PFAS: wait-and-see Vs precautionary principle

If you had to decide whether something is safe based on limited data, which way would you default?

Let's look at recent regulatory developments re "Teflon-like" chemicals (PFAS) in cosmetics and medical devices. Per- and polyfluoroalkyl substances (PFAS) are highly inert synthetic chemicals which makes them sought after for both everyday uses and specialist ones. However, they are so inert that biology cannot break them down. They persist in the environment and accumulate in creatures at the top of the food chain: us.

The regulatory approach to PFAS, also called Forever Chemicals, is another staggering example of the US vs. EU cultural divide.

U.S. wait-and-see approach
🇺🇸 Context: In 2024, FDA launched the Modernization of Cosmetics Regulation Act (MoCRA) which required registration of all cosmetics and listing of all their ingredients. This allowed FDA a fresh overview on PFAS' use in cosmetics, which inspired recent research.
🇺🇸 Research: A December 2025 report revealed that 51 types of PFAS are intentionally used in 1,744 cosmetic formulations in the US, commonly in makeup and even baby products.
🇺🇸 Conclusion: Due to a lack of critical toxicological data and acute toxicity, the safety of 76% of these compounds could not be definitively established. FDA deemed current evidence insufficient to justify a federal ban, opting instead for continued monitoring.
🇺🇸 Note: The FDA excluded environmental considerations and the assessment of unintentional degradation products, which are often the most harmful (e.g., PFOA and PFOS).

EU precautionary principle
🇪🇺 Context: The EU is already phasing out PFAS over concerns regarding long-term health effects and environmental contamination.
🇪🇺 Research: Rising concentrations in water streams and human blood (even in teenagers) are increasingly suspected to suppress the immune system and increase risks of cancer, infertility, thyroid dysfunction, and metabolic dysregulation.
🇪🇺 Conclusion: Action and monitoring stepped up at national and union level.
> This month, France has banned PFAS in all cosmetics (as well as clothing textiles and ski waxes).
> Yesterday, the European Environment Agency (EEA) kicked off a mandatory EU-wide program to systematically monitor PFAS in drinking water.
> Meanwhile, European Chemicals Agency (ECHA) is evaluating a proposal to ban 10,000 PFAS as a broad category, with stricter concentration limits (ppb levels) expected by October 2026.
🇪🇺 Note: The EU had already restricted all PFAS and even banned some under the REACh and the POPs regulations (which also impact allowed limits in medical devices under MDR).

Which side would you take? Personally, I’m leaning EU on this one.

Sources:
- FDA’s report
- EEA programme
- Forever pollution project (image credits)