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Intentionally added PFAS” refers to per- and polyfluoroalkyl substances that are specifically included in a product formulation as an ingredient to serve a functional purpose. The FDA identified 51 different PFAS that were intentionally added as ingredients in 1,744 cosmetic product formulations sold in the U.S. These ingredients were added to various cosmetic and personal care products due to their water- and oil-resistant properties, durability, and ability to enhance texture.

What Do Safety Assessments Indicate?

With increasing Regulatory attention, the safety profile of these commonly used PFAS is under closer evaluation. Based on available toxicological data, the FDA has grouped the most prevalent 25 PFAS ingredients into 3 categories:

  • Low Safety Concern

    Includes PTFE, Perfluorodecalin, HC Yellow No. 13, Perfluorohexane, and Tetrafluoropropene, which are currently considered to present relatively lower risk under typical use conditions.

  • Potential Safety Concern

    Perfluorohexylethyl Triethoxysilane has been identified as a potential safety concern, particularly at higher concentrations of use in body lotion, requiring closer formulation oversight.

  • Insufficient Data

    The majority (19 out of 25 key PFAS ingredients) fall into this category, including Perfluorononyl Dimethicone and Trifluoroacetyl Tripeptide-2, where limited data prevent definitive safety conclusions.

Why This Distinction Matters for Compliance

Regulators globally are increasingly focusing on “intentionally added PFAS” when introducing bans, restrictions, and reporting requirements, as these reflect deliberate formulation decisions by manufacturers rather than trace-level contamination.

Globally and especially across the U.S. states, such as Minnesota, Maine, New Mexico, Washington, and Connecticut, have introduced reporting and notification requirements for intentionally added PFAS in products, increasing compliance obligations for manufacturers.

This evolving landscape signals a shift from basic ingredient disclosure to deeper formulation accountability. Brands are now expected to clearly identify where PFAS are intentionally used and prepare for increasing regulatory scrutiny and reporting obligations.

Freyr helps you navigate evolving PFAS regulations with State-wise PFAS assessment, tracking new and evolving state PFAS laws, and continuous regulatory monitoring to ensure timely updates and proactive action.

Consult Freyr Today!