Non-polymer PFAS can build up in blood protein of animals, and is not always removed quickly. This means that predators eating PFAS-contaminated food will have higher levels in their bloodstream, and concentrations can increase up the food chain. Studies suggest that build up of PFAS is similar to those of other Persistent Organic Pollutants such as DDT.PFAS are estimated to be settling in arctic regions at rates of tens to hundreds of kilograms per year (25-850kg per year), depending on the specific PFAS chemical in question. Certain PFAS are released as gases to the environment and are blown a long way by wind and air currents in the atmosphere,. These gas PFAS will over time degrade to more persistent chemicals like PFOS and PFOA. This may be one reason why PFAS of environmental concern have been found in remote regions such as the Arctic as well as near PFAS production sitesPFAS including PFOS and PFOA have been found in air samples around Europe. The chemicals are found in small quantities, but appear in almost all samples tested. PFAS enters the atmosphere both from factories and the air inside our homes. PFAS is found in treated waste water from industrial and domestic sources and has been found in both rivers and groundwater. Conventional drinking water processes will not remove PFAS.PFAS-coated clothes that are thrown away will often end up either incinerated or in landfill. Unless incinerated at very high temperatures (>1000oC), fluorinated polymers could release more harmful PFAS during burning. PFAS of environmental concern have also been found in landfill leachate. Non-polymer PFAS are used in the production of fluorinated polymers. The manufacture of stain-resistant finishes generally releases these PFASs into the environment, both by air and water emissions. They are very hard to remove during water treatment. Workers in textiles factories are some of the population most exposed to these potentially harmful chemicals. Small quantities of PFAS will be removed during wash and wear of products containing PFAS. This includes fluorinated polymers used on stain-resistant coatings, and non-polymers that remain on clothes after production (Lassen et al. 2015).Most UK waste still ends up in landfill, and this includes PFAS-containing products. Studies have shown that the liquid coming from landfills (known as leachate) often contain non-polymer PFAS chemicals. In the USA the total quantities were estimated at 563-638 kg in 2013. To properly break down PFAS chemicals high temperature (1000oC or more) incineration is recommended. Incineration of municipal waste does not necessarily reach these temperatures (min temp. required is 850oC), and the incomplete breakdown could release non-polymer PFAS.Wash and wear of clothing that contains PFAS-based stain-resistant or water repellent finishes release PFAS to the environment. Coatings are thought to lose effectiveness after 20-30 washes. This can include non-polymer PFAS, remnant from production or as a break-down product of side-chain polymers (Lassen et al. 2015). The manufacture of stain-resistant finishes releases PFAS into the environment, both by air and water emissions. PFAS are very hard to remove during water treatment. Industrial emissions are estimated to be the biggest source of these chemicals to the environment.

UK Minister agrees PFAS “need to be addressed as a group”

Fidra welcomes comments from UK government minister Rebecca Pow MP, which highlights the need to move away from the current one by one approach to chemical legislation, but adds that legislation is now needed to make this a reality.

On 24th February, Fidra joined with 26 other leading health and environmental charities, filmmakers, scientists and experts, in asking the UK government to take action on forever chemicals. In recognition of the detrimental impact PFAS have on our health and environment, and following our recent report highlighting their widespread use on the UK market, the letter called for comprehensive legislation restricting the use of PFAS in paper and board food packaging.

This week Fidra received a response from Rebecca Pow MP, Parliamentary Under Secretary of State at the Department for Environment, Food and Rural Affairs (DEFRA). We are grateful for the detailed response provided, and of course for the level of attention our letter has received from DEFRA during this challenging time.

Forever chemicals and the future regulatory landscape

Fidra are extremely pleased to see recognition that tackling the issue of PFAS requires action across the full chemical group, moving away from the current one by one approach to chemical legislation. This was a key ask within the original joint letter and something that is increasingly being highlighted as a necessity to ensure health and environmental protections from this large, and growing, chemical group.

“We agree with you that these substances need to be addressed as a group, rather than on a substance by substance basis, in order to address their impacts effectively and avoid the risk of substitution by alternatives that may have similar properties.”

In her response, Ms Pow also provides important assurances that the PFAS already listed as substances of very high concern under the EU REACH regulation will remain so under UK law as we move beyond this BREXIT Transition Phase. The UK will also continue to meet its commitments to the Stockholm convention, maintaining current restrictions on listed PFAS. The below description of the UK’s planned chemicals regulatory framework, and the work currently being undertaken by regulators, offers hope for more stringent future regulations based on updated scientific evidence.

“At the end of the Transition Period the UK will put in place its own independent chemicals regulatory framework, UK REACH. Future UK decisions to control the environmental and human health impacts of substances will be taken under our independent regime and will be based on rigorous assessment of the scientific evidence. The work that our regulators are doing this year to understand the risks associated with PFAS in the UK will contribute to our evidence base.”

Forever chemicals in food packaging

Relating specifically to the risk that PFAS in food contact materials, such as packaging, has on human health, the received response states:

The food packaging industry in the UK has moved away from the use of fluorinated compounds in many paper and board products. They are now predominantly used only in specialist packaging that have particular technical requirements”.

In light of the results from our recent report ‘Forever Chemicals in the Food Aisle, this is a statement Fidra strongly disputes. Our results found PFAS in food packaging from 8 out of 9 major UK supermarkets, and 100% of takeaways tested. PFAS were identified in a range of packaging types from bakery bags intended for fresh bread, to cookie bags and pizza boxes. More worryingly, we also found extremely high concentrations of PFAS in molded fibre takeaway boxes, certified as compostable at the time of sampling. With the move away from plastic packaging gaining momentum, these eco-branded forms of packaging are very much a growing trend across the UK food market.

The response also draws attention to the role of the Food Standards Agency (FSA) in England, Wales and Northern Ireland, and Food Standards Scotland (FSS).

“Whilst fluorinated compounds from food contact materials, such as paper and board, have not raised specific safety concerns to date, the FSA regularly reviews new information on this subject”

“The FSA is currently evaluating [PFAS] relevance for food, including for paper and board food packaging, before considering whether any risk management action is required”

The European Food Standards Agency (EFSA) are currently in the process of revising their recommended tolerable daily intake (TDI) levels for two specific PFAS, PFOS and PFOA. New suggested values are 80 and 1,750 times lower than the previous 2008 levels for these chemicals, respectively. EFSA’s latest draft opinion also highlights the potential health impacts of two other PFAS, PFNA and PFHxS. Meanwhile, the UK Food Standards Agency still relies on EFSA’s outdated 2008 tolerable daily intake level for PFOA, and a level twice that of EFSA’s 2008 value for PFOS, with no mention of PFNA and PFHxS. Given the huge disparity in what is considered safe for human health, Fidra welcome the FSA’s current review and eagerly await the publication of their intended revisions.

Concluding remarks

Finally, we bring attention to the statement provided in the response below:

The current evidence has yet to demonstrate that this particular issue meets the threshold for specific legislation on PFAS in paper and board” [Rebecca Pow MP]

And draw comparison to that given by Danish Food Minister, Mogens Jensen, in September 2019, as Denmark announced their upcoming ban on the use of PFAS in paper and card food contact materials.

I do not want to accept the risk of harmful fluorinated substances (PFAS) migrating from the packaging and into our food. These substances represent such a health problem that we can no longer wait for the EU”. [Mogens Jensen]

We extend our thanks to Rebecca Pow MP for taking the time to respond to our letter during this difficult time, and are optimistic that the reviews and changes currently underway have the potential to achieve the health and environmental protections we are asking for. However, we seek clarification on the intended timescales of review, and continue to assert that the scientific evidence already demonstrates the need for comprehensive UK legislation restricting the use of all PFAS in paper and board food packaging.


Fidra’s project lead, Dr Kerry Dinsmore says:

“We are pleased to see the UK government engage on this issue and acknowledge the need for PFAS to be treated as a group. This clearly strengthens the case for much stronger future legislation in the UK, restricting the whole chemical group and preventing regrettable substitution where one harmful chemical is quickly replaced by another, adding much needed protections for our health and environment.”



Click on the link below to find out more about PFAS use in UK food packaging and to read our recent report  ‘Forever Chemicals in the Food Aisle’