PFAS

The PFAS present in plant protection products do not necessarily have the same effects as the substances of concern that generate so much controversy. Some frequently asked questions are answered below (March 2024).

  1. What are PFAS?
  2. Why are PFAS used?
  3. Why are PFAS in the news?
  4. Are PFAS used in plant protection products?
  5. Do PFAS in plant protection products pose a risk to public health or the environment?
  6. What is being done at European level to reduce the risks posed by PFAS?
  7. Is Belgium taking additional measures for plant protection products?
  8. Is the share of plant protection products in total PFAS use important?
  9. Where can I find more information on PFAS?

1.What are PFAS?

PFAS stands for per- and polyfluoroalkyl substances. They are a diverse group of synthetic substances used for many different applications. Given the broad definition of PFAS, it is not obvious to make general statements about their properties.

It is therefore useful to highlight that there has been some confusion caused by the "broad" definition of this group of molecules. There is a legitimate concern about the pollution of our environment with perfluoroalkyl substances, with PFOA, PFNA, PFHxS and PFOS as examples.

An extended definition (from ECHA) also includes polyfluoroalkyl substances, which correspond to a number of active substances used as plant protection products, but the structures, and hence properties, are broadly quite different.

A useful summary regarding the uses and classifications of PFAS can be found in this OECD document.

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2.Why are PFAS used?

PFAS are designed to be difficult to degrade, or heat-resistant or water-repellent, which can make them useful for manufacturing e.g. non-stick pans, fire extinguishers and rainwear. In plant protection products, they can provide long-lasting and improved efficacy. An overview of the main uses and quantities in Belgium is given in this report.)

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3.Why are PFAS in the news?

There are concerns about the potential harmful effects of PFAS on human health and the environment. Some PFAS are highly persistent, meaning they can remain in the environment for a long time. Some PFAS can also bioaccumulate, meaning they can accumulate in living organisms. There are so many different substances in this group that the toxicity of all of them is not yet sufficiently known. All this together makes it difficult to predict what the long-term effects will be, which is obviously an undesirable situation.

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4.Are PFAS used in plant protection products?

Yes, PFAS are used in a number of plant protection products. Plant protection products are compound mixtures, and both the active substance and the other ingredients can be PFAS.

In Belgium, there are 32 active substances in plant protection products that, according to the broad definition, are PFAS (see also a list of those active substances with their structure).  As mentioned under question 1, these are polyfluoroalkyl substances, which are very different from perfluoroalkyl substances. Only TFA (trifluoroacetic acid) can be considered as a perfluorinated substance , but this is a degradation product of a number of active substances of plant protection products so its effects are also assessed when those substances are approved. Moreover, it is also an important degradation product of numerous other products that are not plant protection products.

There are also a number of other ingredients present in plant protection products on the Belgian market that are PFAS. This concerns only three substances present in four products, so very limited.

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5.Do PFAS in plant protection products pose a risk to public health or the environment?

Plant protection products (including polyfluorinated ones) are strictly controlled for their safety to human health and the environment. The maximum concentration that can be present on a crop is determined, taking into account the authorised uses and in such a way that there is no negative impact on consumer health.

In short, based on current knowledge, the safety margin between residue levels in food and possible effects in consumers is sufficient.

Also for environmental exposure, it is guaranteed for all plant protection products that their concentrations in the environment only have effects below the legal standards.

PFAS from plant protection products do not necessarily have the same environmental or health impact as PFAS from other sources, given the diverse group of PFAS.

It should be emphasised that an active substance is only approved if it is not characterised as a very persistent and very bioaccumulative substance (vPvB). The legislation on plant protection products thus very explicitly prevents such substances from being sold and used.

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6.What is being done at European level to reduce the risks posed by PFAS?

The European Commission has made a proposal to restrict the use of PFAS. Currently, this proposal foresees that PFAS would be banned except for some exceptions, such as pharmaceuticals, active substances for plant protection products and the like. This proposal is still pending and is a source of scientific debate.

This would result in the disappearance of PFAS as coformulants of plant protection products (their occurrence in these is extremely limited), but thus not necessarily as active substances.

The reason why exemptions are provided for some categories of substances is that these categories are subject to a strict authorisation framework, which excludes an unacceptable risk for a substance. Thus, for all active substances of plant protection products, persistence, toxicity and bioaccumulation are evaluated prior to any authorisation.

On 12/01/2021, the Directive on the quality of water intended for human consumption came into force. It imposes a maximum concentration in drinking water of 0.5 µg/l for all PFAS combined, and an even lower standard of 0.1 µg/l for specified PFAS considered risky for human consumption. According to this legislation, the European Commission had to provide an analytical method for this by 12/01/2024, and Member States have to take measures by 12/01/2026 to ensure that water for human consumption meets this requirement. Implementing this legislation is a regional competence in Belgium. It is important to note that this limit is not specific to PFAS originating from plant protection products, but to PFAS in general.

In addition, Europe has provided for general maximum limits for PFAS in food (also for PFAS not originating from plant protection products) through EU Regulation 2023/915. 

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7.Is Belgium taking additional measures for plant protection products?

Regarding active substances, Belgium awaits European measures and will implement them when they are in place. In Belgium, plant protection products containing PFAS are evaluated according to existing legal criteria, ensuring acceptable use. Active substances authorised in application of European legislation cannot simply be banned nationally, even if they contain PFAS.

With regard to other ingredients in plant protection products, Belgium is also awaiting the general ban of PFAS at EU level, which will then be translated into the inclusion of PFAS on the list of banned ingredients so that they will disappear from the composition of plant protection products throughout the EU.

However, the Federal Government fully supports the initiative to further refine the risk assessment of TFA (see question 4) based on field measurements and any new data of concern that will be followed up on a regular basis, as for all other plant protection products.

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8.Is the share of plant protection products in total PFAS use important?

In Belgium, according to a report dated December 2023, an 8330 tons of PFAS would be used on an annual basis.

Based on sales figures of plant protection products, we can state that the share of PFAS-plant protection products in this is less than 5%.

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9.Where can I find more information on PFAS?

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