Following a similar analysis of surface water and groundwater, a new study from the European Pesticide Action Network (PAN) Europe has found trifluoroacetic acid (TFA), an atmospheric degradation product of HFO-1234yf and other f-gases, in 34 of 36 European tap-water samples from 11 EU countries and in 12 of 19 bottled mineral and spring waters.
The study raises questions about the safety of drinking water as TFA and other PFAS (per- and polyfluoroalkyl substances) continue to proliferate in the environment.
“The good news for now is that, in almost all samples, the TFA levels we found appear to be still within what is considered safe limits according to current knowledge,” said Helmut Burtscher-Schaden, an environmental chemist with GLOBAL 2000, which contributed to the PAN Europe study. “However, TFA inputs are increasing daily, and the safety buffer is already very small. Moreover, we are already unduly burdened by other PFAS. Measures to prevent further TFA contamination must therefore be taken immediately.”
A report based on the study, “TFA: The Forever Chemical in the Water We Drink,” was published on July 10 by PAN Europe, a Brussels-based NGO, and its partner organizations in 11 countries: Austria (Global 2000), Belgium (Nature & Progrès), Bulgaria (Via Pontica Foundation), Croatia (Earth Trek), France (Générations Futures), Germany (BUND and PAN Germany), Magyar Természetvédők Szövetsége (Hungary), Luxembourg (Mouvement Écologique), Netherlands (PAN Netherlands), Spain (Ecologistas en Acción) and Sweden (Swedish Society for Nature Preservation).
The organizations collected drinking water samples in their respective countries between April and June 2024, and the samples were analyzed by the Water Technology Centre in Karlsruhe, Germany.
The report called for an immediate ban on PFAS pesticides and f-gases – the two primary sources of TFA. It also asked for swift implementation by the European Chemical Agency (ECHA) of the general PFAS restriction under the EU’s REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation, establishment of a safe drinking water limit for TFA at the EU level and setting quality standards for TFA for water regulated under the EU’s Water Framework Directive. In addition, the report urged that wherever it is necessary to purify water due to chemical contamination, “the polluter pays principle shall be applied.”
GLOBAL 2000 demands that the Austrian government investigate the potential health risks of TFA and monitor TFA in nature, water and food.
In the EU, TFA is considered an ultrashort-chain (two carbon) PFAS under the scientifically endorsed OECD (Organisation for Economic Co-operation and Development) definition. PFAS, known as “forever chemicals” for their durability in nature, encompass a broad class of more than 14,000 fluorinated chemicals used in numerous consumer products; some longer-chain PFAS, such as PFOA (perfluorooctanoic acid), have been deemed toxic to human health.
Highest level in Austria
The TFA detected in the 34 tap-water samples ranged from “below the detection limit” (0.02mcg/L) to 4.1 mcg/L, with an average of 0.74mcg/L. The highest tap-water level was found in the Austrian state of Upper Austria. In the 12 bottled mineral/spring water samples (derived from 17 mineral and two spring water sources) in which TFA was found, concentrations were seen from below the detection limit to 3.2mcg/L, with an average of .278mcg/L. The report did not identify the producers of the bottled water, pending further tests during the summer.
Notably, the Netherlands has set a TFA drinking water limit of 2.2mcg/L (exceeded by only two of the 55 water samples tested), while the EU has proposed a Drinking Water Directive limit of 0.5mcg/L for total PFAS that will take effect in 2026.
“This PAN report is yet another indicating that more of us are drinking increasing amounts of TFA every day via drinking water, regardless of where our drinking water comes from,” said Hans Peter Arp, Environmental Chemist at the Norwegian Geotechnical Institute. “The TFA emitted to the environment now will persist for countless generations and will spread to our most pristine freshwater ecosystems and mineral water resources. This impact is irreversible as TFA is too widespread, and the costs of removing it too unfeasible.”
Tests for 24 other PFAS chemicals in the PAN Europe study revealed that TFA accounted for more than 98% of the total PFAS load across all drinking-water samples tested. The study links the TFA to the breakdown of pesticides in farming areas and the decomposition of f-gases. Certain f-gases that are emitted from HVAC&R systems into the atmosphere undergo photolytic conversion to TFA (100% conversion for HFO-1234yf over two weeks) and then enter the water cycle through rainfall all over the world.
“To safeguard these impacts from future generations, it is important to put more urgency on creating pathways to limit the major sources of TFA, such as f-gases and pesticides like flufenacet, diflufenican and fluazinam,” said Arp.
“If nothing is done here, I believe that this issue will soon overtake climate change,” says Philipp Baumgartner, Managing Director for Austrian refrigeration contractor Equans Kältetechnik in a LinkedIn post. With respect to refrigerants, he points out that there are “tried and tested” alternatives to f-gases, namely natural refrigerants CO2 (R744), ammonia (R717) and hydrocarbons.
The European Fluorocarbons Technical Committee (EFCTC), which represents chemical manufacturers, did not respond to a request for comment on the new PAN Europe study. On its website, f-gas producer Chemours said the proposed regulations in Europe to restrict f-gases and other PFAS substances under REACH “would have a devastating impact on jobs, supply chains, the economy, and the ability to achieve EU climate, strategic autonomy, and innovation objectives. Chemours supports and advocates for a coherent regulatory approach that allows for the use of safer, better performing chemistries in the EU.”
In May, PAN Europe released a study that found TFA in samples from 23 rivers and lakes (surface water) and six aquifers (groundwater) across Europe. The peak values in the new drinking water study are comparable to those found in the study of surface water, though the average of 0.74mcg/L in the former is lower than the average of 1.22mcg /L in the latter.
The May report pointed out that the amount of TFA in the environment has experienced a steady increase “that has been going largely unnoticed by the public for decades, but which has been predicted or described by scientific experts since the 1990s and has already materialized.” For example, in Germany, the measured TFA levels in rainwater have increased fourfold in two decades, according to a 2020 study.
The May report also said that TFA cannot be removed from water by filters (such as activated carbon) or ozonation; it can only be removed by reverse osmosis, an expensive technology that “requires more resources, leads to higher energy costs, and raises the unresolved issue of disposing of the resulting concentrates.”
Another NGO, BUND (German Federation for the Environment and Nature Conservation), recently published a study of drinking (tap) water and mineral water in German cities and Brussels, Belgium, finding several chemical pollutants, with TFA’s being the most frequently discovered chemical.
In the U.S., a panel of scientists recently discussed health concerns associated with TFA at the ATMOsphere America 2024 conference, organized by ATMOsphere, publisher of NaturalRefrigerants.com.
Risk assessments vary
The PAN Europe report noted that there are few studies on the environmental and health risks of TFA, despite its widespread presence in waters across the globe, adding, “risk assessments vary significantly due to differences in the way regulators deal with the scarce scientific knowledge,” and “underestimation of the risk cannot be excluded.”
The most noteworthy example of a health assessment of TFA comes from the German Federal Office for Chemicals (Bundesstelle für Chemikalien or BfC), which recently submitted to the European Chemical Agency (ECHA) a proposal linking reproductive toxicity to TFA and its inorganic salts. This is one of the first efforts by a country to associate exposure to small quantities of TFA (concentrations of at least 0.1% to 0.3%, well above those found in the PAN Europe study) with harmful human health effects.
For its proposal, BfC relied on TFA study summaries from ECHA’s non-confidential registration dossiers, including one on rats’ reproductive performance/offspring development and general systemic toxicity and another on embryo-fetal developmental toxicity in rabbits. In the latter study, eye malformations in litters occurred in all three dose groups of rabbits administered TFA, reminiscent of the similar malformations in rats and humans associated with exposure to PFOA uncovered by American attorney Robert Bilott.
The PAN Europe report cited several assessments of tolerable levels of TFA:
- European Food Safety Authority (EFSA) in 2016: 50mcg/kg body weight per day.
- German Federal Environment Agency (UBA) in 2020: 12.5mcg/kg/day.
- Dutch National Institute for Public Health and the Environment (RIVM) in 2023: 0.32mcg/kg/day. RIVM assumes that TFA has a comparable toxicological profile to other, better-studied PFAS.
The PAN Europe report also observed that there is currently no legal EU limit for TFA in surface water, groundwater or drinking water, though in 2026 the EU’s standard limit value for total PFAS of 0.5mcg/L in drinking water will come into force. However, when this value was proposed by the EU Commission, “it was not considered that existing TFA loads would exceed this limit,” the report said, adding that half of the tap water samples analyzed surpass 0.5mcg/L.
“From a legal perspective, TFA has so far been and remains an ‘invisible’ chemical,” said Sara Johansson, Senior Policy Officer for Water Pollution Prevention at the European Environmental Bureau (EEB). “The lack of quality standards for groundwater or surface water and the absence of a TFA limit for drinking water have resulted in widespread chemical contamination to pass under the radar.”
However, with the update of water pollution standards regulated under the Water Framework Directive, this could change, added Johansson. “The European Institutions now have the opportunity to set the course for water protection – they owe this to their citizens. People have a right to healthy water.”
The chemical industry addressed the environmental deposition of TFA in an October 2021 study funded by the Global Forum for Advanced Climate Technologies (globalFACT), which represents f-gas producers Chemours, Honeywell, Arkema and Koura (and equipment manufacturer Daikin). The study concluded that “with the current knowledge of the effects of TFA on humans and ecosystems, the projected emissions through 2040 would not be detrimental.” But the study also acknowledged that “the major uncertainty in the knowledge of the TFA concentrations and their spatial distributions is due to uncertainties in the future projected emissions.”
This article was updated on July 12 to include comments from Chemours’ website.
“The TFA emitted to the environment now will persist for countless generations and will spread to our most pristine freshwater ecosystems and mineral water resources.”
Hans Peter Arp, Environmental Chemist at the Norwegian Geotechnical Institute
