Short answer: since 1 January 2026, France prohibits the manufacture, import, export and sale of cosmetic products containing PFAS above set thresholds — the first national ban of its kind — and a broader EU-wide PFAS restriction is in consultation, so this audit is worth doing beyond France.

PFAS — the per- and polyfluoroalkyl substances sometimes called "forever chemicals" — have moved from environmental headlines into cosmetics law. France legislated first; the EU is working on a bloc-wide restriction. For brands selling into Europe, the practical question is no longer whether PFAS rules arrive but which ones apply to which SKU, and whether your formulas and documentation can answer for them.

What the French law actually does

France's Law No. 2025-188, supplemented by its implementing decree published at the end of 2025, entered into force on 1 January 2026. For cosmetics it prohibits the manufacture, import, export and sale of products containing PFAS above the thresholds the decree specifies, with a twelve-month transition for pre-existing stock.

Three features make it more consequential than a single-country restriction:

  • The definition is broad. PFAS is a family of thousands of substances. A formula is not "PFAS-free" because its intentional ingredients are innocent — trace contamination and undeclared precursors count, which shifts the burden onto supply-chain documentation.
  • All four activities are covered. Manufacture, import, export and sale — so an overseas manufacturer shipping into France is within scope from the factory gate.
  • It is a preview. The EU-level PFAS restriction under chemical-agency review would extend similar logic across the single market. Formulas cleaned up for France are, in effect, being prepared for the EU.

Where PFAS actually hide in cosmetics

Most brands never intentionally added PFAS. The exposure routes are subtler:

  1. Fluorosurfactants in long-wear systems — historically used in some long-wear foundations and lip products for their spread and slip properties.
  2. Coatings on packaging — greaseproof or moisture-barrier treatments on certain cartons and labels can carry PFAS, a packaging-side exposure that formula audits miss.
  3. Equipment and trace contamination — processing aids and legacy materials, usually at trace levels, but the thresholds in law are what they are.
  4. Undeclared intermediates — ingredients whose own supply chains carry fluorinated residues, visible only if your raw-material documentation goes deep enough.

The honest audit therefore runs on two axes — formula and packaging — and depends entirely on supplier declarations being trustworthy and current.

The importer's audit checklist

  1. Inventory intentional-use risk. Flag SKUs in long-wear, transfer-resistant and high-slip formats first; they are the category where fluorinated additives historically appeared.
  2. Collect current PFAS declarations from every raw-material and packaging supplier — dated, covering the specific grades you buy, not blanket statements about product families.
  3. Check the packaging line of the audit too: coatings on cartons, labels and any greaseproof elements.
  4. Ask your manufacturer how they verify. A factory with systematic supplier qualification and retained documentation can answer with a process; answers like "our suppliers said so" are the audit finding, not the audit.
  5. Watch the transition: pre-existing stock has a twelve-month runway from 1 January 2026; products newly placed after that must comply from the start.
  6. Track the EU-level file, because a bloc-wide restriction would convert this from a France SKU decision into a Europe-wide one.

What to ask a manufacturer about PFAS readiness

  • Can they produce current, substance-specific declarations for the raw materials in your formula?
  • Do they run supplier qualification that reaches down to ingredient manufacturers, or only to distributors?
  • What is their process when a declaration changes — does it trigger a formula impact review?
  • Do their packaging specifications for your SKUs specify PFAS-free coatings?

The pattern behind all four questions is the same one that governs every modern compliance file: the product's compliance lives in its documentation chain, not in the bottle. This is the same muscle behind batch-level documents like the CoA and compliance set that should already accompany every order.

Beyond France: the direction of travel

France is first, and firsts in EU cosmetics regulation tend to become defaults. The bloc-wide PFAS restriction under consultation covers a wider chemical universe and more sectors, and whichever final form it takes, the direction is set: fluorinated chemistry in cosmetics is being phased toward zero. Brands that treat the French law as a one-market nuisance will redo the work twice; brands that audit once at EU-strictness keep the result.

There is also a commercial layer: retailers increasingly ask PFAS questions in onboarding regardless of legal requirements, and "we have current declarations on file" is becoming a shelf-access answer as much as a legal one.

FAQ

Q: What is banned under France's PFAS law for cosmetics? A: Since 1 January 2026, the manufacture, import, export and sale in France of cosmetic products containing PFAS above the thresholds set in the implementing decree, with a twelve-month transition for pre-existing stock. France is the first country to ban PFAS in cosmetics.

Q: My formula never used PFAS — is it automatically compliant? A: Not automatically. PFAS can enter through trace contamination, undeclared intermediates and packaging coatings rather than intentional use. Compliance rests on current, substance-specific declarations from raw-material and packaging suppliers.

Q: Does the ban apply to packaging as well as formulas? A: The law targets cosmetic products containing PFAS, and packaging coatings — greaseproof cartons, some labels — are a recognized PFAS route, so a complete audit covers both the formula and its packaging materials.

Q: Is an EU-wide PFAS ban coming? A: A bloc-wide restriction is under consultation. Its final scope is not set, but the direction is clear — which is why auditing formulas and documentation to the strictest current standard, rather than just to the French thresholds, is the strategy that avoids doing the work twice.