ECHA Recommends TFA Classification: Implications for PPPs and Biocides
ECHA Recommends TFA Classification: Implications for PPPs and Biocides
On the 6th of October 2026, the European Chemicals Agency (ECHA) published the final opinion of its Committee for Risk Assessment (RAC) recommending new harmonised classifications for trifluoroacetic acid (TFA) and its inorganic salts. The opinion, adopted in June 2026 following a proposal from the German authorities, recommends classifying TFA and its inorganic salts as toxic to reproduction, as well as persistent, mobile and toxic (PMT) and very persistent and very mobile (vPvM). For reproductive toxicity, RAC recommends Category 1B for adverse effects on development and Category 2 for effects on sexual function and fertility. For TFA itself, RAC also recommends Acute Toxicity Category 4 by the oral route and Acute Toxicity Category 3 by inhalation.
The proposed environmental classifications reflect concerns regarding the very high persistence and mobility of TFA. The ECHA CLH assessment reports that no degradation was observed in several environmental studies and that TFA⁻ has an extremely low adsorption potential. In an OECD 106 adsorption/desorption study, TFA⁻ did not sorb onto soil to any extent. These findings are consistent with the assessment of TFA as very persistent and very mobile, with the potential to cause persistent contamination of water resources.
TFA is also a potential degradation product of a range of fluorinated substances, including active substances used in both plant protection products (PPPs) and biocidal products (BPs).
The potential significance of TFA as a degradation product has already been demonstrated in the PPP sector. In 2024, the Danish Environmental Protection Agency published the results of the TriFluPest research project, which investigated TFA formation from seven fluorinated pesticide active substances in agricultural soils. The findings indicated that TFA formation from some of these active substances could contribute to TFA concentrations in groundwater. In 2025, Denmark subsequently withdrew the approvals of 33 pesticide products containing six active substances: fluazinam, fluopyram, diflufenican, mefentrifluconazole, tau-fluvalinate and flonicamid. The Danish Environmental Protection Agency stated that these active substances can form TFA, which can leach into groundwater and is very slowly degraded. The decisions were therefore taken to protect Danish groundwater.
It can also be noted that the Danish decision predates the ECHA RAC opinion, which may indicate that Member States could take national regulatory action in relation to PPPs or BPs containing active substances that may form TFA as a transformation product and contribute to groundwater contamination, either before or following any future amendment to the EU harmonised classification. The ECHA RAC Opinion has now been sent to the European Commission for consideration.
For companies involved in the development, registration and authorisation of PPPs and BPs containing relevant active substances, this is an important development to monitor, particularly in relation to potential implications for environmental risk assessment.
If you need support with environmental risk assessments or regulatory strategy for PPPs and biocidal products, please do not hesitate to contact the regulatory team at info@kerona.ie.