Opinion 033/2024

doi https://doi.org/10.17590/20240710-153639-0

10 July 2024

Feed is key to compliance with maximum PFAS
levels in food of animal origin→ Updated opinion no. 37/2021 of November 24, 2021. Following the establishment of maximum
levels for PFAS in animal feed, the calculations on the maximum PFAS levels in feed wereupdated. New findings from animal studies were taken into account.

Per- and polyfluoroalkyl substances, PFAS for short, are chemicals that are used inmany industrial processes and are processed in numerous consumer products.
They are difficult to break down and accumulate in the environment, for example
in water and soil. This has earned them the name "Forever Chemicals". As plants
can absorb PFAS from the soil as they grow, livestock can accumulate thesecompounds through feeding, which then enter the human body when food ofanimal origin is consumed.
Since January 2023, maximum levels have applied in selected food of animal origin
in the EU : for perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA),
perfluorononanoic acid (PFNA) and perfluorohexane sulfonic acid (PFHxS) as well
as for the sum of these four PFAS. In this opinion, the German Federal Institute for
Risk Assessment (BfR) has determined the maximum concentration of individual
PFAS in complete feed for various livestock in order to comply with the maximum
levels in food. PFAS levels in feed for cattle, sheep, fattening pigs and laying hens
were modelled.
According to the BfR's assessment, feed with a PFAS level below the calculated
values does not lead to the maximum levels in food of animal origin being
exceeded. Until the (intended) establishment of maximum levels in feed, thevalues can serve as consumer protection-based guidance values for various players
in the environmental and agricultural sectors.
The BfR points out that the data available on the PFAS level in various feedmaterials is currently limited and recommends to collect representative feed data.
If an assessment of the health risks posed by PFAS is to be made for the transfer ofPFAS from feed to food of animal origin, other sources of PFAS intake by livestock
such as soil or drinking water must also be taken into account.

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Subject of the assessment
Against the background of the discussion on the introduction of EU maximum levels for perand polyfluoroalkyl substances (PFAS) in food of animal origin in the European Union, theBfR was asked by the Federal Ministry of Food and Agriculture (BMEL) in 2021 to comment
on questions regarding the level of PFAS in feed. The aim was to examine whether, based on
the background contamination of PFAS in feed, the proposed maximum levels in food ofanimal origin can be complied with or up to which PFAS concentrations feed fromcontaminated areas is still suitable for feeding purposes under these requirements. (Opinionno. 037/2021 of November 24, 2021). Based on the discussion proposals at EU level in 2021,
the BfR had estimated maximum possible PFAS levels in feed for various livestock species atwhich the proposed maximum levels in the corresponding food of animal origin would not
be exceeded.
Since January 1, 2023, maximum levels for perfluorooctane sulfonic acid (PFOS),
perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA) and perfluorohexane sulfonicacid (PFHxS) as well as for the sum of these four PFAS, which have been adopted inCommission Regulation (EU) 2023/915 of April 25, 2023 on maximum levels for certain
contaminants in foodstuffs, have been applicable in certain food of animal origin. No
maximum levels have been set for milk; instead, guidance values for the four individualcompounds are recommended in Commission Recommendation (EU) 2022/1431 of August24, 2022 on the monitoring of perfluoroalkyl substances in food.
The maximum levels for PFAS in food of animal origin laid down in Regulation (EU) 2023/915
differ slightly from the maximum levels that were under discussion at EU level in 2021.
Discussions are currently underway with the European Commission to regulate maximum
levels of PFAS in feed. A timely setting of maximum levels for PFAS in feed is not expected
due to the current insufficient data situation, among other things. However, the BfR believes
that there is an increasing need for consumer protection-based guidance values for PFAS
levels in feed for various stakeholders in the environmental and agricultural sectors. For
these reasons, the BfR has updated its opinion on PFAS maximum levels in feed.

2ResultThe BfR has used toxicokinetics modeling to estimate PFAS levels in complete feed for which
it can be assumed that the currently applicable maximum levels or indicative values for foodare complied with. The modeling is based on the results of scientific studies on the transferof PFAS from feed to food of animal origin. PFAS levels were modelled for complete feed forcattle, sheep, fattening pigs and laying hens. For feed with an actual PFAS content below
these recalculated values, the BfR assumes that it is unlikely that the maximum level in foodwill be exceeded.

3Rationale
The BfR has created toxicokinetics models for laying hens (Kowalczyk et al 2020), dairy cows
and beef cattle (Mikkonen et al. 2023), sheep (Kowalczyk et al. 2012, Zafeiraki et al. 2016,
Drew et al. 2021) and fattening pigs (Numata et al. 2014) using the transfer studies on© BfR | PFAS in feed | Opinion issued 10 July 2024

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livestock available to it. For the calculations, it was assumed that the exposure of theanimals to PFAS occurs exclusively via the feed and over an entire period of use (e.g. layingperiod, fattening period) without prior exposure to these compounds (e.g. in piglets/lambs
during the suckling period). As all four PFAS compounds have different toxicokinetics in theindividual animal species, the calculation of PFAS concentrations in complete feed is limited
to the individual substances PFOS, PFOA, PFNA and PFHxS.
Table 1 shows the PFAS levels determined by the BfR in complete feed for various livestock
species in micrograms per kilogram of dry matter (µg/kg DM), the feeding of which does notexceed the maximum levels in food according to Regulation (EU) 2023/915 on average.
Table 1: Maximum PFAS levels in food of animal origin according to Regulation (EU) 2023/915 and modelledmaximum possible PFAS levels in complete feed for laying hens, fattening cattle, sheep and fattening pigs, forwhich the maximum levels according to Regulation (EU) 2023/915 for eggs or meat/offal are not exceeded onaverage when fed
Food*

PFOS

PFOA

PFNAPFHxSµg/kg fresh weightEggs

1,00,300,700,30

Meat of bovine animals,pigs and poultry

0,300,800,200,20

Meat of sheep

1,00,200,200,20

Offal of bovine animals,
sheep, pig and poultry

6,00,700,400,50PFOSPFOAPFNAPFHxS

Complete feed

µg/kg dry matter

Laying hens

0,420,250,290,17

Cattle0,14

n.a.**

n.a.

1,0

Sheep

0,21#n.a.

n.a.

n.a.

Fattening pigs

0,07

0,05

n.a.

0,06

* Maximum levels according to Regulation (EU) 2023/915; ** The transfer of PFOA in cattle is very low; # Calculation withlimited data set; n.a.: not available due to insufficient data

Table 2 shows the PFAS levels in the complete feed for dairy cows in the daily ration (µg/kgDM) at which the indicative level for PFAS in milk according to Recommendation (EU)2022/1431 are complied with.
Table 1: PFAS concentrations in complete feed for dairy cows which, when fed on average, do not lead to theindicative level for milk in accordance with Recommendation (EU) 2022/1431 being exceeded.

Milk (µg/kg fresh weight)*
Complete feed for dairy cows(µg/kg dry matter)

PFOS

PFOA

PFNAPFHxS

0,02

0,01

0,05

0,06

0,07

6,5**

n.a.

3,7

* Indicative level according to Recommendation (EU) 2022/1431; ** The transfer of PFOA in cattle is very low;n.a.: not available due to insufficient data available© BfR | PFAS in feed | Opinion issued 10 July 2024

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When estimating PFAS levels in complete feed, there are differences between animal
species and production categories, which can be attributed, for example, to differences inweight gain, feed intake of the animals and the accumulation and excretion behaviour of thecompounds.
The current data are not sufficient to estimate what proportion of the total PFAS
concentration in the ration individual feed components may have in order to ensure thatfood of animal origin has PFAS concentrations that do not exceed the applicable maximum
levels. The PFAS levels in feed shown in Table 1 and Table 2 were therefore based on thecomplete feed. For the improvement of the data set and future recommendations forpossible options for action in the composition of rations, the BfR recommends the collectionof representative data for PFAS in various feed materials from different origins as part ofmonitoring programs.
PFAS are industrial chemicals that are ubiquitous in the environment. For this reason,
livestock can be exposed to PFAS not only via feed, but also via e.g. soil or drinking water.
Accordingly, all PFAS sources relevant to the food-producing animal must be taken into
account in a risk assessment.

Further information on PFAS on the BfR website
FAQ: Here to stay: Per- and polyfluoralkyl-substances (PFAS) in food and in theenvironment
https://www.bfr.bund.de/cm/349/here-to-stay-per-and-polyfluoroalkylsubstances-pfas-in-food-and-in-the-environment.pdf
BfR-opinion: Exposure assessment for the intake of PCDD/Fs and dioxin-like PCBs
as well as PFAS through the consumption of different fish species
https://www.bfr.bund.de/cm/349/exposure-assessment-for-the-intake-of-pcddfs-and-dioxin-like-pcbs-as-well-as-pfas-through-the-consumption-of-different-fishspecies.pdf

4Referenzen
Drew R, Hagen TG, Champness D. Accumulation of PFAS by livestock - determination oftransfer factors from water to serum for cattle and sheep in Australia. Food Addit Contam
Part A Chem Anal Control Expo Risk Assess. 2021 Nov;38(11):1897-1913. doi:
10.1080/19440049.2021.1942562. Epub 2021 Jul 29. PMID: 34323170.
Kowalczyk J, Ehlers S, Fürst P, Schafft H, Lahrssen-Wiederholt M. Transfer of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) from contaminated feed into milk
and meat of sheep: pilot study. Arch Environ Contam Toxicol. 2012 Aug;63(2):288-98. doi:
10.1007/s00244-012-9759-2. Epub 2012 Mar 28. PMID: 22453775.

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Kowalczyk J, Göckener B, Eichhorn M, Kotthoff M, Bücking M, Schafft H, LahrssenWiederholt M, Numata J. Transfer of Per- and Polyfluoroalkyl Substances (PFAS) from Feed
into the Eggs of Laying Hens. Part 2: Toxicokinetic Results Including the Role of Precursors.
Journal of Agricultural and Food Chemistry 2020 68(45): 12539-12548.
Mikkonen AT, Martin J, Upton RN, Moenning J-L, Numata J, Taylor MP, Roberts MS, Mackenzie L. Dynamic exposure and body burden models for per- and polyfluoroalkyl substances (PFAS) enable management of food safety risks in cattle. Environment International2023
Numata J, Kowalczyk J, Adolphs J, Ehlers S, Schafft H, Fuerst P, Müller-Graf C, LahrssenWiederholt M, Greiner G. Toxicokinetics of seven perfluoroalkyl sulfonic and carboxylic acids
in pigs fed a contaminated diet. J. Agric. Food Chem. 2014. 62: 6861-6870.
Zafeiraki E, Vassiliadou I, Costopoulou D, Leondiadis L, Schafft HA, Hoogenboom RLAP, vanLeeuwen SPJ. Perfluoroalkylated substances in edible livers of farm animals, including
depuration behaviour in young sheep fed with contaminated grass. Chemosphere. 2016
Aug;156:280-285. doi: 10.1016/j.chemosphere.2016.05.003.

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About the BfR
The German Federal Institute for Risk Assessment (BfR) is a scientificallyindependent institution within the portfolio of the Federal Ministry of Food andAgriculture (BMEL) in Germany. The BfR advises the Federal Government and theStates (‘Laender’) on questions of food, chemicals and product safety.
The BfR conducts independent research on topics that are closely linked to its
assessment tasks.

This text version is a translation of the original German text which is the only legally binding version.
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