Testing has found PFAS in a lot of long-wear makeup. Lead and mercury have turned up at levels the FDA ties to poisoning, in products sold illegally. In a 2021 study of 231 cosmetics, 52% carried high fluorine, the authors' screen for PFAS, and only 8% listed a PFAS ingredient. A 2015 US law banned plastic scrub beads. Lead in lipstick is the headline people know, and it's small by the FDA's own numbers.
If you want a short label you can check line by line, I'd start with Bare Silk ($34, as of October 5, 2026). It's five ingredients, none of them a pigment, a glitter, a film-former or a fluorinated compound.
What has testing found for PFAS in makeup?
PFAS, short for per- and polyfluoroalkyl substances, are fluorinated chemicals, and some go into cosmetics on purpose. The FDA says they're used to condition and smooth skin and hair so they look shiny, or to change a product's texture. It names polytetrafluoroethylene (PTFE) and perfluorononyl dimethicone among them, in products from lipstick to nail polish. Some get in by accident. They come in as impurities in raw materials, the agency says, or when an added PFAS breaks down.
Here's what a 2021 study by Whitehead and colleagues found. They screened 231 products bought in the US and Canada for total fluorine, and 52% came back high. Foundations led at 63%. Eye products came in at 58% and lip products at 55%. Mascaras sat lower, at 47%. The high readings turned up in products sold as long-lasting or wear-resistant, with waterproof mascaras and liquid lipsticks among them.
They tested 29 products in depth. Every one held at least four individual PFAS, and one held 13. Labels didn't say so. Only one of those 29 listed any PFAS as an ingredient. The authors raise two possible ways in: lipstick that's swallowed without meaning to, and mascara near the tear ducts, where some PFAS could be absorbed.
What does the law say about PFAS in cosmetics?
At the federal level, the answer so far is a report the FDA published on December 29, 2025. The Modernization of Cosmetics Regulation Act of 2022 set that deadline. The report's summary stresses what's missing. The FDA named four gaps: limited data on use levels, no absorption data for skin or mouth, missing mechanistic information and no dermal toxicity data. Its next step, it says, is to keep monitoring.
Minnesota has gone further. Since January 1, 2025, it's barred selling cosmetics with intentionally added PFAS there. From 2032 the ban reaches any product with intentionally added PFAS, unless the state rules that use currently unavoidable. It counts any fluorinated organic chemical with a fully fluorinated carbon atom as PFAS. Intentionally added means put in on purpose, to do a job in the finished product, so a stray impurity isn't the target.
Most of the PFAS in long-wear makeup goes unlabeled, and that part is measured. The FDA says many break down very slowly and some build up in people and the environment over time, a potential health risk. Without absorption data, it can't yet say what mascara adds to your body's load.
How much lead is in lipstick?
In lipstick, lead is an impurity, which is how the FDA approaches it. The agency says lead can occur in any cosmetic ingredient because it's in the environment, and most listed color additives already carry a lead limit. In 2010 it tested 400 lipsticks and other lip products sold in the US. The average was 1.09 parts per million (ppm). Across its lip surveys, the highest reading was 7.19 ppm, in one lipstick.
The FDA's draft guidance from December 2016 recommends a maximum of 10 ppm lead in lip products and in cosmetics put on the skin. It's still a draft, and non-binding. The agency concluded that 10 ppm wouldn't pose a health risk, and its data put over 99% of those products on the US market below it. So the lipstick headline is a real measurement, and a small one.
Where is the heavy metal risk real?
Start with eye cosmetics sold as kohl, kajal, surma or tiro. The FDA calls them illegal color additives, never approved for any product it regulates, and it keeps an import alert on them. Lead, usually as lead sulfide, sometimes makes up more than half of a kohl product's weight. Studies have found more lead in exposed children's blood, and the FDA links high lead exposure to anemia and kidney problems. At the far end, it lists neurological damage that may include seizures and death.
Mercury is the other real case. The FDA has warned about it in skin creams and soaps sold as lighteners and anti-aging products, usually made abroad and sold illegally in the US. It doesn't allow mercury in cosmetics outside a narrow preservative exception. The agency names pregnant women and young children as especially vulnerable, and mercury passes into breast milk. Family members can be exposed too, through the vapor or shared towels. Check labels for mercurous chloride, calomel, mercuric, mercurio or mercury, the names the FDA says give it away.
If a child in your house has worn kohl or surma, or anyone's used one of these creams, call your pediatrician or doctor. The FDA also points people to poison control at 1-800-222-1222, open 24 hours a day.
What happened to microbeads, and what comes next?
The US acted on scrub beads with the Microbead-Free Waters Act, signed December 28, 2015. It defines a plastic microbead as any solid plastic particle under five millimeters meant to exfoliate or cleanse the body. Rinse-off cosmetics can't contain them, toothpaste included. Manufacturing had to stop by July 1, 2017, and sales across state lines by July 1, 2018. Over-the-counter rinse-offs got a year longer.
The EU went wider with Regulation (EU) 2023/2055, which restricts plastic particles of 5 mm or less across many products. Scrubbing microbeads got no transition period, so they've been restricted since October 17, 2023. Other cosmetic uses phase in after that. Rinse-off products follow on October 17, 2027, and leave-on products on October 17, 2029. Makeup waits longest. It has until October 17, 2035, along with lip and nail products.
Both rules are framed around water and the environment, and the US act says so in its name. The EU text cites its chemicals agency's estimate that more than 42,000 tonnes of microplastics added on purpose reach the environment every year. My sources don't measure harm to the person using a scrub, so I'll leave that question open.
| Contaminant | Where found | What the law says | Where the risk sits |
|---|---|---|---|
| PFAS | High fluorine in 52% of 231 products | FDA report, 2025 · Minnesota ban since 2025 | Mostly unlabeled · no absorption data |
| Lead in lipstick | 1.09 ppm average, 400 lip products | FDA draft limit: 10 ppm | Small: over 99% below it |
| Lead in kohl | Over half the weight, at times | Illegal color additive | Real, worst for children |
| Mercury | Lightening creams sold illegally | Allowed only as a last-resort preservative | Real, for whole households |
| Microplastics | Scrubs, then leave-on products and makeup | US ban from 2017 · EU phase-in to 2035 | Water and environment |
What's in our jars, and what isn't?
None of the five to ten named ingredients in our recipes is a pigment, a glitter, a film-former or a fluorinated compound. No plastic means no microbeads to ban. With no water, there's no preservative system and no emulsifier holding water and oil together. Our Never List names the rest of what we keep out, and why there's no water in our balms covers the chemistry.
Here's the limit of what I can promise. The FDA says lead and PFAS can both arrive as impurities in raw materials, and that applies to the fats and oils in our jars too. We don't run our own PFAS or heavy-metal panels on finished jars, so I won't print a number we haven't measured. A short list does something narrower. It leaves out the classes these stories turned on: color additives, fluorinated ingredients, plastic beads and mercury compounds. A tallow balm doesn't pull metals or PFAS out of anyone's body. It's cosmetic care, not a treatment, and when exposure is the worry, your provider's plan comes first.
If you came here worried about what rides along in a jar, I'd hand you the shortest list we pour, the Unscented original with no essential oils or fragrance.
Start with Bare Silk ($34), five ingredients and sixty days to disagree.
Questions we hear
Does makeup contain PFAS?
Testing has found PFAS in a lot of it, and labels usually don't say so. A 2021 study by Whitehead and colleagues screened 231 cosmetics from the US and Canada and found high fluorine, their screen for PFAS, in 52%. Foundations led at 63%. Only 8% of the 231 listed any PFAS as an ingredient.
Is there lead in lipstick?
There's trace lead in lipstick, and the FDA handles it as an impurity. In 2010 the FDA tested 400 lipsticks and other lip products sold in the US, and the average was 1.09 ppm. The highest reading across its lip surveys was 7.19 ppm, in one lipstick. Its draft guidance sets a recommended maximum of 10 ppm, which the agency concluded wouldn't pose a health risk.
Why is kohl illegal in the US?
The FDA classes kohl, kajal, surma, tiro and similar eye cosmetics as color additives it has never approved, which makes them illegal. Some are more than half lead by weight, usually as lead sulfide. Studies have found more lead in the blood of children exposed to these products, and the FDA keeps an import alert on eye cosmetics labeled with those names.
Are microbeads banned?
In the US, plastic microbeads are banned from rinse-off cosmetics, toothpaste included. The Microbead-Free Waters Act of 2015 stopped their manufacture by July 1, 2017, and their sale across state lines by July 1, 2018, a year later for over-the-counter drugs. The EU's 2023 rule restricted scrubbing microbeads from October 17, 2023, and it's phasing out other plastic particles in cosmetics through October 17, 2035.
Do your balms contain PFAS or microplastics?
None of our five recipes lists a fluorinated ingredient, a plastic, a pigment or a glitter. With no water, there's no preservative system or emulsifier either. We don't run our own PFAS or heavy-metal panels on finished jars, and the FDA says lead and PFAS can both arrive as impurities in raw materials. So we won't promise zero.
Go deeper
The beef tallow for skin guide covers what a balm does once it's on. How to read a tallow label walks an ingredient list line by line, and sunscreen ingredients people are told to avoid reads the 2021 benzene recalls the way this post reads PFAS. Parabens, phthalates and fragrance covers the other names on the worry list, and ingredients we looked at and left out is our own bench's list.
Sources
- Whitehead HD and colleagues (2021). Fluorinated compounds in North American cosmetics. Environmental Science & Technology Letters, volume 8, issue 7, pages 538 to 544.
- US Food and Drug Administration (2025). Per- and polyfluoroalkyl substances (PFAS) in cosmetics, content current as of December 29, 2025. FDA.
- Minnesota Legislature (2025). Minnesota Statutes, section 116.943 (2025 edition), products containing PFAS. Revisor of Statutes.
- US Food and Drug Administration (2016). Lead in cosmetic lip products and externally applied cosmetics: recommended maximum level, draft guidance for industry. FDA.
- US Food and Drug Administration (2022). Kohl, kajal, al-kahal, surma, tiro, tozali, or kwalli: by any name, beware of lead poisoning. FDA.
- US Food and Drug Administration (2022). Mercury poisoning linked to skin products. FDA Consumer Updates, page content current as of December 21, 2022.
- US Congress (2015). Microbead-Free Waters Act of 2015, Public Law 114-114, approved December 28, 2015. US Government Publishing Office.
- European Commission (2023). Commission Regulation (EU) 2023/2055 of 25 September 2023 amending Annex XVII to REACH as regards synthetic polymer microparticles. EUR-Lex.
Brian is the founder of Craft Tallow, a small-batch tallow skincare line shipped from Cottonwood Heights, Utah, built on 100% grass-fed suet. Questions? Reply to any email from us; it lands with him.