This week our new report reveals an alarming rise in PFAS pesticide residues in fruit and vegetables. PFAS pesticides can harm our health and the environment. Pesticide producers umbrella organisation CropLife says their use is safe and well regulated. We contest this statement. These pesticides and their breakdown products are toxic and persistent. The officially allowed residue levels are far too high since the cocktail effect on our health and environment is not taken into account. Their use leads to direct PFAS contamination of water, soil, our food and living organisms including humans.
In a statement on their Dutch website CropLife admits that the chemical design of active substances with a PFAS molecular structure is intentional. This exposes the industry's full awareness of PFAS presence in pesticides while it is unknown for most regulators, their users (farmers) and the public. Even the label of the pesticides does not mention that they are a PFAS. ‘Farmers don’t have to know, it is safe’, is the approach by the producers. However, many farmers would like to know what they actually spray on their fields.
Alleged necessity of PFAS in pesticides
CropLife argues for the necessity of introducing this fluorinated backbone, with a strong carbon-fluoride bond, in the structure of pesticide substances. This is meant to enhance their stability and effectiveness. However, the stability provided by PFAS and praised by Croplife translates into environmental persistence. Combined with their toxic pesticidal action by design, the very long lifespan of PFAS poses long-term threats to ecosystems and humans, who are gradually exposed to rising levels of PFAS. CropLife's emphasis on ‘effectiveness’ as a pesticide disregards the broader implications of PFAS contamination for human health, animal health and the environment.
The use of PFAS pesticides results in a significant PFAS environmental legacy considering the tons sold and spayed each year in open fields. In 2021, PFAS pesticides sold reached 2 332 tons in France, 1 450 tons in Germany, 221 tons in the Netherlands and 220 tons in Belgium.
PFAS pesticides represent 16% of EU-approved synthetic active substances. This leaves conventional farmers with 84% of other approved substances. This means PFAS pesticides are absolutely not necessary to grow crops. However, pesticides should only be used as a last resort if all preventive measures fail. According to Integrated Pest Management (IPM), which is a requirement for all Member States (see Directive 2009/128/EC), chemical pesticides must only be used once cultural, mechanical and biological methods of prevention and control of “pest organisms” have failed. IPM has been proven to be a very efficient way to protect crops, while being a safe and sustainable way of food production.
PFAS pesticides are not safe and not adequately regulated
According to CropLife, the risk assessment of PFAS pesticides have found them to be safe for humans and the environment. They argue that PFAS pesticides are not declared to be combined Persistent Bioaccumulative and Toxic (PBT) substances, according to EU Pesticides Law (EC) Regulation 1107/2009. Therefore, in Croplife’s vision, there should be no concern at all, neither for the short term, nor for the long-term exposure.
These statements are incorrect. The fact that PFAS pesticides are regulated by the Pesticides Law does not mean that they are sufficiently and adequately regulated. PFAS active substances have been assessed in the light of pesticide approval criteria. In terms of persistence, these require that only persistent organic pollutants (POPs), combined PBT or very persistent, very bioaccumulative (vPvB) substances are banned. However, active substances that are persistent and toxic, or whose metabolites are persistent, are approved. This is the case even if these substances have been designed to be toxic to certain organisms that are considered pests and are also toxic to non-target organisms.
However, this does not mean that they are safe. Persistence alone and especially combined with toxicity or mobility in soil and water raises serious concerns. A report (1) by PAN Europe and Générations Futures published in November 2023 revealed that many PFAS pesticide substances were approved although significant doubt about their toxicity remained. For example on the endocrine disrupting properties and environmental impact. Considering how long PFAS stay in the environment and within living organisms (including humans), this is worrying. Especially combined with the inevitable exposure to a cocktail of chemicals in today's world.
The EU has already presented a ‘restriction proposal of PFAS’, to phase out all PFAS, recognising the serious risks they pose for humans and the environment. However, PFAS pesticides have been excluded from the proposal, wrongly assuming that these would anyway be regulated under the Pesticides Law. This, however, is not the case. The Pesticide Law must be aligned with this more protective approach to ensure that persistent synthetic pesticide substances and/or persistent substance metabolites but also persistent and mobile (PMT/vPvM) pesticides substances are banned. Moreover, there is an urgent need and overdue legal obligation to address mixture effects, which are directly relevant for persistent chemicals like PFAS.
Chronic toxicity
Chronic toxicity is generated by long-term exposure to these persistent substances. This is not sufficiently assessed in the context of pesticide risk assessment. At the approval level, the longest and most complete tests to assess toxicity to humans required for active substances last two years and are done on adult animals (long-term toxicity and cancer studies). However, these are for occupational exposure and have certain limitations. They are not carried out on metabolites such as the very persistent trifluoroacetic acid (TFA), which most PFAS pesticides emit.
Moreover, pesticide risk assessment does not assess the risk of cocktail effects. This arises from a combined exposure to several chemicals, including many pesticides that end up as residues in food. This is a violation of the legal requirement of EU Pesticides Law as well as EU Law on MRLs (Maximum Residue Limits), which has been in force since 2005 (Regulation 396/2005).
The toxicity of the whole pesticide products is also not tested per se. The EU decides on the active substance, but Member States assess the formulations in which they are combined with other ingredients. At this national level, the Pesticide Law requires that EU Member States assess the long-term toxicity and carcinogenicity of pesticide formulations. This is not done by testing the products. Instead, Member States use a modelling calculating the overall chronic toxicity of the formulation based on the toxicity of each individual compound. However, the lack of data requirements on co-formulants, safeners and synergists means there is actually very limited information available on the toxicity of these compounds.
Lastly, it is not true that the substance toxicity is re-evaluated every 10 years (for new substances) or 15 years (for those already in the market). Although this is the rule, in fact, there are significant delays in the assessment of substances. They almost systematically lead to approval periods being extended year after year, a practice that undermines the protection of human health and the environment. For example, the PFAS herbicide Flufenacet was meant to be approved in 2003 until 2013 but was prolonged year after year until 2025. Flufenacet has been on the market for more than 20 years despite its toxicity. Its reassessment is still underway and according to EFSA (2) the substance is an endocrine disruptor for humans and for non-target organisms, which means it must be banned.
Water polluting TFA - the dangerous PFAS metabolite
PFAS pesticides are a sub-group of PFAS chemicals containing a – CF3 group attached to carbon. This structure makes them potential emitters of the degradation product trifluoroacetic acid (TFA). In fact, most PFAS pesticides form TFA according to the German Environmental Agency (UBA) (3). This very soluble chemical is a source of massive water cycle pollution (4). PFAS pesticides like Flufenacet, Diflufenican and Fluazinam are major TFA emitters. This process takes place all over the agricultural areas and has a substantial effect on water sources. The role of TFA-forming pesticides in the TFA pollution should therefore not be downplayed based on the limited existing information.
Croplife refers to the insufficient evidence of TFA harmful effects. In fact, TFA is very persistent. Its half-life is 10,000 days, which means it takes almost 30 years to reach 50% degradation. According to the German Environmental Agency UBA, it is also very mobile. These properties explain the widespread and massive nature of TFA pollution. The toxicity of TFA for humans and the environment cannot be ruled out on the sole basis of the regulatory studies used in pesticide risk assessment. As stated by UBA, these industry studies are “insufficient for assessing specific risks of very persistent and very mobile substances within a precautionary and risk-oriented procedure. (...) These are usually short-term studies and cannot account for (potential) long-term effects that may occur after several decades, affecting future generations. The effects of mixtures with TFA and other substances or their behaviour under different environmental conditions and media are also not considered by these tests. It is therefore very plausible that the toxicity of TFA has been completely underestimated for the time being.”
This claim is supported by Germany's recent proposal (5) to classify TFA as toxic for reproduction.
Read more:
Europe's Toxic Harvest: Unmasking PFAS Pesticides Authorised in Europe (PAN Europe and Générations Futures, November 2023)
Misleading Croplife statement on PFAS pesticides (Croplife Netherlands, January 2024)
Notes :
(1) Europe's Toxic Harvest: Unmasking PFAS Pesticides Authorised in Europe (PAN Europe and Générations Futures, November 2023)
(4) Small, mobile, persistent: Trifluoroacetate in the water cycle - Overlooked sources, pathways, and consequences for drinking water supply (Germany); Mass Balance of Perfluoroalkyl Acids, Including Trifluoroacetic Acid, in a Freshwater Lake (Sweden): Alerte aux PFAS : Révélation d’une pollution inquiétante aux PFAS près de la plateforme chimique de Salindres dans le Gard (France)
