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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 labelling.

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.”

Other proposed updates include updating requirements for fragrances.

The SMC asked experts to comment on the proposal.

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 a 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 jackets).

“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 interest.

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

“The 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 cosmetics.

“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 quantities.”

No conflicts of interest declared.

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

“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.

“Cosmetics 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 interest.

“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 consumers.

“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 absorption.

“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 assessments of cosmetic related chemicals for Te Whatu Ora.”

All: No conflict of interest.

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

“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 2025.

“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 cosmetics.

“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.”

No conflict of interest.