PFAS in Food
The necessity to lower the acceptable intake values for PFAS had been discussed for years in the light of new research demonstrating adverse and toxic effects also at very low levels. Moreover, the number of epidemiological studies had increased allowing more direct assessment. In Sep 2020 EFSA (EU food safety authority) published a final scientific opinion. Previous TDI (tolerable daily intake) limit values had included PFOS and PFOA only with separate limits. The new TWI (tolerable weekly intake) value of 4.4 ng/kg BW/week was instead based on the sum of four PFAS. The decision to substitute daily values with weekly was to reflect the accumulative nature of the substances, and the four PFAS were selected considering their, at large, comparable exposure, blood levels and expected toxicity. This also motivated treating them as a group. The drastically lowered acceptable intake value was derived from observed immune system effects in animals and humans such as lowered antibody and T-cell responses at vaccination of children. The intake covers both food and water, and the TWI has already in some cases formed the basis for or motivated new regulation. The four PFAS (PFAS4) comprises:
PFOS - Perfluorooctane sulphonic acid
PFOA - Perfluorooctanoic acid
PFNA - Perfluorononanoic acid
PFHxS - Perfluorohexane sulphonic acid
Limit values for PFAS levels in food have been decided by the EU Commission and apply to animal foods such as meat, fish, crustaceans and eggs (Regulation (EU) 2022/2388 amending (Regulation (EU) 2023/915). Limit values came into force on 1 Jan 2023 implying that food containing more PFAS than the limit value may not be sold. There is already a limit value for drinking water (see below) and the European Food Safety Authority (EFSA) assesses that many people in Europe are ingesting too much PFAS from water and various foods.
The companies are responsible for ensuring that the limit values are not exceeded in their food. Authorities that control food companies can decide that food must be removed from the market if it contains more PFAS than the limit value allows. In total, the regulation contains limits for four individual PFAS and the sum of these. The substances are the same as the ones EFSA established an intake value for (TWI).
Table of allowed maximum values. Annex I to Regulation (EU) 2023/915, section 4 “Halogenated persistent organic pollutants”
|
Foodstuffs |
Maximum levels in µg/kg wet weight |
|||||
|
PFOS1 |
PFOA1 |
PFNA1 |
PFHxS1 |
Sum of PFAS42 |
||
|
10.1 |
Eggs |
1.0 |
0.30 |
0.70 |
0.30 |
1.7 |
|
10.2 |
Fishery products and bivalve molluscs |
|
|
|
|
|
|
10.2.1 |
Fish meat |
|
|
|
|
|
|
10.2.1.1 |
Muscle meat of fish, except those listed under 2.1.2 and 2.1.3. |
2.0 |
0.20 |
0.50 |
0.20 |
2.0 |
|
10.2.1.2 |
Muscle meat of the following fish3, in case they are not intended for the production of food for infants and young children |
7.0 |
1.0 |
2.5 |
0.20 |
8.0 |
|
10.2.1.3 |
Muscle meat of the following fish4, in case they are not intended for the production of food for infants and young children |
35 |
8.0 |
8.0 |
1.5 |
45 |
|
10.2.2 |
Crustaceans and bivalve molluscs: |
3.0 |
0.70 |
1.0 |
1.5 |
5.0 |
|
10.3 |
Meat and edible offal |
|
|
|
|
|
|
10.3.1 |
Meat of bovine animals, pig and poultry |
0.30 |
0.80 |
0.20 |
0.20 |
1.3 |
|
10.3.2 |
Meat of sheep |
1.0 |
0.20 |
0.20 |
0.20 |
1.6 |
|
10.3.3 |
Offal of bovine animals, sheep, pig and poultry |
6.0 |
0.70 |
0.40 |
0.50 |
8.0 |
|
10.3.4 |
Meat of game animals, with the exception of bear meat |
5.0 |
3.5 |
1.5 |
0.60 |
9.0 |
|
10.3.5 |
Offal of game animals, with the exception of bear offal |
50 |
25 |
45 |
3.0 |
50 |
1 The maximum level applies to the sum of linear and branched stereoisomers, whether they are chromatographically separated or not.
2 EFSA4-PFAS: PFOS, PFOA, PFNA, PFHxS - For the sum of PFOS, PFOA, PFNA and PFHxS, lower bound concentrations are calculated on the assumption that all the values below the limit of quantification are zero.
3 Baltic herring (Clupea harengus membras), Bonito (Sarda and Orcynopsis species), Burbot (Lota lota), European sprat (Sprattus sprattus), Flounder (Platichthys flesus and Glyptocephalus cynoglossus), Grey mullet (Mugil cephalus), Horse mackerel (Trachurus trachurus), Pike (Esox species), Plaice (Pleuronectes and Lepidopsetta species), Sardine and pilchard (Sardina species), Seabass (Dicentrarchus species), Sea catfish (Silurus and Pangasius species), Sea lamprey (Petromyzon marinus), Tench (Tinca tinca), Vendace (Coregonus albula and Coregonus vandesius), Silverly lightfish (Phosichthys argenteus), Wild salmon and wild trout (wild Salmo and Oncorhynchus species), Wolf fish (Anarhichas species)
4 Anchovy (Engraulis species), Babel (Barbus barbus), Bream (Abramis species), Char (Salvelinus species), Eel (Anguilla species), Pike-perch (Sander species), Perch (Perca fluviatilis), Roach (Rutilus rutilus), Smelt (Osmerus species), Whitefish (Coregonus species)
EFSA and other bodies have also identified the need of new and more comprehensive data on PFAS concentrations and composition of food within the union. An EU recommendation, (EU) 2022/1431, was published in Aug 2022 calling for monitoring of a wide range of foodstuffs between 2022-25. The recommendation does not only cover animal foods, but for example fruit and vegetables, cereals, beverages and baby food. The screening is to be performed in collaboration between authorities and food business operators. The analytical scope is not only limited to PFAS4, in total 27 individual PFAS substances and two classes are listed to be determined if possible.
For some kinds of food there are also indicative PFAS4 levels given. If these values are exceeded further investigations should be initiated.
An Implementing Regulation (EU) 2022/1428 that sets out requirements for sampling and analysis has also been published. It concerns primarily samples that have been taken as part of an official control. However, applicable parts such as sample preparation and analysis are considered and followed in our work. Eurofins SE has a wide experience of e.g. the requirements for the official pesticide control.
Read more and download regulations on the links below:
EU regulation max limits
EU recommendation screening
EU implementing regulation
EU drinking water directive (DWD)
Press release (Swe Food Agency)
New Swe drinking water regulation