Forever Chemicals: TFA even in Mineral Water – Luxembourg must support the EU Commission’s proposal for a pesticide ban due to TFA on Wednesday, December 4th

The “forever chemical” TFA has relentlessly made its way into our environment. As a breakdown product of various man-made substances (mainly pesticides and refrigerants), small, mobile, and resilient, it has spread to our most precious resource: water.

Rivers, springs, groundwater, and now – as shown by the recent report from Pesticide Action Network Europe (PAN Europe), with the involvement of Mouvement Ecologique[i] – even the water in bottles, which was once considered pure: analyses of bottled mineral water from across Europe show contamination with Trifluoroacetate (TFA).

More than 50% of the environmental contamination with TFA originates from the use of PFAS pesticides. The main sources of TFA are the pesticide active ingredients Flufenacet and Flutolanil, which are found in numerous pesticides.

On the EU Commission’s proposal, these toxic substances should now have their authorization revoked. On December 4-5, 2024, the Commission will present this crucial proposal to the Standing Committee on Plants, Animals, Food and Feed (SCoPAFF).

Mouvement Ecologique urges Luxembourg’s representatives in this committee to strongly support the ban of these toxic substances.

10 out of 19 Mineral Waters Contaminated with TFA

TFA has now been found in all bodies of water. After it was revealed in July as part of the EU campaign by PAN Europe that not only surface waters but also groundwater bodies are contaminated[ii], analyses of bottled mineral waters are now available[iii].

In 10 out of 19 mineral water brands tested, TFA has made its way into the deep groundwater reserves, often hundreds of meters below the surface, that are supposedly protected from anthropogenic pollutants and from which our mineral waters are sourced. In 7 out of 19 cases, the detected TFA levels exceed the drinking water limit for relevant pesticide metabolites, which is set at 0.1 µg/l (100 ng/l).

The mineral water sample from Luxembourg was also contaminated[iv]: approximately 400 nanograms of TFA per liter were detected. Luxembourg’s mineral water was in the middle range. Some foreign mineral waters showed no detectable TFA, while others had much higher levels (up to 3,200 ng/l) (see chart).

This graph displays in alphabetical order the 10 mineral waters with quantifiable TFA residues, as well as the 7 mineral waters and 2 spring waters with no quantifiable TFA contamination. The blue bars represent the summer analysis results, while the light blue bars reflect the confirmatory analyses carried in autumn. Quelle: Pan Europe/Global 2000

* In these cases, it is not mineral water but spring water. According to Directive 2009/54/EC(link is external), spring waters must fulfil less stringent requirements in terms of composition and purity than mineral waters.
** The Luxembourg brand concerned was anonymised at the request of the Luxembourg environmental organisation Mouvement Écologique, which commissioned the analysis of the sample in question. Given the limited number of mineral water producers in Luxembourg, Mouvement Écologique believes that disclosing the brand name could draw undue attention to this one producer rather than to the general problem. The competent authorities in Luxembourg have been informed about the brand concerned. If you have any questions, please contact Claire Wolff: claire.wolff@oeko.lu

It is alarming that it is now clearly established that even bottled mineral water is contaminated with the “forever chemical.” This is particularly problematic because consumers assume that bottled mineral water is a “natural” and “pure” product. To be able to label it as “mineral water,” certain rules and quality criteria must be met. For example, filtration processes for purification are prohibited, and the bottled water must originally be free from contamination. Apart from the fact that TFA can only be filtered out very expensively and inefficiently, this would not be an option for mineral water in any case.

In addition to public water suppliers, the current analysis now presents bottled water producers with the new challenge of taking greater responsibility to ensure that the water sources they use are protected from further contamination. They usually have only limited control over ensuring the protection of their water sources independently and rely on the relevant authorities to take the necessary measures to secure the purity of our drinking water in the long term! However, they cannot stand by idly as this issue develops and must raise their voices in the interest of their customers (and thus their own interests as well).

Health Concerns – Although the detailed effects are still being examined, the precautionary principle must apply!

According to the current state of knowledge, each of the tested mineral waters – even the one with the highest measured contamination of 3,200 ng/l – falls within the health guidelines established by the EU for an adult. However, the issue lies in the limitations of this knowledge. Not least due to the increased pressure on politics in recent months – including from PAN Europe – the effect of TFA on human health is currently being closely investigated by the WHO, with results expected by the end of 2025.[v]

There are already concerns about reproductive toxicity, as reported by the chemical producer Bayer.[vi] TFA should now be considered a “toxically relevant metabolite,” meaning a toxic byproduct. European law sets a uniform limit of 0.1 µg/l for such substances in groundwater and drinking water. Yet this value is significantly exceeded.

With each passing day, as TFA continues to enter our waters unchecked, the risk of exceeding health-relevant thresholds grows. Therefore, it is now crucial to take precautionary action and stop the release of TFA precursor substances into our environment.

Stop the entry of TFA into the environment, ban PFAS pesticides now!
These findings should not cause panic but rather serve as a wake-up call and a motivation for swift action: according to the precautionary principle, any further release of TFA into the environment must be avoided immediately! This is how we can ensure access to clean drinking water even ten years from now.

The first priority must be banning the main contributors: PFAS pesticides used in agriculture that degrade into TFA. This is the primary way TFA enters the environment.
On December 4–5, the European Commission will propose to the Standing Committee on Plants, Animals, Food, and Feed (SCoPAFF) the withdrawal of authorization for the active substances Flufenacet and Flutolanil. These substances belong to the group of PFAS pesticides, identified by Germany’s Federal Environment Agency (UBA) as the main source of TFA contamination in Europe’s groundwater and drinking water resources.[vii]

Banning these substances is a legal necessity: pesticides whose residues (in this case, TFA) are found in water and food, and are suspected of harmful health effects, fail to meet the authorization criteria under the EU pesticide regulation.

This meeting is a crucial opportunity to act in the best interests of the people of Europe, particularly vulnerable groups such as children, and the environment. Pesticides that irreversibly and broadly contaminate our water—the foundation of all life on this planet—with a chemical toxic to reproduction must be stopped.

The Pesticide Action Network (PAN) Europe, together with the Mouvement Écologique, therefore calls on member states to:

• Ban PFAS pesticides: Member states, including Luxembourg, must approve the proposed ban on Flufenacet and Flutolanil this week and implement it immediately.
• Support environmentally friendly agriculture: PFAS pesticides must not be replaced with other toxic substances. Farmers must receive adequate technical and financial support to transition to more sustainable methods.
• Adjust the EU Drinking Water Framework Directive: A limit for TFA in drinking water must be established, based on the latest scientific findings, enabling the definition of a specific threshold for TFA at the European level.
• Revise the EU Water Framework Directive: Key meetings at the end of 2024 must define quality standards for TFA in natural waters.
• Publish analysis results: Authorities should regularly publish analyses of drinking water samples as well as bottled mineral water.
• Expand protection of water sources: As shown by the contamination of bottled mineral water, a broad protection of our drinking water resources is essential. A fundamental discussion on how to optimize this protection must be initiated.
• Regulate the use of various chemicals at the EU level: Luxembourg should take a leading role in ensuring that TFA-related chemicals (e.g., refrigerants, cosmetics, non-stick coatings) are banned at the EU level.
• Ensure public awareness: The state must take responsibility for conducting an active information campaign to educate consumers on how to protect themselves from TFA contamination.

Contact:

Claire Wolff, Mouvement Ecologique; claire.wolff@oeko.lu; +352 43 90 30 35

[i] Pressrelease PAN Europe from 03.12.2024: Forever Chemical Found Even in Pristine Mineral Waters. https://www.pan-europe.info/press-releases/2024/12/forever-chemical-found-even-pristine-mineral-waters (accessed on 03.12.2024)

[ii] https://www.meco.lu/de/blog/documentcenter/ewigkeitschemikalie-tfa-auch-im-trinkwasser-noch-ist-kein-grund-zur-panik-aber-die-politik-muss-sofort-handeln/

[iii] PAN Europe : TFA: The ‘Forever Chemical’ in European Mineral Waters: https://www.pan-europe.info/resources/briefings/2024/12/tfa-%E2%80%98forever-chemical%E2%80%99-european-mineral-waters (accessed on 03.12.2024)

[iv]  The Mouvement Écologique wishes to keep the brand anonymized because—given that only one sample was taken and there is a very limited number of mineral water producers in small Luxembourg—this could overly focus attention on this single producer. However, TFA contamination is a general problem, and beyond the responsibility of producers, it is primarily up to the government to take action!

[v] https://environnement.public.lu/fr/support/faqs/waasser.html (accessed on 27.11.2024)

[vi] https://www.global2000.at/news/tfa-rechtsgutachten (accessed on 27.11.2024)

[vii] PAN Europe : TFA: The ‘Forever Chemical’ in European Mineral Waters: https://www.pan-europe.info/resources/briefings/2024/12/tfa-%E2%80%98forever-chemical%E2%80%99-european-mineral-waters (accessed on 03.12.2024)

Here you can find further information on previous reports about TFA in Luxembourgish surface, ground and drinking water, as well as general information on TFA and PFAS (Where do they come from? How to avoid them?)

TFA in Surface and Groundwater in Luxembourg

This summer, Mouvement Ecologique already reported on the contamination of water bodies with TFA, as part of the EU-wide study conducted by PAN Europe (Pesticide Action Network). Tamples were taken in Luxembourg, specifically from the Alzette River, a spring in Dommeldange, and tap water in one municipality. All samples showed contamination levels that were consistent with the average of other countries’ samples.

The related reports and demands of Mouvement Ecologique can be found here (press release on TFA in surface water) and here (press release on TFA in groundwater).

What is TFA? And what are PFAS?

TFA belongs to the PFAS group of chemicals, a large family encompassing up to 10,000 substances. These are all human-made, highly durable, and mobile. Some have been proven toxic to humans. Once they enter the environment, they remain there indefinitely due to their extreme stability. They cannot be filtered out or destroyed, earning them the nickname “forever chemicals.”

PFAS are used in many areas because of their water-, dirt-, and grease-repellent properties. For instance, they are found in consumer products like non-stick pans, rain jackets, pizza boxes, or dental floss. They are also widely used in pharmaceuticals and pesticides, which are employed in conventional agriculture. Additionally, PFAS are used in firefighting foams and as refrigerants.

More details and frequently asked questions about PFAS can be found in this document: PFAS Information in German.

Underestimated TFA – Already a Problem or a Future Threat?

TFA is essentially the final degradation product of various larger PFAS compounds. It is also a highly persistent molecule that endures in the environment. TFA enters water primarily through PFAS-based pesticides. When used in agriculture, these chemicals seep into the soil and can be washed into surface and groundwater. This issue has largely been ignored so far, leaving current thresholds for TFA in the drinking water directive and pesticide regulations absent.

Now, almost the entire environment is contaminated with TFA, with uncertain consequences.

The study by PAN Europe is finally bringing much-needed attention to this overlooked molecule, enabling action to be taken.

However, environmental organizations also note that other PFAS substances are insufficiently regulated. Due to their durability and the proven toxicity of various PFAS compounds, authorities in Germany, the Netherlands, Norway, Sweden, and Denmark have called for restrictions on these forever chemicals. Read the BUND Germany statement on this matter here.

How Harmful Are TFA and PFAS?[i]

Little is known about the effects of TFA. Other well-researched forever chemicals are linked to hormonal disruptions, fertility issues, deformities, immune system damage, and increased cancer risk. Over 20% of children already have PFAS concentrations in their bodies above health safety thresholds. TFA is suspected to be reprotoxic.

Can We Still Safely Drink Tap Water?[ii]

Yes! However, we need to act now to ensure we can still drink healthy tap water in 10–20 years. TFA contamination in drinking water is increasing daily due to the use of PFAS pesticides and refrigerants (“F-gases”). The “safety buffer” is shrinking, and the health risks are rising.

How Can I Avoid PFAS in Everyday Life?

As a consumer, you can consciously reduce your exposure to PFAS. For example, you can use PFAS-free cosmetics, avoid non-stick pans, and choose outdoor clothing that is free from these chemicals.

The BUND Germany provides useful tips (in German):

–  PFAS in cosmetics (pdf also in downloads)

–   PFAS in the kitchen

–  PFAS in outdoor clothing

[i]https://environnement.public.lu/fr/support/faqs/waasser.html (aufgerufen am 27.11.2024)

[ii] https://www.global2000.at/news/tfa-rechtsgutachten (aufgerufen am 27.11.2024)

[iii] Global2000, https://www.global2000.at/publikationen/tfa-im-trinkwasser (aufgerufen am 27.11.2024)

[iv] Global2000, https://www.global2000.at/publikationen/tfa-im-trinkwasser (aufgerufen am 27.11.2024)

03.12.24