EUROPEAN UNION
EU – EFSA lowers acceptable daily intake of trifluoroacetic acid (‘TFA’). The European Food Safety Agency (‘EFSA’) has lowered the acceptable daily intake of down to 0.014 milligrams per kilogram of bodyweight per day (compared to 0.05 mg previously). The value refers to the amount of a substance in food or drinking water that can be consumed daily over a lifetime, without presenting an appreciable risk to health. EFSA has also set a new acute reference dose of 0.07 milligrams per kilogram of body weight. Both changes stem from the collection of new data, following the issuance of a call for data by the Agency back in 2024. TFA is notably formed as a result of the use of certain pesticides. This will also feed the upcoming recommendation of the European Chemicals Agency on potential new PFAS restrictions, expected by end-2026.
EU – Commission Guidance still to be issued as PFAS limits in food contact packaging come into effect on 12 August 2026. The Commission’s Committee on packaging met on 16 July 2026. Discussion points mentioned in the meeting’s agenda include the implementation of the limits on the presence of PFAS in food contact packaging, set out under Article 5(5) of Regulation (EU) 2025/40 on packaging and packaging waste (‘PPWR’). While the limitation will apply from 12 August 2026, the issuance of guidance on the measurement methods to be used is still expected. A draft was discussed during the meeting, although it hasn’t been published by the end of July. The process is supported by the work of a task force created in March 2026, which has been working on the elaboration of a methodology.
MEMBER STATES
FRANCE – Tax on pollution of water by PFAS is confirmed for September. France has issued a Decree on 27 June which confirms the application of a tax on PFAS pollution in water from 1 September 2026. The application, initially foreseen for March, had been postponed by the Government. The tax targets emissions of TFA. An Order issued the same day details the collection and analytical methods used, as well as monitoring and calculation methods.
UNITED KINGDOM
UK – ‘Automatic red’ rating for PFAS above certain threshold in Recyclability Assessment Methodology (RAM) 2027. PackUK, the scheme administrator of the UK’s extended producer responsibility for packaging (pEPR) regime, has published the RAM framework that will apply to recyclability assessments of items of packaging and components supplied from 1 January 2027 onwards. Under pEPR, ‘large’ producers of packaging are required to use RAM to assess the recyclability, via a ‘green/amber/red’ system, of household packaging and packaging that commonly ends up in public bins. RAM 2027 states that an item of packaging must automatically be rated ‘red’ if it or a component contains ”more than 1 parts per million (ppm) of PFAS (individual or sum), or PFAS in food packaging exceeding 25 parts per billion (ppb) for any individual or total PFAS”. This is a move away from previous RAM (referred to as ‘RAM 1.1’ – covering 1 January to 31 December 2026) that required certain packaging types to be rated red if they contained intentionally added PFAS. RAM ratings are significant because they influence fee modulation and ultimately the amounts payable by producers, who should familiarise themselves with this document ahead of the next reporting year.
UK – Government declines calls for rapid PFAS restrictions but appears to signal closer EU alignment. The UK Government has responded to the Environmental Audit Committee’s (ECA) report on addressing the risks from PFAS. It acknowledges that there is “plausible evidence that a risk of serious or irreversible pollution could occur if PFAS emissions continue” but makes few substantive commitments beyond the measures already included in the PFAS Plan published in February 2026. Among the EAC’s many recommendations was the adoption of an essential-use approach to PFAS regulation, under which non-essential applications would be rapidly restricted. It also recommended that the Health and Safety Executive (HSE) bring forward restrictions on PFAS in non-essential consumer products, including food packaging, cookware and school uniforms, with phased restrictions beginning in 2027. The Government has not committed to either recommendation or the EAC’s proposed timetable, citing that extending the essential-use concept to PFAS “presents additional complexities”. It will instead continue to explore regulatory and non-regulatory options, support industry’s transition towards safer alternatives and “wait to see how the final EU REACH universal PFAS retraction applies to non-essential applications”. Similarly, it did not commit to introducing interim limits or standardised labelling for PFAS-containing consumer products, as recommended by the EAC. The response does confirm that UK REACH will be reformed so that restrictions can be adopted more quickly, efficiently and in closer alignment with the EU. The Government’s proposed approach would “draw from” final EU regulatory decisions, including final EU REACH restrictions, unless there were “compelling” reasons to diverge, while retaining domestic control over the ultimate decision. Defra’s view is that this will “reduce uncertainty, provide a clearer direction of travel for both industry and regulators, and avoid the time-consuming, costly and unnecessary duplication of EU scientific assessment” but how this works practically remains to be seen.
UK – HSE consults on PFAS in firefighting foams and on new SVHCs. The HSE has opened a 60-day public consultation on its draft Socioeconomic Assessment Opinion (SAO) concerning a proposed UK REACH restriction on PFAS in firefighting foams. The consultation, which closes on 7 September 2026, seeks views and relevant evidence on the draft SAO. The HSE has also published its final Risk Assessment Opinion, which forms part of the wider Agency Opinion but is not itself open for consultation. Separately, the HSE is consulting on adding nine substances or groups of substances of very high concern to the UK REACH Candidate List. These include perfluoroheptanoic acid and its salts. The consultation closes on 20 August 2026.
UK – PFAS Site Profiles Published. The organisation CL:AIRE (Contaminated Land: Applications in Real Environments – a UK not-for profit organisation) has published 13 PFAS Site Profiles to “provide regulators and other interested parties with researched advice on how to assess problem sites that may be impacted by legacy use or release of PFAS”. There is a profile for each of the following industry sectors: civil and military airfields, Control of Major Accident Hazards (COMAH) Regulated Sites, fire-fighting grounds and fire stations, landfills, metal manufacturing and finishing, military bases (other than air transport sites), oil and gas industry (onshore exploration and extraction operations), paper and cardboard manufacturing, refineries and fuel sites, textiles, upholstery, leather, apparel and carpets (TULAC) manufacturing, and waste water treatment works. While not relating directly to a particular site type, there are also profiles for aqueous film-forming foam and fire suppression systems.
UK – Call for evidence on alignment with EU toy safety rules: The Office for Product Safety & Standards (OPSS) is giving “due consideration” to the EU’s reforms of toys legislation and asking for stakeholder views on the costs and benefits of so doing. Alongside measures on digital product passports and internet-connected toys and artificial intelligence that feature in the new EU Toy Safety Regulation, this could eventually mean consideration of a UK ban on intentional use of PFAS and certain bisphenols in toys.
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