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PFAS Ban in Cosmetics: What French Law Requires
- Jeanne Julé
- 21 hours ago
- 6 min read
Complete analysis of Law n° 2025-188 and its impacts on the industry
Since January 1st, 2026, PFAS are banned in cosmetic products in France. This ban results from Law n° 2025-188 of February 27, 2025 and its implementing decree. France has thus established itself as a pioneer within the European Union regarding the regulation of per- and polyfluoroalkyl substances (PFAS). This legislative turning point marks a clear break with previous cosmetic industry practices, which used these "forever chemicals" for their texture and long-wear properties.
Introduction
By enacting Law n° 2025-188, France has established itself as a pioneer within the European Union in regulating per- and polyfluoroalkyl substances (PFAS). This legislative turning point marks a clear break with previous cosmetic industry practices, which used these "forever chemicals" for their texture and long-wear properties.
To understand the chemical nature of these substances, you can consult our technical guide on PFAS definition.
The stakes for cosmetic industry players from raw material suppliers to brands, including manufacturers and distributors are colossal. It is no longer just a recommendation or a "clean beauty" trend, but a strict legal obligation whose non-compliance exposes companies to heavy criminal and administrative sanctions.
This new PFAS regulation in cosmetics requires brands to rapidly bring their formulations and product files into compliance.
What does French law say about PFAS?
Law n° 2025-188 of February 27, 2025
Adopted in a context of national awareness regarding environmental pollution, this law aims to protect the population and ecosystems from risks linked to PFAS persistence.
The key provisions are unequivocal:
Total Ban: As of January 1st, 2026, the manufacture, import, export, and placing on the market (for free or for a fee) of any cosmetic product containing per- and polyfluoroalkyl substances are prohibited.
Major Legal Innovation: Unlike current European REACH regulation which often restricts substances "intentionally added", the French law adopts an approach based on concentration thresholds.
This de facto makes the ban applicable without distinction between intentional addition (formulated ingredient) and unintentional contamination (impurity, packaging migration). If the substance is detected above the threshold, the product is non-compliant, regardless of the PFAS origin.
The implementing decree: thresholds and technical modalities
Decree n° 2025-1376 of December 28, 2025
Published in the Official Journal (JORF n°0301) a few days before the ban came into force, this implementing decree is the technical reference text for laboratories and quality departments. It specifies the concrete implementation modalities of the law, notably by setting analytical compliance limits.
This text underwent a European notification procedure which concluded without a blocking detailed opinion, thus validating the French initiative under European law. The decree has been fully applicable since January 1st, 2026.
What are the applicable regulatory thresholds?
A cosmetic product is considered non-compliant if it exceeds one of the following three thresholds defined by the decree:
PFAS thresholds applicable to cosmetics in France
Watch out for the Total Fluorine threshold
The threshold of 50 ppm Total Fluorine is crucial. It sanctions the presence of polymers like Teflon® (PTFE), often used as texturizing agents. These polymers are insoluble and generally undetectable by classic targeted analyses (LC-MS/MS). Only Total Fluorine analysis allows verifying their absence.
Ban timeline: key dates
The transition to PFAS-free cosmetics follows a strict legislative calendar that companies must imperatively respect.
Timeline of the PFAS ban in cosmetics
Stock depletion: rules and precautions
The decree provides a stock depletion clause to avoid immediate massive waste, but this tolerance is strictly framed.
The 12-month rule
Products manufactured or imported (released for free circulation in the territory) before January 1st, 2026 can still be marketed for a duration of 12 months, i.e., until January 1st, 2027.
Strict management conditions
Proof of date: The company must be able to prove, via batch numbers and manufacturing/import orders, that products on shelves were indeed manufactured before the deadline.
Mandatory destruction: After January 1st, 2027, any remaining stock containing PFAS must be withdrawn from the market and destroyed according to appropriate channels for hazardous chemical waste.
Coordination: This management must be synchronized with other labeling and eco-design requirements applicable from 2026 (AGEC Law, Packaging Regulation).
Cosmetic industry commitment
Aware of health issues and societal evolution, the cosmetic industry did not wait for the law to act, although the legislative framework accelerated the movement.
Voluntary initiatives
Cosmetics Europe: The European association issued a voluntary recommendation as early as 2023 asking its members to phase out all intentionally added PFAS ingredients in cosmetic products by December 31, 2025.
FEBEA (France): The Federation of Beauty Enterprises supported the legislative process while emphasizing the marginal nature of PFAS in the sector. It launched substitution programs as early as 2023 and published technical guides for SMEs.
Analytical standardization
FEBEA actively participates in the PFAS Platform led by AFNOR, whose work began in early 2026. The objective is to develop standardized reference methods for PFAS analysis in complex cosmetic matrices, to legally secure controls.
Sanctions and controls: what are the risks?
In France, law enforcement is jointly monitored by the DGCCRF (Fraud Control) and the ANSM (Health Safety).
Typology of risks
Administrative measures: Injunction to comply under penalty, immediate suspension of marketing, order to withdraw and recall products at the exclusive expense of the operator.
Criminal sanctions: Violations of regulations on hazardous chemical substances can constitute offenses of deception regarding the substantial quality of the product or endangering others.
Reputational risk: Publication of control results ("Name and Shame" practice) can permanently tarnish a brand's image, particularly on a subject as sensitive as "forever chemicals".
FEBEA asked authorities to also target imported products, notably via marketplaces, to avoid distortion of competition with French manufacturers who respect the law.
European and international context
The French ban is not an isolated case, but the vanguard of a global regulatory movement.
Universal REACH restriction project
Submitted in January 2023 by 5 countries (Germany, Netherlands, Sweden, Norway, Denmark), this proposal aims to ban approximately 10,000 PFAS in all uses in Europe. Final ECHA opinions are expected by late 2026, with likely entry into force around 2029. France is therefore 3 years ahead of the European schedule.
International context
Stockholm Convention: Global ban on PFOS (2009), PFOA (2020), and PFHxS (2022).
USA: "MoCRA" strengthens cosmetic safety and the EPA monitors a list of over 14,000 PFAS.
Canada: Publication of a State of PFAS Report in 2023, signaling an intention to regulate by class.
PFAS regulation: France vs European Union
What should brands do now?
To comply with PFAS regulation, cosmetic companies must undertake a structured and methodical approach:
Action plan to comply with PFAS regulation
This approach is essential to anticipate DGCCRF and ANSM controls, and to secure the placing on the market of cosmetic products in France. Companies that act proactively transform this regulatory constraint into a competitive advantage.
Conclusion: anticipate to comply
The ban on PFAS in cosmetics in France marks a major regulatory evolution. Law n° 2025-188 places the French cosmetic industry before an immediate challenge: the ban has been active since January 1st, 2026, thresholds are defined, and the countdown for stock depletion has started.
For companies, compliance is not limited to product reformulation: it also implies a thorough analysis of raw materials, packaging, and supply chain. Total supply chain mastery and increased analytical vigilance are indispensable to avoid cross-contaminations and guarantee compliance with regulatory thresholds.
To succeed in your transition, consult our practical guides:
FAQ: Frequently Asked Questions
Since when are PFAS banned in France?
The ban on manufacture, import, and placing on the market came into force on January 1st, 2026.
Can I still sell my stocks in March 2026?
Yes, but only if the products were manufactured or imported before January 1st, 2026. This tolerance ends permanently on January 1st, 2027.
What thresholds must be respected?
25 ppb for an individual PFAS, 250 ppb for the sum of PFAS, and 50 ppm for Total Fluorine (including polymers like PTFE).
Who enforces the law?
Controls are carried out by the DGCCRF (market surveillance, fraud) and the ANSM (health safety).
What are the sanctions for non-compliance?
You risk product withdrawal/recall at your expense, stock destruction, administrative fines, and criminal prosecution for deception.
Will Europe follow France?
Yes, a universal REACH restriction project is currently under review by ECHA. However, its application is not expected before 2029 at the European level.
Is your company ready for regulatory inspections?
Don’t take risks with the 2026 regulations.
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