolic and immune-related proteins was confirmed, per the article abstract. (Read the full open access article here.)
"The scientists are the first to delve into underlying molecular mechanisms, identifying genes involved with the body’s natural defenses and a hormone that regulates sleep," the University of Southern California website reported.
Notably, this study was not focused on PFAS from a given source like personal care products. It was generalized to all sources. But if history has taught the beauty industry anything, it's that consumers assume guilt by association. So whether it's a short or long chain PFAS, it's still a PFAS.
PFAS vs. Sleep: Study Inconsistencies?
Considering the association between given PFAS and sleep disruption and their presence in personal care, we asked industry expert Karen Yarussi-King, president of Global Regulatory Associates, to weigh in on these findings. She observed some inconsistencies.
"... I think it is a bit skewed. The baseline studied 136 19-year-olds selected (2014-2018) from another study. These 19-year-olds were participants in this other study when they were 13-14 years old, and were selected based on having a history of being overweight or obese (defined as age- and sex-specific BMI > 85th percentile; BMI was obtained between age 14 and 15), and free of diabetes. Two years later, they looked at 76 of the participants who were now around 24-year-olds. Many began using alcohol and smoked, and 58% of the 76 follow-up participants were Hispanic.
"They contradict themselves by saying that marginalized populations are more susceptible, yet the highest levels of the four PFAS that were found that 'impact sleep' were in the white participants. The initial study also had 55% men but the follow-up had 64% women. I could not find data that showed the levels in each group.
"Interestingly, when they looked at data on the population in general, they found these results [as reported in the article Discussion section]:"
Conversely, a recent study using data from NHANES [U.S. National Health and Nutrition Examination Surveys] spanning from 2005 to 2014 did not identify any association between PFAS and sleep health. It even revealed an inverse association between PFAS mixtures and sleep disorders (Guo et al., 2023).
These findings contradicted those of another study conducted by Shiue et al. using NHANES data, which identified specific PFAS such as 2-(N-methyl perfluorooctane sulfonamido) acetate (MeFOSA) and perfluorobutanesulfonic acid (PFBS) as being associated with worse sleep outcomes (Shiue, 2017).
Given that the NHANES study population represents the general U.S. population, with a median age of approximately 45 years, it is plausible that the effects of PFAS on sleep outcomes may not be as evident as in historically marginalized populations. Our study, conducted in young adults, aligns with the findings in pregnant women, infants and children (Choi et al., 2024; Huang et al., 2023, 2022; Xie et al., 2022).
Yarussi-King continued, "I feel like they had a number of things that they could not hold constant — for example, did the subjects lose sleep because of school stresses, did they lose sleep because they had a fight with the girl/boyfriend, were they out partying, did they have mental issues that they struggled with..., etc. This was all based on a basic questionnaire. ...Lastly, they did not look at cosmetics versus food versus water. No samples of the participants' water was taken. So basically, they could not narrow down the source of the PFAS they were exposed to."
These observations are an important reminder to not jump to conclusions and examine the study design. Of course, not all media are as tuned into the science, so the truth gets stretched across headlines.
MoCRA PFAS Mandate, Global Actions Against PFAS
As studies like these continue making news, they also draw greater consumer and regulator attention. In fact, the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) requires the U.S. Food and Drug Administration (FDA) to assess the use of PFAS in cosmetic products and publish a report by Dec. 29, 2025, summarizing any risks associated with their use. Such analysis will hopefully fill in some of the gaps in research on PFAS in cosmetics.
"There have been few studies on the presence of PFAS in cosmetics. Those studies that have been published found the concentration of certain PFAS in cosmetics as impurities or as ingredients, at levels ranging from parts per billion to hundreds of parts per million," MoCRA states. Also according to the act, not all PFAS that may be found in cosmetics can be readily measured, "because the specific 'fingerprint' or analytical standard for the specific PFAS may not be available, making their detection and quantitation challenging."
Per MoCRA, based on the currently limited information, additional research is needed to determine:
- the toxicological profiles for PFAS in cosmetics;
- the extent to which various PFAS in cosmetics can be absorbed through the skin; and
- the potential for human health risks from exposure to PFAS in cosmetics.
Considering concerns for the environment and unknowns (for some PFAS) in terms of health impact, it's no wonder why actions are being taken globally against PFAS. In January this year (2024), New Zealand announced the prohibition of PFAS effective Dec. 31, 2026. In March 2024, Taiwan added certain PFAS to the "prohibited" list. In 2023, five European nations proposed bans and restrictions as well.
As of June 2024, 21 of the fifty U.S. states had pending or finalized legislation relating to PFAS in a variety of industry sectors; firefighting foam and food packaging are the largest. Eight of the fourteen states with enacted legislation have laws relating to personal care products (California [AB 2771], Colorado [HB 22-1345], Maryland [HB 643], Minnesota [HF 2310], Maine [LD 1503], Oregon [SB 546], Vermont [S 25] and Washington [HB 1047]); only one (Minnesota) has designated cleaning products as a category for restriction/prohibition of PFAS.
Is Banning PFAS Across Industries Misguided?
Earlier this year (2024), Mark Jeffreys, CEO of 4Sight, critiqued sweeping proposed bans on PFAS. "The U.S. Environmental Protection Agency (EPA) lists more than 15,000 PFAS chemicals in its CompTox database," Jeffreys wrote. "These are chemicals used in everything from equipment vats that make shampoos or other household products, to non-stick cookware; from dental floss to waterproof outdoor gear.
"PFAS chemicals are also used in things like coatings for solar panels and screens for smartphones. The properties that make PFAS so effective in those thousands of products is also what makes them concerning – their inability to break down easily either in the environment or human body."
"... It's right to be concerned about PFAS ingredients," he continued, "but as with any business or public policy decision, regulators, business leaders and public policy decision-makers should follow the science and facts. A sweeping ban on PFAS chemicals may impact environmental efforts, such as alternative energy technologies in lithium batteries, PV panels, wind turbines and fuel cells, as well as have national security implications."
You're preaching to the beauty industry choir, Jeffreys.
