Germany’s BfR releases protective guidelines to prevent excessive PFAS in animal-derived foods

GERMANY – The German Federal Institute for Risk Assessment (BfR) has published guidelines for per- and polyfluoroalkyl substances (PFAS)  limits in animal feed, aiming to prevent food products from exceeding established safety thresholds.

As of January 2023, new regulations in the European Union set maximum allowable levels for certain PFAS in foods of animal origin. This regulatory development aimed to address the health risks posed by these persistent environmental contaminants, often referred to as “forever chemicals.”

These substances, known for their strong carbon-fluorine bonds, resist degradation and accumulate in the environment, leading to potential health risks for humans and wildlife.

However, there remains a gap in regulation concerning PFAS levels in animal feed, which can significantly influence the PFAS content in animal-derived foods. It is in response to this regulatory void that BfR published these limit guidelines.

The European Commission has introduced Regulation 2023/915, which specifies maximum permissible levels for several PFAS compounds, including perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), and perfluorohexane sulfonic acid (PFHxS).

The regulation also sets limits on the cumulative sum of these four PFAS compounds in foods of animal origin. Nevertheless, discussions are still ongoing with the European Commission regarding the establishment of maximum PFAS levels in animal feed, a critical factor in the food supply chain that influences PFAS accumulation in food products.

BfR’s protective guidelines for PFAS in animal feed

To bridge the regulatory gap, the German Federal Institute for Risk Assessment (BfR) has calculated maximum levels of PFAS in animal feed that would protect public health by preventing food products from exceeding the EU’s regulated maximum levels.

These calculations employ toxicokinetics modeling, incorporating data from scientific studies on PFAS transfer from feed to food of animal origin. This model focuses on complete feed for cattle, sheep, fattening pigs, laying hens, and dairy cows.

According to the BfR’s calculations, the maximum PFAS levels in animal feed, measured in micrograms per kilogram (μg/kg) of dry feed, are as follows: for hens, PFOS should not exceed 0.42 μg/kg, PFOA 0.25 μg/kg, PFNA 0.29 μg/kg, and PFHxS 0.17 μg/kg. In cattle feed, PFOS should not be more than 0.14 μg/kg, while PFHxS is capped at 1.0 μg/kg.

Sheep feed should have a maximum of 0.21 μg/kg PFOS. Fattening pigs’ feed should not contain more than 0.07 μg/kg PFOS, 0.05 μg/kg PFOA, and 0.06 μg/kg PFHxS. Lastly, dairy cow feed should be limited to 0.07 μg/kg PFOS, 6.5 μg/kg PFOA, and 3.7 μg/kg PFHxS.

The BfR’s guidelines aim to ensure that animal-derived products do not exceed EU-regulated maximum levels, thus safeguarding consumer health from the potentially harmful effects of PFAS.

These limits are based on the transfer efficiency of PFAS from feed to food products, highlighting the need for stringent controls on animal feed to prevent downstream contamination.

Addressing PFAS in pesticides

Beyond the issue of PFAS in animal feed, there are growing concerns about the introduction of PFAS into the environment through pesticides.

In the United States, the Center for Food Safety, along with a coalition of environmental and consumer advocacy groups, has filed a petition with the U.S. Environmental Protection Agency (EPA), urging the agency to ban the use of PFAS as ingredients in pesticides and their containers.

The petition highlights the role of PFAS-containing pesticides in exacerbating environmental contamination and calls for comprehensive regulatory measures to mitigate their impact.

The petition seeks a prohibition on the use of PFAS as active or inert ingredients in pesticide formulations and the use of PFAS-containing materials in pesticide containers. It also advocates for a harmonized, scientifically accurate definition of PFAS and mandates that pesticide registrants report any PFAS contamination.

Additionally, it calls for requiring manufacturers to submit relevant PFAS data before approving new pesticide registrations. The petition argues that current practices conflict with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which mandates the EPA to ensure that approved pesticides do not pose “unreasonable adverse effects on the environment.”

Despite acknowledging PFAS as an urgent public health concern, the EPA has yet to take significant action to limit their use in pesticides.

The petition, spearheaded by the Center for Food Safety, is backed by several organizations committed to environmental conservation and public health.

These include the American Bird Conservancy, Beyond Pesticides, the Massachusetts Pollinator Network, the Maine Organic Farmers and Gardeners Association, the Norwalk River Watershed Association, Pesticide Action Network North America, the Northeast Organic Farming Association of Vermont, the Northwest Center for Alternatives to Pesticides, Rural Vermont, Toxic Free NC, and chemical safety attorney Tom Neltner, B.E., J.D.

Beyond Pesticides, one of the petition’s key supporters, provides resources on safe alternative practices and products that do not rely on PFAS-containing pesticides, emphasizing the feasibility of transitioning to environmentally benign options.

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