PFAS limit values

This article summarizes and compares the various limit values for PFAS in the EU and in Germany and the known PFAS indirect discharger monitoring values. PFAS (per- and polyfluorinated alkyl substances) are a group of more than 4700 synthetic chemicals that are used in many industrial and consumer products. They are persistent, bioaccumulative and toxic and can harm the environment and human health.

Limit values for PFAS in the EU

The EU has issued various directives and regulations to limit the contamination of PFAS in the environment and in drinking water. The most important limit values in the EU are

Directive 2008/105/EC on environmental quality standards (EU EQS), which sets limit values for PFOS (perfluorooctane sulfonate) in inland surface waters, transitional waters and coastal waters. The annual average standards (AAD-UQS) are 0.65 ng/L for inland waters and 0.13 ng/L for transitional and coastal waters. The maximum concentrations (ZHK-UQN) are 36000 ng/L for inland waters and 7200 ng/L for transitional and coastal waters.
Directive 2020/2184 on drinking water quality (EUTWRL), which sets limits for a group of 20 PFAS (PFAS-20) and for the total amount of PFAS (Total PFAS) in water intended for human consumption. The limit values are 100 ng/L for PFAS-20 and 500 ng/L for total PFAS.
The 2020 European Food Safety Authority (EFSA) recommendation proposing a health-based guidance value for a group of four PFAS (PFAS-4), which includes PFOA (perfluorooctanoic acid), PFOS, PFHxS (perfluorohexanesulfonate) and PFNA (perfluorononanoic acid). The guide value is 4.4 ng/L per week, based on dietary intake.
The EU Commission’s 2022 proposal to amend the EU EQS and the EUTWD to introduce limits for a group of 24 PFAS (PFAS-24) based on the sum of PFOA equivalents. The PFOA equivalents are a measure of the toxicity and accumulation of PFAS in the body that takes into account the different properties of the individual PFAS. The proposed limit value is 4.4 ng/L for PFAS-24 both in the environment and in drinking water.

Limit values for PFAS in Germany

Germany has transposed the EU directives and regulations into national law and has also set its own limit values in the Drinking Water Ordinance (TrinkwV). The most important are:

The Drinking Water Ordinance of 2023, which sets limits for PFAS-4 and PFAS-20 in water intended for human consumption. These are 20 ng/L for PFAS-4 and 100 ng/L for PFAS-20. The limit values apply from 12.01.2028 for PFAS-4 and from 12.01.2026 for PFAS-20.
There is still no generally binding regulation for wastewater (see below).

Comparison and evaluation

The limit values in the EU and in Germany are partly different and partly the same. The most important differences and similarities are

The EUUQN and the EUTWRL only contain limit values for PFOS and PFAS-20, while the TrinkwV also contains limit values for PFAS-4. The limit values for PFAS-4 in the Drinking Water Ordinance are higher than the EFSA health-based guideline value, but lower than the limit values for PFAS-20.
The limit values for PFAS-20 are the same in the EU and in Germany, both for the environment and for drinking water. The limit values for Total PFAS are only contained in the EUTWRL and are higher than the limit values for PFAS-20.
The EU Commission’s proposal in the draft EQS Directive of 26.10.2022 aims to introduce the limit values for PFAS-24, which are based on the sum of PFOA equivalents in water at 0.0044 PFOA equivalents and 0.077 PFOA equivalents. This approach should enable a more comprehensive and consistent assessment of PFAS exposure, taking into account the different toxicities and accumulations of individual PFAS. The proposed limits for PFAS-24 are lower than the limits for PFAS-20 and PFAS-4 and correspond to the EFSA health-based guidance value.

PFAS monitoring values in wastewater

In Germany, various PFAS/PFT monitoring values have already been set for individual indirect dischargers in the past, although there was no generally binding legal basis. Known monitoring values from indirect discharge notices (from the surface / electroplating sector) are:

Draft of the last amendment to Annex 40 in the unimplemented 11th amendment to the Waste Water Ordinance (11th amendment 2022):
PFOS monitoring value for perflouroctane sulfonic acid and its derivatives of 10 µg/l (1 µg = 1000 ng) in the sample.
Notification from 2019:
PFOS 20 µg/L
Notification from 2013:
Sum 2 PFT (PFOS and PFOA) 10 µg/L
Sum 10 PFT (PFBA, PFPeA, PFHxA, PFOA, PFNA, PFDA, PFBS, PFHxS, PFOS) 30 µg/L
Decision from 2008: PFT (without further definition) 3 µg/L

No general monitoring values or limit values are yet known for the substitute substance H4PFOS or 6:2-fluorotelomer sulfonic acid (6:2-FTS). Due to its structure and properties, there is no obvious reason why the substitute should behave differently in humans. In one case, a monitoring value for H4PFOS of 50 µg/L was found.

Future developments

It is to be expected that generally binding PFAS monitoring values for indirect dischargers will be introduced in the future. In particular, the new development must be considered, according to which the European Food Safety Authority (EFSA) and the BfR point out in Opinion No. 020/2021 of 28.06.2021 that the PFAS limit value of 4.4 ng/kg bw must be taken into account.
The EQS of 0.65 ng/L for PFOS was based on a TWI of 1,050 ng/kg bw. With a linear conversion, this would mean a future value of 0.00272381 ng/L EQS, i.e. a factor of 1615 lower, and would require a very significant future reduction in monitoring values.

In the draft BFEF-STM (Draft 1 (February 2025), p. 746), monitoring values of 100 ng/L (= 0.1 µg/L) for industrial dischargers from the surface treatment sector are currently under discussion using a combination of techniques such as activated carbon/ion exchange, with up to 20 ng/L (= 0.02 µg/L) being stated as achievable in individual cases. These correspond to the values in drinking water in Germany from 2026/2028. However, it remains unclear how these values were recorded, i.e. with regard to sampling, mixing with other waters, etc.

After an individual evaluation (e.g. from industrial wastewater or groundwater), PFAS are usually removed using activated carbon and/or ion exchangers, which are then thermally recycled in a single-use application. There are also other techniques, but the question remains as to whether complete mineralization actually takes place or whether only the C-C bonds are split into smaller and (currently) unmeasurable parts instead of the C-F bonds.

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