Food and PFAS: the latest guidance from the European Commission
Food and PFAS: the latest Commission guidance
With two measures adopted on 24 August 2022 and published in the Official Journal of the European Union (L221) on 26 August, the European Commission issued the latest guidance and requirements on the control and monitoring of per- and polyfluoroalkyl substances (PFAS) in food.
The reference texts are:
- Implementing Regulation (EU) 2022/1428, signed by Ursula Von der Leyen, President of the Commission;
- Recommendation (EU) 2022/1431, signed by Stella Kyriakides, Commissioner for Health and Food Safety.
Control methods and 2022–2025 monitoring plan
The regulation lays down sampling and analytical methods for PFAS control in a wide range of foods reflecting real consumption habits: fruit, vegetables, starchy roots and tubers, seaweed, cereals, nuts, oilseeds, foods for infants and young children, animal products, soft drinks, wine, and beer.
The recommendation, addressed to EU Member States, calls for PFAS monitoring in food over 2022–2025, highlighting good practices for reduction as well as gaps in detection and toxicity assessment.
PFAS: ECHA definition, persistence and spread
According to the European Chemicals Agency (ECHA), “PFAS” covers thousands of synthetic chemicals widely used in industry and often released into the environment with harmful effects.
PFAS share strong carbon–fluorine bonds, among the toughest in organic chemistry, making them resistant to natural degradation and prone to spreading over wide areas far from their source, while retaining their original properties.
They are often linked to contamination of soil, groundwater, and surface waters, the remediation of which is technically difficult and costly. The environmental emergency stems from their near “indestructibility” and ubiquity, raising serious concerns about long-term accumulation.
Chemical properties and industrial uses
PFAS show highly diverse chemical-physical properties: at normal temperature and pressure, they may be gases, liquids, or high-molecular-weight solid polymers. Some are referred to as long- or short-chain PFAS, but this does not cover all observed structures, which include many subgroups.
Their widespread use is due to functional advantages such as high-temperature stability and surfactant properties, making them ideal as repellents and lubricants. Key sectors include aerospace, automotive, defence, textiles, leather, food-contact materials (FCM), household goods, electronics, firefighting, and medical devices.
Recommendation (EU) 2022/1431 recalls PFAS use in stain-resistant coatings for textiles and carpets, oil-resistant FCM coatings, firefighting foams, extractive chemicals, floor polishes, and pesticides. The most common in food and humans are perfluorooctane sulfonic acid (PFOS – C₈HF₁₇O₃S) and perfluorooctanoic acid (PFOA – C₈HF₁₅O₂), including their salts and related compounds, all already listed under the Stockholm Convention for elimination.
EU members are also urged to monitor perfluorononanoic acid (PFNA – C₉HF₁₇O₂) and perfluorohexane sulfonic acid (PFHxS – C₆HF₁₃O₃S). Norway proposed a PFHxS restriction in 2019, backed by ECHA in 2020, now under Commission review.
EFSA, in 2020, set a new tolerable weekly intake (TWI) of just 4.4 ng/kg bw for PFOA, PFOS, PFNA, and PFHxS.
Other PFAS of concern and animal exposure
Member States should also test for further PFAS (PFBA, PFPeA, PFHxA, PFHpA, PFDA, PFUnDA, PFDoDA, PFTrDA, PFTeDA, PFBS, PFPS, PFHpS, PFNS, PFDS, PFUnDS, PFDoDS, PFTrDS, FOSA), present in food, drinking water, and human serum.
Recommendation (EU) 2022/1431 stresses that animal products contribute significantly to human PFAS exposure, as animals ingest them from feed, soil, and drinking water. If levels exceed Regulation (EC) No 1881/2006 limits, investigations should also cover feed, water, and soil. The Commission notes data gaps on PFAS in feed and the limited number of labs capable of such complex analyses.
Partial substitutions and health issues
Long-chain PFAS have been partly replaced with other PFAS or fluorine-free alternatives. But research has shown that many substitutes are just as harmful.
All PFAS are highly persistent; even stopping emissions today would not remove risks for current and future generations. Their mobility in air and water drives contamination of aquifers. Some accumulate in living tissues, adding toxic effects including on reproduction and fetal development. Others cause cancer or disrupt hormones.
Towards further EU restrictions
Restrictions are increasing. Long-chain PFCAs (C9–C14), their salts and related substances, fall under Regulation (EU) 2021/1297. Germany also proposed a PFHxA restriction in 2021, supported by ECHA.
The Netherlands, Germany, Norway, Denmark, and Sweden are preparing a joint proposal to heavily restrict PFAS use, expected to be filed with ECHA in 2023. Meanwhile, ECHA has also proposed restrictions on firefighting foams, under RAC and SEAC review.
Conclusions: awareness, market, and innovation
PFAS contamination is a declared emergency. The only immediate measures are phasing out PFAS in production and limiting human exposure. But awareness is still low: PFAS lack the “visual drama” of Chernobyl or Fukushima, making them harder to communicate.
Businesses face costs for switching materials or installing controls, but compliance is mandatory. Beyond compliance, change requires stronger consumer and market pressure. Chemistry and materials engineering must provide alternatives, and policy must push demand for safer solutions.
Carmine F. Milone
