Environmental Legislation - Water

A major difference between PFAS and many other organic pollutants is that most of the substances have a relatively high water solubility, which applies specially to fluorinated sulfonates and acids (e.g. PFOS approx. 550 and PFOA > 3500 mg/l). The aquatic systems therefore often become a sink for these compounds. Since 2013, PFOS is one of the priority substances in the Water Framework Directive (WFD) with permitted annual average values of 0.13 and 0.65 ng/l (2013/39/EU). In the new proposal (COM(2022) 540 final)  a value of 4.4 ng/l PFOA eqv for the sum of 24 PFAS is given. For the groundwater directive (GWD) instead PFAS20 from the drinking water directive (DWD) together with a PFAS4 sum of 4.4 ng/l have been suggested in the compromise proposal (11383/24, June 2024). Still for groundwater this PFAS24 has been introduced as a threshold in the SE regulation SGU-FS 2023:1. SGU has also introduced environmental status classes for PFAS4 and 24 in groundwater. In Dec 2023 PFAS24 was enforced in DK for surface water (Miljøstyrelsen, 2023). Eurofins can, using the new “ultralow” method, achieve reporting limits down to 0.02 ng/l for a number of PFAS in natural waters and thereby a sum of 1.1 ng/l PFOA eqv (incl LOQ) for PFAS24 (i.e. <30% of the proposed EQS value).

Besides WFD/GWD, in Norway (NO) the 12 PFAS on the priority list of the Environment Agency (Miljødirektoratet) are in focus together with six precursors from an earlier list. In DK the same guideline values are used for groundwater as drinking water (Miljøstyrelsen) i.e. PFAS4 – 2 ng/l and PFAS22 – 100 ng/l. In Sweden, SGI (Swe Geotech Inst) has proposed a value for groundwater at contaminated sites based on PFAS4 (2 ng/l) but the draft is currently being subject to an impact assessment. 

Environmental Legislation – Soil, sediment and sludge

Contaminated areas around e.g. fire training sites have been identified in numerous places. In SE SGI (Swe Geotech inst) have published preliminary guideline for sensitive (KM; 3) and less sensitive (MKM; 20 µg/kg DM) land use to be applied for PFAS7. In 2022 SGI calculated new prel guideline values KM (0.25) and MKM (1.2 µg/kg DM) for PFAS4, but these are still not decided upon. In DK there are two soil quality criteria, one for PFAS4 (10) and one for PFAS22 (400 µg/kg DM). In Norway there is a standard (norm) value for PFOS of 100 that likely will be lowered to 2 µg/kg DM, and there are additional EQS values for sediment, down to 0.23 µg/kg DM for PFOS and 71 for PFOA (Miljødirektoratet, 2020).  

PFAS from products can end up in wastewater and sludge. In DK, the same guideline values have been applied for sludge as for soil, but a recent report suggests a PFAS4 guideline value of 15 µg/kg DM or 0.5 µg PFAS4/kg P. It is expected that a formal decision will be taken during 2024. A similar approach is found in Norway where the same value as for soil (100 µg/kg DM) is set as max value for PFOS, PFOA and other PFAS (NIBIO, 2019). Moreover there is a proposal for a limit value in the revised Fertilizer regulation of 40 µg/kg DM for PFOS + PFOA (Mattilsynet, 2024). In 2023 an investigation arranged by the certification body REVAQ was undertaken with the objective to compare sludge concentrations to the DK guidelines and in addition measure some PFAS compounds (e.g 6:2 and 8:2 diPAP) that have been found at relatively high levels in scientific studies. Action limits of 7.5 µg/kg DM for PFAS4 and 25 µg/kg DM for PFAS22 will now be included in the certification program from 2025.

Environmental Legislation – Waste

When it comes to waste there may also be a need to determine PFAS. This applies not least to PFOS, which in the so-called POP regulation (EU 2019/1021) has a “low-POP” value of 50 mg/kg. In 2022 it was decided that in EU PFOA and PFHxS will also receive POP limits, 1 mg/kg for both substances and 40 mg/kg for their precursors. In the Swedish report Avfall Sverige 2019:1 the PFOS POP value of 50 mg/kg is used as hazardous waste guideline value for excavated soil and sediment, and can be applied to the sum of the SE PFAS11 as well.

However, hazardous waste limits are relatively high as compared to relevant levels in many waste treatment processes and landfilling. PFAS is also present in many waste fractions that are not known to be directly polluted. Eurofins has investigated common building materials/waste such as concrete, tiles, flooring and wallpaper. PFAS was detected in about half of the samples, various compounds e.g. PFOS, PFOA and diPAPs showing a wide concentration range 1-1750 µg/kg. Eurofins can both analyze different waste fractions and perform customized leaching tests for PFAS (see PFAS analysis page)