Publication of a FAQ regarding the order of 03/09/25 on PFAS in urban wastewater treatment plants

[hover_box image=”https://www.phytocontrol.com/wp-content/uploads/2025/11/epuration.png” image_hover=”https://www.phytocontrol.com/wp-content/uploads/2018/03/actu_publication-rasff-2016_02.jpg” link=”” target=””]

A FAQ was published in early November to provide technical clarifications regarding the implementation of the order of 3 September 2025 on the analysis of per- and polyfluoroalkyl substances in water entering and leaving urban wastewater treatment plants.

Here are the points that have been clarified:

Treatment plants concerned

Urban wastewater treatment plants with a capacity greater than 10,000 population equivalent are subject to the order.

• Plants covered under heading 2752 are not concerned.
• Plants with a gross pollution load of less than 600 kg/day of BOD5 are also included.
• Plants that have already tested for PFAS must comply with the monitoring requirements.

Procedures for implementing the order

No prefectural authorisation is required for the implementation of the order.

• Monitoring only concerns the plants and substances specified in the order.
• A prefectural order is required if additional requirements are added.

Measurements required for monitoring

The plant operator must carry out 3 measurements in 2026 in both raw water and treated water, spaced at least one month apart, allowing the average 24-hour concentrations of each substance to be monitored to be determined. Sampling of raw water and treated water will be carried out on the same day.

Measurement periods must cover peak activity periods, such as summer in coastal areas.

List of PFAS to be monitored

Plant operators must establish a list of PFAS to be monitored in effluents from classified facilities.

• This list must be sent to the water police department within three months of 8 September 2025.
• PFAS quantified during analyses of classified facilities (ICPE) must be included.

Access to ICPE data

PFAS analysis results from classified facilities (ICPE) are published on the DREAL and DEAL websites.

• The data includes the destination of discharges and the PFAS quantified.
• Plant operators can use this data to determine the substances to monitor.

Laboratory accreditation requirements

Testing laboratories must be accredited for PFAS sampling and analysis.

• Accreditation is required for the 22 PFAS substances, but not for additional analyses.
• Laboratories must comply with current standards to ensure the quality of analyses.

Sampling procedures

Sampling operations must follow specific standards to ensure quality.

• Sampling must be representative and carried out using suitable materials.
• Quality control (sampling blank) must be carried out during the campaign.

Transport and receipt of samples

Samples must be transported and received in accordance with strict procedures.

• They must be kept at a temperature of 5±3°C and analysed within 24 hours of sampling.
• Specific deadlines apply to samples from overseas departments and regions (DROM).

Carrying out PFAS analyses

Analyses must take into account the whole sample, including the particulate phase.

• Enhanced quality control is required due to the widespread presence of PFAS.
• Laboratories must implement specific steps to recover adsorbed PFAS.

AOF measurement and additional parameters

AOF measurement must be carried out only on outlet water (point A4).

• Specific standards for AOF measurement are currently being developed.
• The plant’s usual monitoring parameters must be analysed to interpret the results.

Please note that Phytocontrol holds national approval from the Ministry of Health and the Environment for carrying out sampling and analyses for water health monitoring.

Details of our accreditations can be found in our COFRAC technical annex No. 1-6066.

Need technical, regulatory or pricing information? Our customer service is available from 8am to 6:30pm, Monday to Friday, at +33 800 900 775 or service-clients@phytocontrol.com.

And to stay up to date with Phytocontrol news, follow us on our LinkedIn page!