EPA Proposes Ban On PFAS In Cosmetics – Expert Reaction

The Environmental Protection Authority is seeking
feedback on its proposed changes to the Cosmetics Products
Group Standards, which contain rules around ingredients and

The EPA proposes that New Zealand aligns
its rules for ingredients with the European Union, and phase
out perfluoroalkyl and polyfluoroalkyl substances (PFAS),
sometimes known as “forever chemicals.”

proposed updates include updating requirements for

The SMC asked experts to comment on the

Melanie Kah, Associate Professor, School of
Environment, University of Auckland; Lokesh Padhye.
Associate Professor, Department of Civil and Environmental
Engineering, University of Auckland; and Erin Leitao, Senior
Lecturer, School of Chemical Sciences, University of
Auckland, comment:

“This proposal to ban PFAS in
cosmetics in NZ is fantastic news. PFAS in cosmetics are
under scrutiny across Europe and the U.S., but they have not
been banned (yet). The EU is currently discussing a complete
ban of PFAS, not only for cosmetics but also for all other
non-essential uses (from non-stick pan to waterproof

“PFAS are found in about 50% of cosmetics
(mainly mascara, foundation and lipstick) to improve product
durability and texture. There are established links between
PFAS and human health issues, but exposure via the use of
cosmetics is likely to be low compared to other sources
(PFAS from water, food, inhalation).

“The main
driver to phase out PFAS in cosmetics (and other
non-essential uses) is linked to the persistence of PFAS.
They are very hard to degrade. If we keep producing PFAS,
the global load will continue to increase, inevitably
leading to negative impacts. We need to turn off the tap and
limit PFAS to essential uses, which does not include long
lasting lipsticks.

“And there are alternatives.
Cosmetics without PFAS may not last that long, but consumer
awareness and growing legislation can boost research to find
alternatives that provide the functions while avoiding the
drawbacks of PFAS.”

All: No conflicts of

Professor Sally Gaw, Director of
Environmental Science, School of Physical and Chemical
Sciences, University of Canterbury, comments:

changes proposal by the EPA to align New Zealand’s lists
of banned ingredients in cosmetics with the requirements of
the European Union will have significant benefits for the
health of people who wear cosmetics and wider environmental
benefits. Cosmetics are, for many people, everyday products
and people will have their favourite types of products and
brands – this means that a person is almost continuously
exposed to the ingredients used in their

“This measure will also be protective of
children as chemicals from cosmetics have been measured in
amniotic fluid indicating that babies can be exposed in the
womb with potential impacts on their development and
lifelong health. As these types of products also enter waste
streams including rubbish and wastewater, cosmetic
ingredients can be released into the environment. Extending
the list of banned ingredients in cosmetics to align with
the European Union will also prevent New Zealand from
becoming a dumping ground for products that are considered
unacceptable in other countries.

“The extensive list
of chemicals that will be banned in cosmetics highlights the
vast number of chemicals used in everyday products with the
majority of these chemicals not being monitored for in New
Zealand. The EPA also propose banning perfluoroalkyl and
polyfluoroalkyl substances (PFAS), the so-called forever
chemicals and a class of chemicals for which the evidence
for human health effects is steadily increasing. The extent
of usage of these persistent chemicals highlights the urgent
need to require mandatory declaration of all ingredients in
manufactured products either being made or imported into New
Zealand. We cannot prevent health and environmental risks
associated with chemicals in everyday products if we do not
have information on the chemicals and their

No conflicts of interest

Peter Cressey, Science Leader, ESR, and
Abhishek Gautam, Senior Scientist-Risk Assessor, ESR,

“Cosmetics regulations in New Zealand are
not very different from the European Union. In fact,
Schedule 4-8 of the cosmetic group standard are based on the
provisions of Cosmetic Regulation (EC) No. 1223/2009 of the
European Parliament. But there are still some aspects of the
Regulation which New Zealand not yet adopted. The proposed
amendments to the group standard look to adopt further
aspects of the EU Regulation. This is in line with current
initiatives in a number of areas to harmonise regulatory
approaches to protect consumer health.

are made of different chemicals and all of them can be
hazardous if the exposure dose is sufficiently high.
Hazardous chemicals can be intentionally added to cosmetic
products (mercury in skin lightening cream) and may be
purchased by New Zealanders through online retailers even
though they are banned in New Zealand. Sometimes the
presence of hazardous chemicals can be technically
unavoidable (benzene in sunscreens, deodorants etc.) as they
might be degradation products of permitted ingredients or
residual impurities from the manufacturing process. The
identification and risk assessment of hazardous chemicals is
an ongoing area of international

“Therefore, a proper human health risk
assessment and updated product documents (certificate of
analysis, technical specification sheet) should be regularly
reviewed to have safer products for the

“Per- and polyfluoroalkyl substances
(PFAS) are a class of chemicals that are used in wide range
of consumer and industrial products. PFAS can be used
intentionally in some cosmetic products such as foundation,
lipstick, eyeliner, eyeshadow, nail polish and mascara.
Their function in cosmetics is to condition and smooth the
skin, making it appear shiny, or to affect product
consistency and texture. However, they may be
unintentionally present in cosmetic products. In 2018,
Denmark’s Environmental Protection Agency conducted a risk
assessment of five different PFAS unintentionally present in
high concentrations in cosmetics (body lotion, foundation
and concealer). It was concluded that the levels at which
PFAS identified in the individual products tested was
unlikely to pose a health risk for consumers. The
conclusions may not be definitive as more research is
required on PFAS identification and quantification,
toxicology of PFAS, and its dermal

“Research into the adverse human health
effects of PFAS is ongoing but to date the potential health
effects have not been conclusively established. However, the
extreme environmental persistence of PFAS makes them
undesirable to use. In light of environmental persistence,
NZEPA’s decision to phase out PFAS from cosmetic products
is consistent with international trends. ESR has conducted a
number of risk
of cosmetic related chemicals for Te Whatu

All: No conflict of

Professor Allan Blackman, School of
Science, Auckland University of Technology,

“The Environmental Protection Authority is
calling for feedback on proposed updates to the Cosmetic
Products Group Standard, which details rules for cosmetics
in New Zealand, so that it more closely aligns with that of
the EU.

“In addition to relatively minor changes
such as clarification of the hazardous nature of cosmetics,
requirements for emergency contact numbers, and various
housekeeping changes, the major proposed change involves the
phasing out of PFAS (perfluoroalkyl and polyfluoroalkyl
substances) as components in cosmetics by the end of

“PFAS (commonly known as ‘forever
chemicals’) are defined as compounds containing both
carbon and fluorine, in which at least one carbon atom is
bonded to the maximum possible number of fluorine atoms.
Since the accidental discovery of Teflon in 1938, PFAS have
been used to impart desirable properties such as flow,
shine, water resistance, and durability to a number of
industrial compounds, including those classified as

“The perceived problem with PFAS arises
from the robustness of the C-F bond, meaning that these
compounds are not easily broken down and therefore persist
in the environment. Health concerns about PFAS have been
raised, resulting in bans on particular compounds around the
world, and such concerns are doubtless behind the proposed
revisions to the group standard.

“However, the
definition of PFAS used in the proposal would render illegal
any compound containing a carbon atom bonded to three
fluorine atoms – in chemical parlance, a trifluoromethyl
group. This combination of atoms finds significant use in
pharmaceuticals, most notably Prozac and a number of
anti-cancer and anti-HIV drugs which are safe for human
consumption, having been approved by the FDA. While these
fall outside the classification of cosmetics, a redefinition
of PFAS will be required when the use of fluorine-containing
drugs comes under the regulatory spotlight.”

conflict of

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