Per- and Polyfluoroalkyl Substances (PFAS) in Pesticide and Other Packaging

As part of the U.S. Environmental Protection Agency’s (EPA) extensive efforts to address PFAS, the Agency is making new information available about EPA testing showing PFAS contamination from certain fluorinated containers. Read EPA’s 2021 press statement.

While the Agency continues to investigate and assess potential impacts on health or the environment, the affected pesticide manufacturer has voluntarily stopped shipment of any products in fluorinated high-density polyethylene (HDPE) containers.

On September 8, 2022, EPA released results from its evaluation on the leaching potential of PFAS from the walls of certain fluorinated HDPE containers into the liquids stored in those containers. Results from this study indicate that PFAS present in the inside walls of the fluorinated HDPE containers can be readily leached into formulated liquid products, with higher total amounts seen for products formulated in organic solvents such as methanol compared with water-based products. For both solvents tested (methanol and water), the study also shows continued gradual leaching of PFAS over time. View the summary memo and results.  (pdf) (483.05 KB)

In September 2022, the Agency issued a notice for public comment that would remove 12 chemicals identified as per- and polyfluoroalkyl substances (PFAS) from the current list of inert ingredients approved for use in pesticide products to better protect human health and the environment. These chemicals are no longer used in any registered pesticide product. Given the Agency’s concerns with PFAS use and releases, EPA believes it is appropriate to remove these chemicals from the list of approved inert ingredients in order to allow for an updated review of available information for these chemicals to be required, if their future use in pesticide products is requested. Upon publication of the Federal Register Notice, EPA will accept public comments on this proposal for 30 days in docket EPA-HQ-OPP-0542 at www.regulations.govEXIT EPA WEBSITERead the prepublication notice.

1. What is the definition of a PFAS compound in the context of pesticides?

Pesticides undergo a rigorous scientific assessment process prior to registration. EPA independently evaluates chemical-specific data to ensure that pesticides can be used safely and without unreasonable adverse effects to the environment when label directions are followed. In response to public interest in PFAS chemicals, the EPA Office of Pesticide Programs previously determined that there were no pesticide active or inert ingredients with structures similar to prominent PFAS such as PFOS, PFOA, and GenX. As further due diligence, we are now working with other offices in EPA (including the Office of Research and Development) to further evaluate structures by applying the latest working definition from our sister office, the Office of Pollution Prevention and Toxics (OPPT), which manages the Toxic Substances Control Act (TSCA) program.

2. When did EPA first learn of this contamination? What steps have been taken since initial PFAS discovery in the pesticide product?

On September 1, 2020, Public Employees for Environmental Responsibility (PEER) contacted the Massachusetts Reclamation Board, the Massachusetts Department of Agricultural Resources’ (MDAR) Division of Pest Services, and other state agencies claiming that there were unspecified PFAS in a pesticide used for mosquito control. EPA Region 1 was notified that same day.

3. What is knows about these PFAS?

To learn more about EPA’s current understanding of the human health and environmental risks of PFAS, please visit this webpage. To learn more about the concrete steps the Agency is taking to address PFAS and to protect public health, please read EPA’s PFAS Strategic Roadmap.

4. What should pesticide registrants do if they find PFAS in their production lines?

Under FIFRA Section 6(a)(2), pesticide registrants should report to EPA additional factual information on unreasonable adverse effects, including metabolites, degradates, and impurities (such as PFAS). EPA considers any level of PFAS to be potentially toxicologically significant and may trigger 159.179(b) in the Code of Federal Regulations (CFR). Under 40 CFR 159.155(a)(5)EXIT EPA WEBSITE, 6(a)(2) information about impurities must be received by EPA no later than the 30th calendar day after the registrant first possesses or knows of the information.

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