Luxembourg's Ecological Movement (Mouvement Ecologique) recently called on the Luxembourg representatives on the Standing Committee on Plants, Animals, Food and Feed (PAFF Committee) to support the European Commission's proposal to ban pesticides including trifluoroacetic acid (TFA).

According to a statement issued by the Ecological Movement, the chemical TFA has made its way into the environment unchecked. TFA forms as a result of the degradation of various man-made substances (especially pesticides and coolants). It is small, mobile and resilient, and according to the statement, it has spread to groundwater as well as rivers and springs. The organisation added that the latest report from Pesticide Action Network Europe (PAN Europe) revealed that analyses of bottled mineral water, from all over Europe, show contamination with TFA.

The organisation also noted that over 50% of the environmental contamination with TFA comes from the use of perfluoroalkyl and polyfluoroalkyl (PFAS) pesticides. The main sources of TFA are the pesticide active ingredients flufenacet and flutolanil, which are contained in numerous pesticides. It also reported that that the European Commission has submitted a proposal to withdraw the approval of these ingredients to the PAFF Committee.

The statement emphasised that TFA is now found in all water bodies. In July 2024, as part of an EU campaign by PAN Europe, both surface and groundwater bodies were reportedly contaminated. Analyses of bottled mineral water found that, in ten out of nineteen brands examined, TFA was present in the groundwater reservoirs from which the mineral water was sourced, often hundreds of meters deep and supposedly protected from anthropogenic pollutants. In seven of nineteen cases, the TFA contamination level exceeded the drinking water limit for relevant pesticide metabolites, which is 0.1 μg/l (100 ng/l).

Around 350 nanograms of TFA per litre were detected in mineral water samples from Luxembourg. The Luxembourg mineral water contamination level was in the mid-range. In some non-Luxembourg mineral waters, no TFA could be detected; in others significantly higher values (up to 3,200 ng/l) were noted.

The statement continued: "It is worrying that it is now clearly established that bottled mineral water is also contaminated with the eternal chemical. This is all the more problematic because consumers assume that this is a ‘natural’ and ‘pure’ product. In order to be allowed to write the name ‘mineral water’ on your bottle, certain rules and quality criteria apply: For example, a filter process for cleaning is prohibited, the bottled water must originally be free of contaminants. Apart from the fact that TFA is very expensive and inefficient to filter, this would not be an option for mineral water anyway."

In addition to public water suppliers, the current analysis is also reported to reveal that mineral water bottlers are faced with the new challenge of having to ensure that the water sources they use are protected from further contamination. They are reported to have only limited influence on ensuring the protection of their water resources independently and are dependent on the responsible authorities taking the necessary precautions to ensure the purity of drinking water in the long term.

The Ecological Movement emphasised that, according to current knowledge, each of the mineral waters examined - even the one with the highest measured contamination of 3,200 ng/l – is within the health guidelines for adults, set out in the EU, but it stressed that there are limitations to this knowledge. It added that the effect of TFA on human health is currently being examined more closely by the World Health Organization (WHO), with the results due to be available by the end of 2025.

The Ecological Movement indicated that there is suspicion of reproductive harm as a result of TFA, explaining that the chemical producer Bayer has reported TFA should be considered a "toxicologically relevant metabolite", i.e. a toxic degradation product. According to European law, a uniform limit of 0.1 μg/l applies to such substances in groundwater and drinking water. But this value is far exceeded. As a result, as TFA enters waters unchecked, the risk that health-relevant threshold values will be exceeded increases. The organisation added that "it is therefore now necessary to act as a precaution and stop the entry of TFA precursor substances into our environment".

The statement noted that water from the tap is preferable to water from a bottle, mentioning that the average TFA content of all mineral water analysed was in the range of that of tap water. Taking factors such as CO2 emissions during transport, packaging material, etc., into account, tap water is still considered more sustainable than bottled water.

The organisation stressed that "the findings should not be a reason to panic, but rather a wake-up call and motivate us to act quickly: In accordance with the precautionary principle, all further entries of TFA into the environment must be avoided immediately! So that we can still drink our water in ten years!"

PAN Europe together with the Ecological Movement appealed to the member states to:

• Ban PFAS pesticides, by having member states, including Luxembourg, agree to the proposed ban on flufenacet and flutolanil and implement it immediately;

• Support environmentally friendly agriculture: PFAS pesticides should not be replaced by other toxic substances. Farmers should be given adequate technical and financial support when switching to more environmentally friendly methods;

• Adapt the EU Drinking Water Framework Directive: A TFA limit value for safe drinking water must be set that corresponds to the latest scientific findings and opens up the possibility of setting an individual limit value for TFA at European level;

• Revise the EU Water Framework Directive: There are crucial meetings here at the end of 2024: quality standards for TFA in natural waters must be set there;

• Publish analysis results: The state should publish regular drinking water samples as well as analyses of bottled mineral water;

• Opt for wide-ranging protection of sources: As the contamination of bottled mineral water now shows, wide-ranging protection of drinking water bodies is required. A fundamental discussion on how this can be optimised should be ensured;

• Use various chemicals at EU level: Luxembourg should become an active driver so that TFA-relevant chemicals (coolants, cosmetics, pan coatings, etc.) are banned at EU level, including within the framework of the Chemicals Ordinance;

• Ensure general educational work: It is the role of the state to ensure that an active information campaign is carried out on how consumers can generally protect themselves from the contamination of TFA.