PAN Europe welcomes the opportunity to provide comments on the ECHA’s CLH report on the new hazard classes of TFA.
Our organisation is closely following the developments related to TFA, as it is a common degradation product of 30 PFAS pesticide active substances used in numerous pesticide products across Europe. The use of PFAS pesticides has increased over the past 10 years, as we can see by rising residue levels in fruit and vegetables, as well as in sales data, where available. Most PFAS pesticides contain at least one -CF3 group and are a significant source of TFA contamination into the environment and water resources. Our preliminary work has shown that TFA is detected in water resources across all Europe, including drinking water, both tap or mineral bottled water, as well as groundwater.
Given that human and environmental exposure to TFA is already widespread and rapidly increasing, it is of utmost importance to conduct an objective, independent, and thorough investigation of the toxicity of this common pesticide metabolite. As this issue concerns multiple PFAS substances, the assessment process must be protected from industry attempts to downplay the toxicity of the substance.
Scientific evidence clearly indicates the potential of this very persistent and very mobile metabolite to impair fertility and foetal development. A correct classification of its hazard properties will support political measures to remove the relevant pesticide products from the market- as well as other TFA emitters - and ensure better protection of public health, now and for future generations.