Yesterday (Mars 5, 2025), the Government of Canada published its long-awaited Final State of the Science Report on Polyfluoroalkyl Substances (PFAS) in addition to signaling their intent to initiate processes to add this large group of chemicals to Part 2 of Schedule 1 of the Canadian Environmental Protection Act (CEPA) [List of ‘Toxic’ Substances], based on conclusions that these substances may present a risk to human health and the environment. Excluded from this Report and risk management efforts is any activity on fluoropolymers[1], which have been set aside in the interim, pending additional study. This Final Report builds on the previous Draft State of the Science Report on PFAS originally published Mai 2023 and Updated State of Science Report released in Juillet 2024, which together, received input from 100’s of stakeholders.
This development was featured in a CBC newscast that aired late yesterday, and we will no doubt see similar pick-up by other outlets in the coming days. Not surprisingly, given past media activity on PFAS in cosmetics, this news feature included a profile on the use of PFAS in cosmetics. CA Canada will continue to monitor the news for on-going coverage and engage accordingly.
Recall, that the addition of a substance or group of substances to Schedule 1 of CEPA serves to enable the Government of Canada to mitigate potential risk(s), as identified, and as such, does not necessarily mean that a substance(s) is de facto banned. Correspondingly, with this publication, the Government of Canada also published a Risk Management Approach, wherein it is proposed that officials will be initiating processes to establish restrictions and/or controls across targeted use scenarios, including both consumer and industrial products, in order to mitigate the potential risk(s) identified. Specifically, the Government of Canada will be taking a phased approach, as it seeks to “reduce environmental and human exposure to the lowest levels that are technically feasible…”, namely:
Phase 1: Targeting use of PFAS’ in firefighting foams, based on high potential for environmental and human exposures
Phase 2: Addressing possible restrictions of PFAS use in consumer products (including cosmetics), where suitable alternatives exist
Phase 3: Evaluating other possible restrictions and/or control activities for further consideration though additional stakeholder consultations
Overall, this phased approach, focused on establishing targeted use restrictions is pragmatic and a welcome ‘common sense’ approach, that reflects long-standing stakeholder input, including those submitted by Cosmetics Alliance Canada, especially, given the very large and diverse nature of this class of chemicals.
Note: Both of the State of the Science Report and the Risk Management Approach document are hefty, extensive, and highly technical reads. For a concise summary of these publications, members are directed to the following ‘Information Sheet’ for highlights of critical findings and next steps.
Use of PFAS in Cosmetics and Industry Initiatives
PFAS represents a very large class of chemicals, some of which have traditionally been used in some cosmetics, as effective ‘water proofing’ or ‘sweat proofing’ ingredients. Some may have also been deliberately added to cosmetics to impart desired ‘slip’ and ‘feel’ functionality to enhance sensorial experience.
Unfortunately, due to the ‘carbon-fluorine’ chemistry that is common to this large class of substances, these ingredients do not readily breakdown in the environment and have therefore been found to persist and build up in the environment, over time. In this regard, the cosmetic industry, globally have undertaken initiatives (e.g., Cosmetics Europe recommendation, Décembre 2023) to prioritise the identification of alternatives to impart these same functionalities without dependence on fluorinated chemistries, with corresponding reformulation of products now well underway across our industry.
In fact, this was the very subject of our member engagement presentation entitled “PFAS – The Writing is On the Wall”, as presented during our Fall 2023 Regulatory Workshop (Décembre 2023); which was built on a corresponding update CA Canada presented at the Society of Cosmetic Chemists (SCC) Regulatory Day in Mars 2023. On this basis, the cosmetic and personal care industry is already well engaged with phasing out the deliberate use of PFAS in products.
That said, over the past few years, in addition to moving away from the deliberate use of PFAS in products, our industry’s efforts regarding PFAS, both domestically and across the globe, has become focused on establishing a dialogue to address the unintentional presence of PFAS in cosmetics and personal care products; largely because residual PFAS can be incidentally present in products, due to the use of PFAS in packaging and, more critically, the post-consumer resin (PCR), that industry is moving to, in addressing plastic waste and reducing our industry’s collective environmental sustainability footprint.
In this regard, our industry remains vigilant in ensuring the identification of an appropriate diminimis to address the unintentional presence of PFAS which will inevitably be attributed, at least for the near to medium term future, to cosmetics, as alternatives to PFAS chemistries in plastic packaging are duly identified. CA Canada continues to pursue dialogue on these important considerations both domestically and internationally, and we welcome members to ‘join the conversation’ as we tackle these important aspects to minimizing the impacts of PFAS across our supply chain.
Finally, it is important to note, that although all PFAS are likely to be environmentally persistent (due to carbon-fluorine chemistry), they do not necessarily present the same human health as those attributed to Perfluorooctane sulfonate (PFOS), Perfluorooctanoic acid (PFOA), and long-chain Perfluorocarboxylic acids (LC-PFCAs) and their salts and precursors, that have already long been subject to risk management under CEPA for well over a decade now. In this regard, not all PFAS are created equal in terms of their potential to present risks to human health. This observation is critical in so far as establishing a balanced and pragmatic risk management approach for these substances under the Canadian Chemicals Management Plan (CMP).
[1] Fluoropolymers are defined in the State of Science Report as the subset of PFAS “polymers made by polymerization or copolymerization of olefinic monomers (at least 1 of which contains fluorine bonded to 1 or both of the olefinic carbon atoms), to form a carbon-only polymer backbone with fluorine atoms directly bonded to it.”
