Decisive days for people and the environment: Luxembourg should now push ahead with the ban on PFAS pesticides – both nationally and at EU level

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Open letter from the Mouvement Ecologique to Agriculture and Consumer Protection Minister Martine Hansen and Health Minister Martine Deprez

 

An urgent appeal to Luxembourg’s MEPs!

An increasing number of analyses throughout Europe, but also in Luxembourg, show how polluted the environment and people are by the toxic perpetual chemicals (PFAS and their degradation product TFA), which mainly come from pesticides used in agriculture. In fact, all analyses carried out on behalf of PAN-Europe and the Mouvement Ecologique show contamination in surface water, groundwater, drinking and mineral water as well as in wine samples.

TFA is not called an “eternal chemical” for nothing. It does not degrade and so a large proportion of the TFA released today will remain in the environment for generations to come. Planetary boundaries are under threat. It is clear that any further use brings us closer to irretrievably exceeding any limit values. It is therefore imperative that we act quickly (1). Among other things, TFA is considered reprotoxic, i.e. a substance that can impair the ability to reproduce or the development of offspring.

In order to protect the population and the environment from this exposure, Luxembourg must both use the debates at EU level to support the phase-out of these toxic substances and utilise the rights we have as a country.

 

Raise your voice at EU level next week in favour of reducing the use of pesticides

Next Tuesday 9 and Wednesday 10 July 2025, the EU Standing Committee on Plants, Animals, Food and Feed (SCoPAFF) is expected to discuss the European Commission’s very important proposal not to renew the authorisation of the pesticide active substance Flutolanil® (a PFAS chemical). Flutolanil is used as an antifungal agent in agriculture and is considered to be one of the most frequently used substances in pesticides that is responsible for exposure to the perpetuating chemical TFA.

TFA was identified in the authorisation procedure as the main metabolite of flutolanil in crops. In view of its high persistence, mobility and reproductive toxicity, this active substance poses an immediate risk to consumers and groundwater. An extension of the authorisation should therefore be ruled out.

Even if no decision is made next week, it is important that Luxembourg sides with those countries that are in favour of the EU Commission’s proposal. And if a vote were to take place, Luxembourg must absolutely support the EU Commission’s proposal.

Flutolanil is used on significant areas in Luxembourg every year – withdrawing the authorisation for this substance would be an important step towards reducing the environmental impact of TFA.

 

Revoke all authorisations for pesticides containing PFAS in Luxembourg: now! immediately!

At the same time, it is only logical for Luxembourg to prohibit the authorisation of the remaining pesticides containing PFAS that are still authorised by the EU. The EU Plant Protection Products Regulation (EC) explicitly provides for this possibility (No. 1107/2009 in Art. 44 para. 3), and even prescribes it (2). According to Article 44(3)(a) of the Plant Protection Products Regulation, Member States are obliged to withdraw authorisations of products if they prove to be particularly toxic. This is the case with TFA. Based on the latest findings, the European Commission has recognised TFA as a so-called relevant metabolite. Limit values of 0.1 µg/l are binding for these. In reality, however, this is regularly exceeded – in some cases even significantly (more than 10 µg/l). This means that products containing PFAS no longer fulfil the requirements of the Plant Protection Products Ordinance and the Groundwater Directive.

The Luxembourg government should therefore immediately revoke all national authorisations for plant protection products containing PFAS active substances in accordance with Article 44(3) of the EU Plant Protection Products Regulation.

The Mouvement Ecologique is convinced that the majority of citizens are in favour of protecting human health and the environment and are therefore against the continued use of this dangerous substance. We therefore make an urgent appeal to the Luxembourg Minister of Agriculture and Consumer Protection as well as the Minister of Health, Martine Deprez, to be a consistent voice for the ban – the revocation of authorisations.

We thank you in advance for your commitment to protecting our water resources and environment, consumers and public health.

 

Mouvement Ecologique

Luxembourg, 03 July 2025

 

  • The contamination of the environment by perpetual chemicals – be it by long-chain PFAS molecules in general or their smallest degradation substance TFA – is far-reaching and we are only at the beginning of uncovering the full extent of the problem. The warning credo of scientific analyses: a large proportion of the TFA released today will remain in the environment for many generations to come and threatens the planetary boundaries.As recent analyses from 2024 by the Pesticide Action Network Europe impressively showed, TFA is widespread in water resources throughout Europe – in concentrations that exceed those of other PFAS many times over. The Mouvement Ecologique contributed samples of surface water, groundwater, drinking water and mineral water from Luxembourg to these studies – TFA is also a problem here in Luxembourg. Another study this year, which also included samples from Luxembourg, focussed on wine as a proxy for agricultural products – due to its long shelf life, it is able to document the historical increase in TFA over the last decades. The analyses showed that this is alarming and that the concentrations of TFA in wine are many times higher than in water.These results, as well as analyses of toxicity etc., highlight the urgency of taking measures to combat the environmental and health risks posed by PFAS-containing pesticides, which have so far gone largely unnoticed.
  • According to scientific modelling, PFAS pesticides account for around 76% of TFA groundwater pollution. Other sources are TFA emissions via precipitation (mainly from fluorinated refrigerants, 17%) as well as sewage treatment plants and manure (3% each). More than 30 PFAS active substances are currently authorised for agricultural use in plant protection products in the EU. These are deliberately applied to agricultural land and contribute to the contamination of food, soil and water – with TFA being a common degradation product.

 

  • These developments are in direct contradiction to the EU Plant Protection Products Regulation (EC) No. 1107/2009, which aims in particular to protect drinking water and groundwater from pesticide contamination. According to Article 4 (3) and taking into account the precautionary principle in Article 1 (4), pesticides must not have any immediate or long-term negative effects on human health – either directly or via groundwater. In addition, according to the EU Groundwater Directive (2006/118/EC), the concentration of relevant metabolites in groundwater must not exceed the threshold value of 0.1 µg/litre.The European Commission has recognised TFA as a relevant metabolite due to its toxicological properties – in particular the proposed classification as toxic for reproduction in accordance with CLP Regulation (EC) No. 1272/2008. The legally prescribed limit value of 0.1 µg/l is therefore binding. In reality, however, this limit value is regularly exceeded – in some cases even significantly exceeded (more than 10 µg/l). This means that products containing PFAS no longer fulfil the requirements of the Plant Protection Products Ordinance and the Groundwater Directive.

 

 

You can find the open letter as a PDF in the downloads here!

 

04.07.25