Cosmetics placed on the EU market now face binding limits on PFHxA, its salts and related substances, as the transition window granted under the REACH restriction process has closed, Personal Care Insights reports.

The restriction targets undecafluorohexanoic acid (PFHxA), a short-chain per- and polyfluoroalkyl substance (PFAS) used for water-grease repellency and film-forming performance. With the REACH transition period ended, cosmetic products containing covered PFHxA-related substances above the restriction's conditions can no longer be supplied in the Union.

What does the change cover?

PFHxA entered the REACH restriction pipeline as regulators moved to rein in PFAS "of very high concern" following the phase-out of longer-chain compounds such as PFOA. Short-chain substitutes — PFHxA among them — attracted scrutiny because of persistence in the environment and documented mobility in water. The adopted restriction sets concentration limits and, critically for the beauty sector, applies them to consumer articles and mixtures, a category cosmetics fall within where relevant PFHxA chemistry is present.

For formulators, the practical exposure points are ingredients and componentry that deliver fluorinated performance: durable water-repellent film formers, long-wear and transfer-resistant textures, and certain treatments applied to packaging or applicator materials. Suppliers of such raw materials carry the primary burden of certifying compliance.

What should compliance teams do now?

• Review INCI listings and technical data sheets for fluorinated film formers and surface-treatment agents in current formulas.
• Request written compliance statements from raw-material suppliers covering PFHxA, its salts and PFHxA-related substances.
• Assess whether any residual PFHxA presence stems from impurities or from intentional functional chemistry — the restriction's conditions differ accordingly.
• Check whether safety assessments and the Product Information File need updating to reflect the new restriction.
• Screen packaging and applicator components, not only the bulk formula, since the restriction's scope extends beyond cosmetic ingredients in isolation.

Responsible persons should treat the end of the transition as a live market-access issue: products already in the supply chain that breach the restriction's conditions can no longer lawfully be made available, and distribution agreements may need revisiting.

Is this the endpoint for PFAS in cosmetics?

Probably not. PFHxA restriction is one strand of a broader EU push on PFAS, with a wide-ranging universal PFAS restriction proposal still working through the REACH process. Cosmetics were identified early as a use sector in that dossier, meaning today's PFHxA limits may read, in hindsight, as the first concrete wave rather than the final rule.

Brands that depend on fluorinated performance claims — long-wear, waterproofing, transfer resistance — now face procurement decisions: qualify non-fluorinated alternatives or reformulate ahead of any wider restriction. Silicone and acrylate-based film formers remain the most common replacement routes suppliers are positioning.

What to watch next

The next data point for EU cosmetics teams is the trajectory of the universal PFAS restriction proposal through ECHA's committees — watch for sectoral derogations, concentration thresholds and any cosmetics-specific transition periods as the dossier advances.