AGROCHEMICALS document on PFAS of June 2025, ECHA noted that a general restriction of PFAS in PPPs could affect at least 48 active substances contained in more than 200 PPPs currently approved in the EU. Similarly, the NGOs Pesticide Action Network and Générations Futures identified 32 PFAS active substances in their July 2025 Position Paper on PFAS Pesticides & Other Sources of TFA, stating that“ nearly all” the identified substances are possible precursors to TFA. 1
More targeted assessments have highlighted a subset of PFAS substances of particular relevance to TFA. The EC’ s 2024 mandate to review toxicological reference values for TFA listed 11 active substances of interest, while the TriFluPest report by the Danish Environmental Agency assessed seven active substances for their potential to form TFA and leach into groundwater, with 24 authorised substances as potential TFA precursors due to the presence of a carbon-bonded CF 3 structure. 2
AgbioInvestor identified 51 distinct active substances from these sources. Figure 2 shows the value of the active substance on the EU market while Figure 3 lists the proportion of the 2024 European crop protection market( excluding Russia, Ukraine and the UK) associated with active substances identified within the highlighted reports and material.
The Background Document to the Opinion on the Dossier Proposing Restrictions on PFAS from ECHA’ s Committee for Risk Assessment( RAC) and Committee for Socioeconomic Analysis( SEAC) provided a non-exhaustive list of PFAS active substances. 3
The TriFluPest report is perhaps the most comprehensive publication to date identifying TFA precursor molecules. It found that all of them degrade to TFA, with formation rates varying depending on the parent compound and soil type, and identified seven active substances for assessment based on their commercial relevance and potential to form TFA.
Ultimately, Denmark banned 33 PPPs containing diflufenican, fluazinam, flonicamid, fluopyram, mefentrifluconazole and taufluvalinate. The bans explicitly cited the fact that these PPPs contain active substances capable of forming TFA, marking what is understood to be the first explicit restriction of PPPs based on TFA formation.
Lastly, EFSA’ s mandate to review toxicological reference values for TFA was published in July 2024, and referenced substances for which TFA had been identified in completed and ongoing assessments as part of the approval procedure for pesticide active substances in the EU.
The following analysis assumes general restrictions on the identified substances to consider the commercial implications of such measures, based on market data from 2024. Using the list of substances identified in the Background Document, approximately 11 % of the European crop protection market could be at risk of general regulatory actions.
Based on the list of substances identified in the TriFluPest report, which is more targeted to TFA precursor pesticides, approximately 7 % of the European crop protection market could be at risk from general regulatory actions. The substances already banned in Denmark represent over 2 % of European market, while the substances identified in the mandate to review toxicological reference values for TFA account for about 3 %.
Outlook
The evolving nature of regulatory procedures concerning TFA precursor substances and PFAS more broadly makes it challenging to provide forward-looking assessments of potential regulatory outcomes. Any scenario involving general restrictions should therefore be understood as illustrative of possible market disruption
12 %
Figure 2- Value share of EU CP market for TFA / PFAS active ingredients identified, 2024
Note: Pink = value of the active substances banned in Denmark in 2025 as a result of the TriFluPest report
10 % |
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8 % |
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6 % |
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4 % |
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2 % |
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0 % |
RAC & SEAC proposed restrictions on PFASs |
TriFluPest |
EFSA mandate for tox. ref values for TFA |
MAY / JUN 2026 SPECCHEMONLINE. COM
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