Document y1OMg5gj4zRemy1JBZGmx6Y6

Document 14 rather come in form of a consumption advice, not a ML. Regular analyses of the areas should be performed to monitor whether the fishing closure can be lifted. The proposed MLs for PFAS in fish, crustaceans and molluscs are based on a small number of products. Additionally, proposed MLs are based on small sampling sizes. This does not take into account the variation of PFAS concentrations in species. For this variation to be levelled out sampling sizes should be bigger (for example sampling sizes should exceed 1 kg. of consumption ready product). It seems that the proposed Maximum Levels (MLs) are based on the data available, not on data based on the actual food safety and/or consumer exposure. The proposed categories of PFAS concentrations seam to place a few (researched) species in a specific category and all others in a residual group. This increases the risk that some species exceed the proposed PFAS levels of that category without there being an actual food safety issue. Additionally, we believe it is strange that a ML is proposed only for certain products, while the Commission recommends (Commission Recommendation) MSs to monitor PFAS in food and feed during the years 2022, 2023, 2024 and 2025. This may indicate that the EC is not certain about the available data regarding the food categories for which a ML is proposed. We therefore ask the Commission to extend its monitoring practices to seafood products. Considering that no information is at hand at FBO level regarding the concentrations of PFAS in end products, it is important for the actual consumption pattern to analyse the PFAS content of products that are actually consumed. As there is little to no information about PFAS concentrations in consumer products at FBO level, it is not possible for the FBOs to react in a proper and motivated way to the PFAS levels proposed by the Commission. More research is necessary. Furthermore, in the calculation of the MLs we miss the actual consumption patterns of consumers. This is important for the calculation of intake of PFAS through seafood products. Without consumption patterns it is difficult to explain to FBOs why certain species fall under higher categories than others when there does not seem to be a food safety risk. Concluding remarks In summary, we consider it too early to establish legal MLs, due to the limited data and limited understanding of food safety issues. Legal MLs can lead to the rejection of sustainably caught fish products without really ensuring food safety. More research into types of end products and areas of origin is needed in order to address the PFAS problem in a meaningful way. Additionally, it is more important to conduct research of PFAS concentration in the environment rather than in individual fish samples due to multiple parameters that can vary and influence the concertation of PFAS in fish meat. AIPCE CEP recommend the Commission to: - develop a management plan on decreasing PFAS in environment - conduct more research of the actual life-span of PFAS 2 Avenue de Tervueren, 188A, 4th Floor, Postbox 4, 1150 Brussels, Belgium - Office phone number + - e-mail address: aipce@kellen.com - website: www.kellencompany.com - conduct more research of the concentration of PFAS in the environment rather than on individual fish samples - recommend Member States to provide consumption advice linked to fishing areas with high PFAS concentrations - establish consumption patterns in order to determine consumer exposure - establish monitoring practices with BFOs before establishing MLs of PFAS in products Kind regards, 3 Avenue de Tervueren, 188A, 4th Floor, Postbox 4, 1150 Brussels, Belgium - Office phone number + - e-mail address: aipce@kellen.com - website: www.kellencompany.com