EU PFHxA Restriction in Tattoo Aftercare: What Studios and Artists Need to Know from October 10, 2026

PFAS Compliance Quiz

1. 1. Under entry 79 of REACH Annex XVII, what are the maximum concentration limits permitted for PFHxA (and its salts) and PFHxA-related substances in cosmetic aftercare products?

   • ✓ 25 ppb or more for PFHxA and its salts, and 1,000 ppb or more for PFHxA-related substances — Entry 79 establishes specific concentration thresholds measured in homogeneous material, setting 25 ppb for PFHxA and its salts alongside 1,000 ppb for related degrading substances.
   • • 1,000 ppb or more for PFHxA and its salts, and 25 ppb or more for PFHxA-related substances — This reverses the threshold levels, as the strict 25 ppb threshold applies to direct PFHxA compounds while the higher limit applies to broader related substances.
   • • 50 ppb or more for PFHxA and its salts, and 500 ppb or more for PFHxA-related substances — These concentration numbers do not correspond to the legal thresholds established in Regulation (EU) 2024/2462.
   • • Zero parts per billion (0 ppb) complete prohibition for all fluorinated compounds — Entry 79 is a targeted concentration-based restriction rather than a blanket zero-tolerance ban on every fluorinated chemical.

2. 2. On what date do the EU entry 79 restriction limits officially begin applying to cosmetic aftercare products and public mixtures?

   • ✓ October 10, 2026 — Commission Regulation (EU) 2024/2462 mandates October 10, 2026, as the operational start date for restrictions on cosmetics and general public mixtures.
   • • January 1, 2026 — January 1, 2026, marks the effective date for France's separate national PFAS law rather than the broader EU-wide REACH rule.
   • • July 1, 2028 — July 1, 2028, is the effective date for Illinois's Chemicals in Cosmetic Products Act in the United States.
   • • December 29, 2025 — December 29, 2025, refers to the publication date of the US FDA's report on cosmetic PFAS under MoCRA.

3. 3. How does EU entry 79 treat existing tattoo aftercare stock that was already placed on the market before October 10, 2026?

   • ✓ The restriction does not apply to products that were already placed on the market prior to the deadline. — EU entry 79 specifically exempts existing stock placed on the market before October 10, 2026, allowing studios to continue using or selling inventory held prior to that date.
   • • All inventory held by studios must be recalled and destroyed immediately on October 10, 2026. — The regulation explicitly excludes existing stock already on the market, avoiding forced product recalls for pre-existing shelf inventory.
   • • Existing stock can only be sold or used until December 31, 2026, after which it must be discarded. — This sunset provision applies specifically under France's national law for products made before 2026, not under the main EU REACH entry 79 rule.
   • • Existing stock is permitted only if the studio re-labels the products with a PFAS warning sticker. — Entry 79 imposes no re-labeling or warning tag mandates for pre-existing market inventory.

4. 4. Why are tattoo aftercare products classified and sold as CE-marked medical devices exempt from REACH Annex XVII entry 79?

   • ✓ They are regulated under the EU Medical Device Regulation (EU) 2017/745 rather than cosmetic rules. — Aftercare products classified and CE-marked as medical devices fall under a separate regulatory framework, placing them outside the scope of REACH entry 79 cosmetics restrictions.
   • • Medical devices are composed entirely of plant oils and are universally PFAS-free by definition. — Exemption status is determined by regulatory classification under medical device laws, not an inherent chemical guarantee of plant-based ingredients.
   • • Entry 79 grants a temporary two-year deferral specifically for medical-grade creams. — The exclusion for medical devices is structural due to overarching regulatory domain, rather than a temporary grace period.
   • • Medical devices are regulated exclusively by REACH Annex XVII entry 75 governing tattoo inks. — Entry 75 specifically regulates hazardous substances in tattoo inks and permanent make-up, not medical devices.

5. 5. How does France's national PFAS law (n° 2025-188) differ from the broader EU entry 79 restriction regarding cosmetic aftercare?

   • ✓ France's law takes effect earlier on January 1, 2026, and covers the PFAS family broadly rather than just PFHxA. — French law n° 2025-188 establishes an earlier implementation date and targets the broader PFAS family, whereas entry 79 focuses specifically on PFHxA, its salts, and related substances.
   • • France's law applies strictly to tattoo inks while excluding cosmetic creams and balms. — French law targets cosmetics broadly, whereas tattoo inks are governed under distinct regulations like REACH entry 75.
   • • France's law sets a blanket zero-trace ban without allowing any decree concentration thresholds. — The French statute explicitly operates with concentration thresholds set by decree, ensuring trace amounts below those levels are not captured.
   • • France's law delays all restrictions until 2032 to match future US state legislation. — France's law takes effect on January 1, 2026, long before US state timeline targets like Illinois's 2032 legislation.

6. 6. Under France's national law, until what date could cosmetic products manufactured prior to January 1, 2026, still be placed on the French market?

   • ✓ December 31, 2026 — French law n° 2025-188 permits cosmetic products manufactured prior to January 1, 2026, to be placed on the French market until December 31, 2026.
   • • October 10, 2026 — October 10, 2026, is the enforcement date for the EU REACH entry 79 restriction, not the cutoff date for France's transition period.
   • • July 1, 2028 — This date reflects the enactment timeline for Illinois state cosmetic legislation in North America.
   • • January 1, 2032 — January 1, 2032, relates to the separate Illinois PFAS Reduction Act deadline.

7. 7. What is the primary scope difference between entry 75 and entry 79 of REACH Annex XVII?

   • ✓ Entry 75 targets hazardous chemicals in tattoo inks, while entry 79 targets PFHxA in cosmetics and public mixtures. — REACH Annex XVII contains distinct entries, where entry 75 governs tattoo inks and permanent make-up, while entry 79 sets specific rules for PFHxA in cosmetic aftercare and general mixtures.
   • • Entry 75 is an Illinois state law, whereas entry 79 is a French national statute. — Both entry 75 and entry 79 are annex entries within European REACH regulations, not US or individual national laws.
   • • Entry 75 applies exclusively to textiles and leather, while entry 79 applies to medical devices. — Entry 75 addresses tattoo inks, whereas medical devices are governed under MDR rather than entry 79.
   • • Entry 75 allows unlimited PFHxA concentrations, whereas entry 79 bans all natural plant waxes. — Neither entry bans natural plant waxes, and entry 75 does not exist to permit unrestricted PFHxA levels in cosmetics.

8. 8. When checking aftercare product ingredient lists, what naming patterns commonly indicate fluorinated ingredients that require supplier verification?

   • ✓ INCI names containing 'fluoro' or 'perfluoro', as well as PTFE — Fluorinated ingredients typically include 'fluoro' or 'perfluoro' prefixes in their formal cosmetic nomenclature, with PTFE being a common fluorinated polymer.
   • • INCI names containing 'aqua', 'glycerin', or plant lipid oils — These terms describe common water-based and plant-derived carrier ingredients that naturally contain no PFAS fluorinated chains.
   • • INCI names ending in '-cone' or '-xane', indicating silicone compounds — Silicone suffixes denote synthetic silicon-oxygen polymers rather than fluorinated PFAS substances.
   • • INCI names listing parabens, phthalates, or alcohol compounds — Parabens and phthalates belong to chemical categories distinct from fluorinated perfluoroalkyl structures.

9. 9. What documentation should a studio request in writing from suppliers to verify that new aftercare orders comply with REACH entry 79?

   • ✓ A written statement of compliance from the brand or an official laboratory test report — Studios can establish due diligence by keeping formal documentation such as brand compliance letters or laboratory test results on file.
   • • A verbal promise made by a sales agent during a routine supply call — Verbal assurances do not provide written verification or lab evidence required to demonstrate compliance with REACH entry 79.
   • • An invoice showing that the product originated from a US supplier — US origin does not guarantee compliance with EU REACH standards, as the US FDA has no federal prohibition on these cosmetic ingredients.
   • • A self-applied 'PFAS-free' sticker on the outer packaging without backing data — Marketing claims or stickers without verifiable testing data or formal documentation fail to provide reliable compliance verification.

10. 10. What restriction takes effect on July 1, 2028, under Illinois's Chemicals in Cosmetic Products Act (HB 3409)?

    • ✓ It prohibits knowingly manufacturing or selling cosmetics with 13 named PFAS intentionally added. — Illinois HB 3409 specifically bans the intentional addition of 13 listed PFAS chemicals in cosmetics starting July 1, 2028.
    • • It mandates that all cosmetic products follow EU REACH Annex XVII entry 79 concentration limits. — Illinois HB 3409 is state-level US legislation targeting intentional addition, operating independently of EU REACH limits.
    • • It institutes a total federal ban across all 50 US states on PTFE and silicone balms. — The law is a state enactment limited to Illinois rather than a federal ban, and it targets specific named PFAS rather than silicone compounds.
    • • It requires tattoo aftercare balms to receive CE-marking under European medical guidelines. — CE-marking is a European conformity designation under EU law, having no legal application under Illinois state statutes.