PFAS testing by EU regulations: overview of restrictions by product category

Published March 3, 2023 | Updated March 1, 2024

Per- and polyfluoroalkyl substances (PFAS) are often described as “forever chemicals” due to their persistence. Rising concern over detrimental health effects and accumulation in the environment has led to tightening PFAS restrictions over the years, culminating in a recent European Chemicals Agency (ECHA) proposal calling for a gradual ban of over 10,000 PFAS compounds in Europe.1

While the full PFAS ban may not pass due to industry pressure in the near future2, existing regulations place limits on the presence of selected PFAS compounds in various products and materials, including food, drinking water, and consumer products. PFAS testing of water, fish, and other environmental samples will also remain important for years to come due to the compounds' persistence.

What are so-called forever chemicals?

PFAS, colloquially known as “forever chemicals” are man-made organic compounds that have been used in consumer products since the 1940s due to their usefulness in repelling water, dirt, and grease. Some common PFAS-containing products include non-stick frying pans, firefighting foams, water-proof textiles, and paper and board food packaging with grease-resistant coatings.

Due to their chemical structure, PFAS degrade very slowly. This leads to their accumulation in nature due to industrial waste and the degradation of consumer products. Humans get exposed to PFAS mainly through food and drinking water, although exposure can also occur through the air and using products containing the chemicals.

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What are the health effects of PFAS?

The impacts of PFAS on human health have been increasingly studied since the beginning of the 2000s. Exposure to elevated amounts has been linked to detrimental effects including increased risk of certain types of cancer, reduced response to vaccines, and increased cholesterol levels.3 Research has been focused, however, on a few of the most well-known compounds (mostly PFOS and PFOA). This means that very little is known about the effects of the thousands of other chemicals within the group.

Current restrictions on the use of PFAS in the EU

The use of the most harmful PFAS compounds has been restricted both globally and within the EU for more than a decade. The Stockholm Convention on Persistent Organic Pollutants (POPs) forbids the use of PFOS, PFOA, PFHxS, and related compounds, apart from specific uses where they may not be effectively replaced. Exemptions have been granted for products including firefighting foams and medical devices, but many of these are about to expire in the upcoming years.4

Several groups of PFAS compounds have also been added to the REACH Regulation Candidate List.5 If chemicals included in the Candidate List are used in products, the producer or importer has to notify ECHA and provide customers with sufficient information on the safe use of the product.

Maximum PFAS concentrations in food and drinking water

At the beginning of 2023, two pieces of legislation came into force in the EU to limit human exposure to harmful amounts of PFAS. The concentrations of PFAS compounds in food are regulated by Commission Regulation (EU) 2022/2388, while Directive (EU) 2020/2184 limits the presence of PFAS in drinking water.

The limits on PFAS in selected food products are listed in Table 1.6 If higher concentrations are discovered in laboratory tests, the product has to be removed from the market.

Table 1: Maximum levels of PFAS per food category

Foodstuff

PFOS, μg/kg

PFOA, μg/kg

PFNA, μg/kg

PFHxS, μg/kg

Sum of the 4 PFAS, μg/kg

Eggs

0.3

0.7

0.3

1.7

Anchovy, babel, bream, char, eel, pike-perch, perch, roach, smelt, and whitefish

35

8

8

1.5

45

Baltic herring, bonito, burbot, pike, plaice, sardine, seabass, wild salmon and trout, etc.* 

7

1

2.5

0.2

8

Other species of fish & all fish intended for young children

2

0.2

0.5

0.2

2

Crustaceans and molluscs

3

0.7

1

1.5

5

Meat of bovines, pigs, and poultry

0.3

0.8

0.2

0.2

1.3

Meat of sheep

1

0.2

0.2

0.2

1.6

Offal of sheep, pigs, poultry, and bovine animals

6

0.7

0.4

0.5

8

Meat of game animals

5

3.5

1.5

0.6

9

Offal of game animals

50

25

45

3

50

* In addition to these, the category covers European sprat, flounder, grey mullet, horse mackerel, pilchard, sea catfish, sea lamprey, tench, vendace, silverly lightfish, and wolf fish.

The revised EU Drinking Water Directive specifies a maximum concentration of all PFAS compounds combined, which is 0.5 μg per liter of water. Alternatively, member states can monitor the sum of 20 selected PFAS compounds, for which the maximum is 0.1 μg/l.7

PFAS prohibited in cosmetics

Several PFAS compounds are listed as prohibited substances in the consolidated version of the EU Cosmetics Regulation. If any of these substances are found, even in trace quantities, the manufacturer has to prove that their presence is technically unavoidable. Otherwise, the product may not be sold in the EU.

The prohibited substances include:8

  • Perfluorooctane sulfonic acid (PFOS)

  • Perfluorooctanoic acid (PFOA)

  • Perfluorononanoic acid (PFNA), its sodium, and its ammonium salts

PFAS analysis for assessing regulatory compliance

PFAS testing is typically performed using the LC-MS method, which combines liquid chromatography and mass spectrometry. With LC-MS, it is possible to detect more than 30 PFAS compounds in water with a detection limit of 0.01 to 0.05 µg/l. This makes the method well-equipped for compliance testing by EU regulations.

Measurlabs offers PFAS testing for plastic materials, firefighting foams, food, drinking water, cosmetics, consumer products, and environmental samples. Other sample types can also be analyzed upon request. You can ask our experts for more information and request a quote through the form below or at info@measurlabs.com. We will get back to you within one business day.

References:

1 ECHA’s draft proposal recommends a full ban on PFAS compounds with an application-dependent transition period from 18 months to 12 years. The proposal was submitted by Germany, the Netherlands, Sweden, Norway, and Denmark. The European Commission’s decision on the possible adoption of the proposal is expected in 2025.

2 The Guardian reported in October 2023 that the European Commission had dropped the PFAS ban proposal from its 2024 work program following intense industry pressure.

3 The European Environment Agency provides a summary of current knowledge on the health effects of PFAS. 

4 List of substances restricted by the Stockholm Convention. See also Annex I to the POP Regulation (EU) 2019/1021, which outlines the exemptions and derogations for using PFOA, PFOS, PFHxS, their salts, and related compounds.

5 ECHA’s Candidate List of substances of very high concern

6 These limits are outlined in the Annex of Regulation (EU) 2022/2388.

7 The maximum concentrations for PFAS Total and Sum of PFAS are listed in Part B of Annex I to Directive (EU) 2020/2184.

8 Prohibited substances are listed in Annex II of Regulation (EC) 1223/2009. PFOS is listed under reference number 1493, PFOA under 1561, and PFNA under 1636.

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