Navigating the PFAS Regulatory Maze

The global PFAS regulatory landscape

The European Union and United States are leading the way in PFAS regulation, adopting increasingly stringent measures to address the presence of these chemicals in food and water.

EU regulatory landscape

The EU takes a proactive and comprehensive approach to mitigate the risks posed by PFAS. A proposed ban on a wide range of PFAS, including thousands of the most concerning compounds, has been submitted by five member states and is currently under review by the European Chemicals Agency (ECHA). This initiative aims to minimise risks to consumers, protect brand integrity, and ensure food supply chain safety by setting strict limits and testing requirements.

The European Food Safety Authority (EFSA) has established a tolerable weekly intake (TWI) of 4.4ng per kg of body weight for four specific PFAS compounds: PFOS, PFOA, PFNA and PFHxS. 4 Based on this TWI, the EU has set maximum limits for these compounds in various food categories, including eggs, seafood, meat and edible offal, as stipulated in EU Regulation 2023/915. Additionally, the European Drinking Water Directive includes limits for 20 PFAS compounds, with a total limit of 500 ng/L for all PFAS combined.

Currently, the EU actively monitors and controls PFAS levels in food through various measures:

• EU REGULATION 2023/915: establishes maximum levels for certain PFAS in specific food categories.
• 6 RASFF NOTIFICATIONS : The Rapid Alert System for Food and Feed (RASFF) monitors and reports food safety issues within the EU. As shown in Figure 1, a search for "PFAS" on the RASFF portal reveals numerous notifications related to PFAS contamination in food products, leading to product recalls and withdrawals.
• ONGOING MONITORING AND RESEARCH : The EU continuously assesses PFAS levels in food to inform future regulations.

These measures demonstrate the EU's commitment to addressing PFAS contamination in food and protecting consumer health. Food manufacturers operating in the EU must stay proactive in PFAS management strategies to ensure compliance.

US regulatory landscape

The US takes a multi-pronged approach to PFAS regulation, with both federal and state-level regulations playing a significant role, presenting unique challenges for food and beverage companies

• FEDERAL REGULATIONS: The US Food and Drug Administration (FDA) monitors and regulates PFAS in food. In 2024, the US Environmental Protection Agency (EPA) established strict limits for PFOA, PFOS, PFHxS, PFNA and HFPO-DA in drinking water under the National Primary Drinking Water Regulation.7 Recent FDA actions include:
• Product recalls: The FDA has issued several recalls of food products due to PFAS contamination, including recalls of smoked clams and various frozen food items that were found to be contaminated through production water. The most

Risks in PFAS management

Managing the risks associated with PFAS contamination requires a comprehensive approach. Food and beverage companies must be aware of the potential consequences of non-compliance, as well as the challenges in identifying, monitoring and controlling PFAS throughout the supply chain.