Key Takeaways
- EFSA has cut the acceptable daily intake (ADI) for trifluoroacetic acid (TFA) from 0.05 mg/kg bw/day to 0.014 mg/kg bw/day and set an acute reference dose of 0.07 mg/kg bw, based on new data gathered after a 2024 call for information.
- The European Commission’s PFAS limits for food‑contact packaging will become enforceable on 12 August 2026, but detailed measurement‑method guidance is still pending, with a task force working on a draft that was discussed in July 2026.
- France has confirmed a tax on PFAS‑related water pollution, effective 1 September 2026, specifically targeting TFA emissions and accompanied by an order outlining collection, analysis, monitoring and calculation procedures.
- In the UK, PackUK’s Recyclability Assessment Methodology (RAM) 2027 introduces an automatic “red” rating for packaging containing > 1 ppm PFAS (or > 25 ppb in food‑contact items), shifting from the earlier intent‑based approach and affecting producer fees under the extended producer responsibility scheme.
- The UK Government’s response to the Environmental Audit Committee rejects rapid PFAS restrictions, opts for closer alignment with forthcoming EU REACH universal PFAS rules, and promises reforms to UK REACH for faster restriction adoption while retaining domestic decision‑making authority.
- The Health and Safety Executive (HSE) is consulting on a PFAS restriction in firefighting foams and on adding nine substances (including perfluoroheptanoic acid) to the UK REACH Candidate List; CL:AIRE has published 13 PFAS site profiles for various sectors, and the Office for Product Safety & Standards is seeking evidence on aligning UK toy safety rules with EU reforms that could lead to a PFAS ban in toys.
EFSA Lowers TFA ADI and Sets Acute Reference Dose
The European Food Safety Agency (EFSA) has revised its safety thresholds for trifluoroacetic acid (TFA), lowering the acceptable daily intake (ADI) from 0.05 milligrams per kilogram of body weight per day to 0.014 mg/kg bw/day. EFSA also established a new acute reference dose of 0.07 mg/kg bw. These changes reflect the incorporation of fresh data collected after EFSA issued a 2024 call for data. TFA is a degradation product of certain pesticides, and the updated limits will inform the forthcoming European Chemicals Agency (ECHA) recommendation on broader PFAS restrictions, anticipated by the end of 2026.
EU Commission Guidance on PFAS Limits in Food‑Contact Packaging Pending
Although the PFAS concentration limits for food‑contact packaging under Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) will take effect on 12 August 2026, the European Commission has yet to publish the accompanying guidance on measurement methods. The Commission’s Packaging Committee discussed a draft of this guidance at its meeting on 16 July 2026, but the document remained unpublished at month‑end. A task force created in March 2026 continues to develop the methodology, aiming to provide clear, harmonised procedures for industry and authorities once finalised.
France Confirms PFAS Water Pollution Tax Effective September 2026
France has issued a decree dated 27 June 2026 that confirms the implementation of a tax on PFAS‑related water pollution, scheduled to begin on 1 September 2026. The tax, initially slated for March, was postponed by the government. It specifically targets emissions of trifluoroacetic acid (TFA). An accompanying order released the same day details the procedures for sample collection, analytical techniques, monitoring regimes, and the calculation of tax liabilities, providing a concrete framework for enforcement.
UK PackUK RAM 2027 Introduces Automatic “Red” PFAS Thresholds
PackUK, administrator of the UK’s extended producer responsibility for packaging (pEPR), has released the Recyclability Assessment Methodology (RAM) 2027, which will apply from 1 January 2027. Under this scheme, packaging items receive a green/amber/red rating that influences fee modulation. RAM 2027 mandates an automatic “red” rating when a package or any of its components contains more than 1 parts per million (ppm) of PFAS (individually or summed) or when PFAS in food‑contact packaging exceeds 25 parts per billion (ppb) for any individual or total PFAS. This represents a shift from the previous RAM 1.1 (covering 2026), which required a red rating only for intentionally added PFAS in certain packaging types, thereby tightening the recyclability criteria and potentially increasing costs for producers using PFAS‑laden materials.
UK Government Response to EAC Report Signals EU Alignment, Not Rapid Restrictions
In response to the Environmental Audit Committee’s (EAC) report on PFAS risks, the UK Government acknowledged “plausible evidence that a risk of serious or irreversible pollution could occur if PFAS emissions continue,” yet refrained from adopting the EAC’s recommendations for an essential‑use approach or immediate restrictions on PFAS in non‑essential consumer products such as food packaging, cookware, and school uniforms. The government cited added complexities in extending the essential‑use concept to PFAS and indicated it will continue exploring regulatory and non‑regulatory options, support industry transition to safer alternatives, and monitor how the forthcoming EU REACH universal PFAS restriction applies to non‑essential uses. It affirmed plans to reform UK REACH to enable faster, more efficient restriction adoption while aligning closely with EU decisions, reserving the right to diverge only for compelling reasons. No commitment was made to interim labelling or standardized limits for PFAS‑containing consumer goods.
HSE Consultations, SVHC Candidates, PFAS Site Profiles, and Toy Safety Alignment
The Health and Safety Executive (HSE) has launched a 60‑day public consultation (closing 7 September 2026) on its draft Socioeconomic Assessment Opinion regarding a proposed UK REACH restriction on PFAS in firefighting foams, complemented by a final Risk Assessment Opinion that is not open for comment. Separately, HSE is consulting (until 20 August 2026) on adding nine substances or groups—including perfluoroheptanoic acid and its salts—to the UK REACH Candidate List as substances of very high concern (SVHC). CL:AIRE has published 13 PFAS site profiles covering sectors such as civil and military airfields, COMAH‑regulated sites, fire‑fighting grounds, landfills, metal manufacturing, military bases, oil and gas operations, paper and cardboard manufacturing, refineries, textiles/upholstery/leather/apparel/carpets, and wastewater treatment works, plus profiles for aqueous film‑forming foam and fire‑suppression systems. Finally, the Office for Product Safety & Standards (OPSS) is issuing a call for evidence on aligning UK toy safety rules with EU reforms, which could eventually lead to a UK ban on intentional PFAS and certain bisphenol use in toys, alongside provisions for digital product passports and internet‑connected toys.