Environmental Working Group

EWG testimony to the California Senate Committee on Agriculture on AB1603 to increase the transparency and reporting of PFAS pesticides usage rcoleman July 9, 2026

Thank you for the opportunity to testify today. My name is David Andrews and I am the Chief Science Officer for the Environmental Working Group.

I hold a Ph.D. in Chemistry from Northwestern University and have been a co-author on ten peer-reviewed publications on PFAS, including a paper on PFAS pesticides.

PFAS—or "forever chemicals"—pose serious health risks, including cancer, reproductive problems, harm to the thyroid and immune system, liver and kidney disease and more. 

2.5 million pounds of PFAS pesticides are used each year in California.

40% of non-organic produce grown in California had at least one PFAS pesticide, some with many. 

PFAS pesticides are widespread in water and soil in California.

PFAS should be regulated as a class - we do not want one problematic chemical substituted for another. 

California’s Department of Toxic Substances Control has stated that all PFAS share the core hazard trait of extreme environmental persistence. 

PFAS pesticides fall into a regulatory blind spot.

The US EPA’s and the California Department of Pesticide Regulations’ current have been inadequate with respect to immune system harm, or the cumulative impacts of the very small PFAS.

TFA, or trifluoroacetic acid, is one of the small PFAS contaminants that result from PFAS pesticide usage and levels are increasing in our water, food and environment.

North Carolina ground water testing found TFA in nearly all of their samples, and it is estimated that PFAS pesticide use in California creates up to 600,000 pounds of TFA.

Earlier this month, ECHA's scientific committee concluded TFA should be classified as toxic to reproduction, and also very persistent and very mobile.

With the increasing evidence of harm from PFAS we are disappointed that the legislature is not acting more decisively on PFAS pesticides but we support this step to catalogue usage.

Thank you.

Areas of Focus Toxic Chemicals Pesticides PFAS Chemicals Authors David Andrews, Ph.D. June 30, 2026

EWG testimony to the California Senate Committee on Environmental Quality on AB1603 to restrict and ban the use of PFAS pesticides rcoleman July 9, 2026

Good morning,

Thank you for the opportunity to testify today. My name is Varun Subramaniam and I am a Science Analyst at the Environmental Working Group.

I hold a graduate degree in health data science as well as a degree in environmental health.

I coauthored recent reports which found that, each year, millions of pounds of PFAS pesticides are being applied to, and detected in high frequencies on, fruits and vegetables grown in California. 

PFAS pesticides are also often found in surface water and soil near agricultural areas.

PFAS in any form pose serious, well-documented health and environmental risks that warrant strict limitations of their use and regulation as a class. 

Exposure to PFAS is linked to liver and kidney disease, reproductive problems, child development delays, cancer, weakened thyroid function, and reduced vaccine effectiveness in children. 

Additionally, all PFAS share the core characteristic of a carbon-fluorine bond that results in extreme environmental persistence; they do not fully break down in the environment.3

This drastically increases the timeframe of exposure, with today’s contamination potentially harming health for decades.

These PFAS pesticides fall into a regulatory blind spot.

Current regulatory evaluations of PFAS pesticides do NOT adequately account for potential immune system harm or the impacts of very small forms of PFAS that form from many PFAS pesticides, including trifluoroacetic acid or TFA.

Immunotoxicity is one of the most critical health effects for PFAS risk assessments, so we are overlooking key, not fringe, information by not considering studies of immune effects.4,5

In addition, TFA, which is linked to reproductive harm, has been detected in nearly all water and human serum samples, where tested.

Fortunately, farmers have options that are not PFAS. 

Of the roughly 1,000 active pesticide ingredients currently approved for use in California, 95% are not PFAS. And other states, like Maine and Minnesota, have already announced planned phase-outs for these chemicals.

The health and environmental risks of PFAS exposure are significant. 

Scientists across the world agree that we must act swiftly to halt this multigenerational cycle of contamination.

Thank you.

Areas of Focus Toxic Chemicals Pesticides PFAS Chemicals Authors Varun Subramaniam, M.S. June 24, 2026

EWG testimony to California Assembly Committee on Environmental Safety and Toxic Materials on AB1603 to restrict and ban the use of PFAS pesticides rcoleman July 9, 2026

Good morning, Mr. Chairman and members of the Committee. Thank you for the opportunity to testify today.

My name is David Andrews, and I am the Acting Chief Science Officer at the Environmental Working Group. I hold a Ph.D. in Chemistry from Northwestern University and have been a co-author on ten peer-reviewed publications on PFAS, including a 2024 paper that identified EPA-approved PFAS pesticides.

PFAS—often called "forever chemicals"—pose serious, well-documented health risks. 

Exposure to this class of chemicals is linked to altered immune and thyroid function, liver and kidney disease, reproductive problems, child development delays, cancer and more. 

The Department of Toxic Substances Control has stated that all PFAS share the core hazard trait of extreme environmental persistence.

And what may surprise you is that our food is a primary, under regulated route of exposure.

PFAS pesticides fall into a regulatory blind spot.

The EPA’s and the California Department of Pesticide Regulations’ current regulatory evaluation of PFAS pesticides have NOT adequately evaluated the pesticides’ potential for immune system harm, or fully assessed the impacts of the very small PFAS, including trifluoroacetic acid or TFA, that form from PFAS pesticides. 

Levels of these small PFAS are increasing in our water, food and environment and exposure to them is linked to reproductive and immune toxicity.

North Carolina ground water testing found TFA in 95% of their samples, and it is estimated that PFAS pesticide use in California creates up to 600,000 pounds of TFA each year. These findings should alarm California, which will likely find similar contamination when official tests are done.

In regard to food, EWG recently found that nearly 40% of all non-organic produce grown right here in California contains traces of at least one PFAS pesticide. For some agricultural staples such as peaches, plums and nectarines, the numbers are even higher.

Fortunately, farmers have options that are not PFAS. Of the roughly 1,000 active pesticide ingredients currently approved for use in California, only 53 are PFAS. 

Thank you.

Areas of Focus Toxic Chemicals Pesticides PFAS Chemicals Authors David Andrews, Ph.D. April 14, 2026

EWG testimony to Vermont House Committee on Agriculture, Food Resiliency, and Forestry on H.911 to prohibit PFAS in pesticides and packaging rcoleman July 9, 2026

Good morning, Mr. Chairman and members of the Committee.

Thank you for the opportunity to testify this morning. 

My name is Varun Subramaniam, and I am a Science Analyst at the Environmental Working Group. 

I hold a master's degree in health data science from the George Washington University’s Milken Institute School of Public Health and a degree in environmental health science from the University of North Carolina at Chapel Hill Gillings School of Global Public Health.

My professional work involves applying data science techniques to issues of environmental health, with attention to chemical exposures. 

EWG is a national environmental organization that has, for several decades, investigated the impacts of PFAS on public health and tracked PFAS detections in tap water. 

EWG has published multiple peer-reviewed studies on PFAS exposure sources, including a 2024 peer-reviewed paper on PFAS pesticides. 

Last month, we published a new analysis on the presence of PFAS on fruits and vegetables in the United States.

The growing threat of PFAS

PFAS pose serious health risks to the public.

According to the Environmental Protection Agency, PFAS exposure may lead to increased cholesterol, decreased fertility, developmental harm including low birth-weight, interference with the body’s natural hormones and harm to the immune system.

The agency also reports that PFAS have been linked to an increased risk of some cancers, including prostate, kidney, and testicular cancers. 

PFAS exposure for children is particularly concerning due to increased sensitivity to the harmful effects of chemicals such as PFAS.

PFAS overexposure

We know from recent research that everyone is overexposed to PFAS. 

In 2022, the National Academies of Sciences, Engineering, and Medicine assessed PFAS concentrations in human blood samples.

They found that 98% of samples had PFAS levels that warranted exposure reduction and screenings for various health disorders, including hypertension during pregnancy and breast cancer.

PFAS are frequently found in our tap water. 

Food as a Primary Route of Exposure

What may surprise you is that our food, not our water, might be an even bigger source of PFAS exposure. 

The general scientific consensus is that our food is a significant, if not primary, route of exposure.

A 2020 study in Environment International concluded that dietary exposure from the ingestion of food and drinks was the “predominant exposure pathway” to PFAS.

How PFAS enters our diets

PFAS contaminates our food in many, overlapping ways. 

First, PFAS that is used in food packaging can migrate into our food. 

Second, sewage sludge that is contaminated with PFAS and used as a fertilizer can contaminate our food and the farm animals who are fed contaminated feed. 

Third, irrigation water that is contaminated with PFAS can also be absorbed by crops and contaminate our food. 

Fourth, and perhaps most directly, pesticides either made with PFAS as an ingredient or stored in containers that are lined with PFAS can contaminate our food. 

PFAS pesticides on produce

The presence of PFAS pesticides on our food is widespread.

Last month, EWG released a new study of PFAS residues on produce. 

We analyzed testing data from the U.S. Department of Agriculture and found 31 different PFAS pesticides were detected on 30% of non-organic U.S. fruit and vegetables.

The most commonly detected pesticide on U.S. produce was fludioxonil–a PFAS fungicide.

Fludioxonil was found on 14% of all produce samples and on nearly 90% of peach and plum samples.

Peer-reviewed literature has linked fludioxonil exposure to hormonal disruption and has found evidence of reproductive toxicity.

Why are PFAS used in pesticides?

You might ask: why is PFAS used in pesticides?

PFAS can modify the attributes of pesticides, mainly conferring increased molecular stability on the chemical. This means that the pesticides can’t be broken down easily and are highly heat-resistant.

PFAS are also known to increase membrane permeability, meaning that pests absorb the chemical faster and can be immobilized more efficiently11.

Alternatives to PFAS pesticides

Farmers have alternatives to pesticides made with PFAS. 

There are effective options available to manage insects and weeds without relying on PFAS pesticides.

Biological controls, such as biopesticides or those derived from entirely biological sources, are popular alternatives to PFAS pesticides.

The menu of pesticides available to farmers is large and ever-growing, with new pesticide active ingredients and products coming to the market each year. 

There are more than 90,000 pesticide products registered with the EPA, comprising over 800 active ingredients. Of these, about 350 active ingredients are approved for use on food crops.

Just 66 of these active ingredients are PFAS. 

According to U.S. Geological Survey, less than 1% of all the pesticides, by volume, used in the state of Vermont are pesticides that include PFAS as an ingredient.

The Hidden PFAS around us

Another concerning characteristic of these chemicals is that most PFAS pesticides ultimately break down into other PFAS like trifluoroacetic acid, or TFA. 

TFA can persist in the environment for hundreds of years and levels are increasing in soil, water, plants, plant based foods, and human bodies.

It’s not just the PFAS pesticides that can last for years and harm health – they are also precursors to other chemicals that will outlast us by centuries.

Conclusion

In summary, we are all exposed to PFAS. Many of us have levels of PFAS in our blood that pose serious health risks. 

Our food is a significant source of our exposure to PFAS. 

The food we eat is contaminated through: PFAS used in food packaging, PFAS in sewage sludge used as fertilizer, contaminated irrigation water, and pesticides either made with PFAS or stored in containers lined with PFAS. 

Most pesticides are made without PFAS, and new, better-studied pesticides are routinely approved for use by the EPA.

Less than 1% of the pesticides, by volume, used in Vermont are pesticides made with PFAS. 

Thank you for allowing me to testify today about PFAS pesticides.

I am happy to answer any questions.

Areas of Focus Toxic Chemicals Pesticides PFAS Chemicals Authors Varun Subramaniam, M.S. April 9, 2026

Statement on FDA’s delay of GRAS amendment proposal Iris Myers July 9, 2026

WASHINGTON – The Food and Drug Administration’s plan to amend the “generally recognized as safe,” or GRAS, regulatory loophole for food chemicals is slipping to December.

The agency originally planned to propose the amendment in October 2025. In December, it sent a draft rule to the White House Office of Management and Budget for pre-publication review, where it’s still pending. The administration then last week released its updated regulatory plan with timelines for upcoming agency rules, including the GRAS delay.

GRAS is a loophole that for years has allowed companies to add new, potentially harmful chemicals and other substances to snacks, drinks and more without undergoing the FDA’s safety review. 

When Congress created the GRAS loophole, in 1958, the exemption was intended to apply largely to ingredients widely recognized as safe, such as salt, water, yeast and vinegar.

But in the intervening years, GRAS has expanded to apply to much more. Since 2000, nearly 99% of food chemicals were introduced into the market as a result of  the GRAS loophole, according to a 2025 analysis from the Environmental Working Group. This allows scores of food chemicals to be approved for use with little government oversight.

The threat of preemption

A draft House bill would, if enacted, further hobble the already broken food safety review process. 

The bill is known as the FDA Review and Evaluation for Safe, Healthy and Affordable Foods, or FRESH and Affordable Foods Act. It would gut rules on the information companies must provide the FDA when submitting a notice that a food chemical is GRAS.

The following is a statement from Melanie Benesh, EWG vice president for government affairs: 

The federal government’s decision to push back its timeline for proposing changes to the broken GRAS system is yet another reminder that consumers cannot afford to wait for Washington to act.

For years, the FDA has failed to adequately oversee food chemicals, leaving states to fill the void by passing commonsense protections against harmful food chemicals linked to serious health risks. 

A delay in this long-promised rulemaking only reinforces why states must continue leading the way.

Congress should not respond by tying states’ hands. 

Lawmakers should reject misguided preemption proposals like the FRESH Act, which would strip states of their ability to protect families while weakening, not strengthening, federal oversight of food chemicals.

The federal government is taking longer to close the GRAS loophole. But the last thing Congress should do is block the states that are already taking action. Americans deserve stronger protections from harmful food chemicals, not more delays and fewer safeguards.

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The Environmental Working Group (EWG) is a nonprofit, non-partisan organization that empowers people to live healthier lives in a healthier environment. Through research, advocacy and unique education tools, EWG drives consumer choice and civic action.

Areas of Focus Food & Water Food Ultra-Processed Foods Toxic Chemicals Food Chemicals Press Contact Iris Myers iris@ewg.org (202) 939-9126 July 9, 2026

‘City slicker’ payments swell to $2.6B with Trump’s Big Beautiful Bill and farm bailouts Anthony Lacey July 8, 2026

More than 92,000 “city slickers” living in some of the biggest metropolitan areas in the U.S. took in over $2.6 billion in farm subsidies between 2020 and 2025, even though many of these people don’t live or work on farms, a new EWG analysis finds.

The soaring payouts went to 13,000 more city slickers compared to last year’s analysis, that looked at payments through 2024, EWG found. At the same time, farm bankruptcies have recently reached new heights.

EWG analyzed Department of Agriculture data and found that between 2020 and 2025, $2.6 billion in farm subsidies went to 92,766 residents of Chicago, Los Angeles, Miami, New York and 197 other major metro areas – with many never setting foot on farmland.

These payments averaged more than $28,000 per person between 2020 and 2025, or just over $4,700 each per year, EWG’s analysis found.

Even more taxpayer funds are going to city recipients this year after Republicans in Congress pushed through President Donald Trump’s One Big Beautiful Bill Act. The law enlarged loopholes that make it easier to qualify for the payouts and get more money.

It hiked payment limits from $125,000 to $155,000 per person, letting every member of some farms collect up to $155,000 a year each, even if they don’t live or work on a farm, as long as it is organized as a pass-through entity, such as a joint venture, S corporation or limited liability corporation.

EWG compiled a list of the 200 biggest metro areas, along with the number of urban recipients and the total farm subsidies they received between 2020 and 2025, including many new recipients in those areas possibly benefiting from the expanded loopholes:

200 largest metro areas with city slicker subsidy recipients

Image Record subsidy amounts

The U.S. is reaching record levels of agricultural industry bailouts, exceeding $25 billion since early 2025, with even more taxpayer-funded handouts still being requested. And these latest bailouts follow payouts from multiple disaster programs in the first and second Trump administrations.

The subsidy increases were paid for with cuts to Medicaid totaling nearly $1 trillion and $187 billion in cuts to hunger assistance programs. These reductions have led to hospital closings and the loss of hunger assistance for over 4 million Americans, including more than 800,000 children. 

As more and more funding is made available for farm subsidies, many recipients benefit from rules that allow people not involved in day-to-day life on the farm to collect payments.

Farm subsidy recipients must be “actively engaged” in farming. 

But it’s very easy to qualify as “actively engaged,” even for someone who never lives or works on a farm. The farm bill’s loopholes allow urban residents to get farm subsidies, even if they do not live or work on a farm. The Government Accountability Office in 2018 found that roughly one-fourth of farm subsidy recipients do not contribute any personal labor to farms.

Another GAO report, issued last month, examined improper payments made to the agriculture industry. It found that a tariff relief program from Trump’s first term had an improper payment rate of 19.3%. A USDA disaster program made improper payments at a rate of 45.2%.

The White House recently requested $11 billion to once again bail out the agricultural industry over the rising costs of fertilizer and fuel from Trump’s war with Iran. This would drive up total farm safety net spending to over $55 billion in 2026 alone.

The proposed “Farm Bill 2.0” making its way through the Senate this month will do nothing to fix these problems. Instead it will maintain the status quo and send billions of dollars in subsidies to city slickers who have nothing to do with farming.

Locating city slickers

For the analysis, EWG identified city slickers living in ZIP codes in the 200 most populous metro areas. Using existing datasets, EWG identified city slicker subsidy recipients as those living in areas with a population density greater than 3,000 people per square mile within census-designated metro areas. 

To rule out non-urban areas, the methodology looked at places the USDA doesn’t consider rural as well as ZIP codes that are outside a distance to a city center dictated by the city’s population size. The methodology also looked at other metrics to determine an area's rural status.

This analysis updates and builds on previous EWG estimates of city slickers, which included only recipients who lived within city limits. The updated methodology seeks to capture urban sprawl, which has changed how certain areas are defined, and to foster a better understanding of how many subsidy recipients live in urban areas.

Areas of Focus Farm Subsidies Over 13,000 more urban-area residents took in farm subsidies in 2025 than in 2024 Authors Jared Hayes July 9, 2026

EPA quietly unleashes three toxic ‘forever chemical’ pesticides onto America’s food supply Monica Amarelo July 2, 2026

WASHINGTON – Under the radar, the Environmental Protection Agency has approved three new PFAS “forever chemical” pesticides for use on crops, including one EPA scientists flagged as having “suggestive evidence of carcinogenic potential.”

There was no warning to the farmworkers who will handle these chemicals or the families who will eat the food they’re sprayed on. The EPA published the fast-tracked approvals in the Federal Register in recent days. The hazardous new herbicides – trifludimoxazin, diflufenican and epyrifenacil – can now be sprayed directly on major food crops, including wheat and citrus.

 “The EPA’s hands-off approach to pesticide mixtures is leaving families exposed to a cocktail of forever chemicals on their food,” said Varun Subramaniam, a science analyst at the Environmental Working Group.

“We know ultra-short-chain PFAS like TFA [trifluoroacetic acid] are accumulating in the environment and pose potential reproductive risks, yet regulators assess these hazards one by one and without considering the full range of potential health harms.

“The science shows combined chemical exposure can amplify health harms, but the EPA is consistently failing to enforce the extra safety protections legally required to safeguard children during pregnancy and early life,” he added.  

The Trump administration is greenlighting forever chemical pesticides at an alarming, unprecedented rate. In less than two years, the EPA has authorized five PFAS pesticides – including cyclobutrifluram and isocycloseram – effectively quintupling the pace of the previous administration, which approved just one over four years.

This isn’t just a policy shift; it’s a direct threat to the food supply.

Approved despite the EPA’s own warning signs

Despite the EPA’s internal data linking these chemicals to animal tumors and persistent water contamination, it quietly posted the approvals without informing the press or the public.

“Allowing an avalanche of new PFAS pesticides onto our fields will never make America healthy again,” said Jared Hayes, senior policy analyst at EWG. 

“Contaminating our agricultural fields with persistent forever chemicals does nothing to help the farmers who work tirelessly to feed us. By prioritizing corporate chemical approvals over public health, the EPA is actively undermining both our long-term food security and the very farming communities we rely on,” said Hayes.

Trifludimoxazin is cleared for everyday staples like oats, wheat and fruit. That’s despite EPA data showing the chemical breaks down into 12 persistent PFAS variants and shows “suggestive evidence of carcinogenic potential.”

Not content with three new approvals, the EPA wrapped up its overnight blitz by expanding uses for the notorious water-pollutant bifenthrin: a PFAS pesticide already classified as a “possible human carcinogen” by the agency.

In March 2026, EWG found residue of the PFAS pesticide fludioxonil was in 14% of all produce samples and in nearly 90% of peaches and plums, with fluopyram and bifenthrin also ranking among the top 10 most detected chemicals.

Peer-reviewed studies link pesticide exposure to hormone disruption and nervous system harm, potentially undermining the cardiovascular and fertility benefits of a fresh produce diet.

Even with the use of PFAS pesticides on crops, EWG stresses that consumers should eat plenty of fruits and vegetables. Despite the mounting risk from exposure to these chemicals, the answer isn’t fearing produce – it’s fixing a regulatory system that fails to protect people.

“A diet rich in fruits and vegetables is essential,” said Subramaniam. “Families should enjoy the significant health benefits of consuming produce while making informed choices to reduce pesticide exposure, particularly for children, without sacrificing nutrition."

This week the EPA also proposed adding six new PFAS, including TFA and other compounds that form from PFAS pesticide use, to the sixth Unregulated Contaminant Monitoring Rule. PFAS pesticides are likely a major source of this contamination but the required nationwide testing would not begin until 2028.

What are ‘forever chemicals’?

PFAS are a group of thousands of human-made chemicals used in a wide range of consumer, industrial and electronic products, in addition to pesticides.  

As these chemicals partially break down over time, they can form other harmful compounds, including trifluoroacetic acid, or TFA, which is increasingly being detected in the environment, wildlife and people. One study estimates PFAS pesticide use in California could generate between 185,000 and 616,000 pounds of TFA each year. 

Emerging research links TFA to reproductive harm and immune suppression, raising growing concerns about its spread and potential health risks.

Regulators are largely flying blind  

An EPA analysis noted that 36 PFAS pesticides – 25 of which are registered in California – lack updated developmental and reproductive toxicity tests. Immunotoxicity studies are routinely waived in pesticide applications, despite growing evidence that PFAS chemicals are particularly harmful to the immune system.

“By the time these PFAS residues reach our plates, they have become part of a toxic cocktail that may suppress the immune system and harm reproductive health,” said Subramaniam “That raises serious concerns about the long-term health risks of using these chemicals on food crops.”

“We’re spraying millions of pounds of chemicals on food without understanding their full health impacts or considering what little we do already know. It’s unconscionable,” he added.

A peer-reviewed study published in the journal Environmental Health Perspectives found PFAS pesticides are increasingly contaminating waterways, posing potential threats to health.

Pesticides containing PFAS are used throughout the country on staple foods such as corn, wheat, kale, spinach, apples and strawberries. They are widely used for residential use in flea treatments for pets and in insect-killing sprays.

Health risks of PFAS exposure

Very low doses of PFAS have been linked to suppression of the immune system. Studies show exposure to PFAS can also increase the risk of cancer, harm fetal development and reduce vaccine effectiveness. 

Some of the most sensitive harms from PFAS are to the human immune system, such as weakened antibody response to vaccinations and increased risk of infectious disease. But since 2012 it has been common for the EPA to waive immunotoxicity study requirements for pesticides, which limits the agency’s ability to detect such harms. 

This means the EPA is missing key, not fringe, health effects when considering the harms of PFAS pesticide exposure in regulatory decisions.

States leading on regulation

Some states are stepping up where the federal government is failing to act. 

California – the nation’s “salad bowl” because of the huge amount of produce it grows that feeds Americans – is weighing a bill targeting the rampant use of the PFAS pesticides. Assembly Bill 1603 by Assemblymember Nick Schultz (D-Burbank) would monitor and report the use of PFAS pesticides in the state. EWG is co-sponsoring the bill, along with other health advocacy groups. 

The legislative push follows a damning EWG analysis of state data exposing the sheer scale of the contamination crisis across California:

• Contaminated produce: PFAS pesticide residues were detected on 37% of California-grown non-organic produce samples, including a staggering nine out of 10 samples of peaches, nectarines and plums.
• Polluted waterways: Mirroring the food data, PFAS pesticides were found in up to 50% of California surface water samples and roughly half of all tested sediment samples.
• Massive environmental footprint: Between 2018 and 2023 alone, mega-farms and local growers applied 15 million pounds of PFAS pesticides across all 58 California counties.

What needs to happen now

EWG is calling on the EPA to reverse course immediately and stop approving new PFAS pesticides while the science of cumulative, low-dose exposure remains poorly understood. 

Specifically, regulators must:

• Halt new PFAS pesticide approvals until cumulative and immunotoxic risks are fully assessed.
• Mandate immunotoxicity testing for every PFAS active and inert ingredient, no more waivers.
• Treat persistence itself as grounds for regulation, regardless of a chemical’s individual toxicity profile.
• Assess cumulative impacts from the fluorinated byproducts shared across multiple pesticide products.
• Expand environmental and biomonitoring programs to cover all PFAS pesticides, not just a fraction.
• Require full disclosure of “inert” ingredients on all pesticide labels.
• End the practice of fluorinating plastic pesticide containers, a known contamination source.

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The Environmental Working Group is a nonprofit, non-partisan organization that empowers people to live healthier lives in a healthier environment. Through research, advocacy and unique education tools, EWG drives consumer choice and civic action.

Areas of Focus Food & Water Farming & Agriculture Pesticides PFAS Chemicals California Agency’s decision brings total of PFAS pesticides to five greenlit in under two years    Press Contact Monica Amarelo monica@ewg.org (202) 939-9140 July 2, 2026

EWG evaluation of food chemicals: Propyl gallate rcoleman June 29, 2026 Dayna de Montagnac, MPH Sydney Evans, MPH Tasha Stoiber, Ph.D. Jump to: What is propyl gallate and why is it added to food? Food propyl gallate is found in What is the regulatory status of propyl gallate? Is food containing propyl gallate always classified as ultra-processed? Is propyl gallate allowed in organic foods? What are the potential health harms associated with propyl gallate? Uncertainties and the need for more research Additional details Other product use categories References June 30, 2026 EWG’s recommendation

Propyl gallate is an ingredient of concern, and EWG recommends limiting consumption of food containing this ingredient. 

Propyl gallate’s toxicity is linked to its breakdown in the body, which produces reactive oxygen species, or ROS. It also causes oxidative stress, a process connected to numerous chronic diseases. When broken down into pyrogallol, a highly reactive oxidizing agent, it can lead to pro-oxidant systemic toxicity, glutathione depletion, and potentially cause damage to the liver (hepatotoxicity) and kidneys (nephrotoxicity). 

Studies in animals and cells have also shown propyl gallate is associated with reproductive health harms, including inducing male infertility and testicular toxicity in mice, anti-estrogenic effects affecting female reproductive health, and impaired early embryonic development.

Science analysis

What is propyl gallate and why is it added to food?

Propyl gallate is a preservative that prevents oxidation, extending the shelf life of fats and oils in processed foods.

Food propyl gallate is found in

Propyl gallate is typically added to meat products, frozen food and candy.

Propyl gallate is used in 275 of the 172,081 food items added to EWG’s Food Scores between 2023 and 2025.

Top 15 food and drink categories organized by supermarket shelf

Image

Source: EWG’s Food Scores. Label created between 1/1/23 and 10/22/25.

What is the regulatory status of propyl gallate?

The Food and Drug Administration classified propyl gallate as “generally recognized as safe,” or GRAS, and approved it for use in food in 1948. Propyl gallate is commonly added to food as an antioxidant, but the total antioxidant content cannot exceed 0.02% of the total fat or oil content of the food. 

Like other synthetic antioxidants, propyl gallate is also approved in the U.S. as a food contact substance – materials and articles intended to come into contact with food. 

In the European Union, an acceptable daily intake, or ADI, of 0.5 mg/kg was established for three gallates – propyl, octyl and dodecyl – in 1987 by the Scientific Committee on Food. WHO/JECFA established a higher ADI of 1.4 mg/kg of body weight in 1996 for propyl gallate. 

In 2014, a European Food Safety Authority, or EFSA, panel derived an ADI of 0.5 mg/kg for propyl gallate only. The panel concluded there was no longer a basis for the group ADI.

Is food containing propyl gallate always classified as ultra-processed?

Yes, propyl gallate and other synthetic preservatives are common ingredients in ultra-processed food, or UPF. As an industrially synthesized ingredient, the NOVA framework classifies it as a UPF ingredient (Monteiro et al., 2019). 

Because it serves as a flavoring agent and adjuvant, the presence of propyl gallate is enough to qualify a food or beverage as ultra-processed, according to a recent California law defining UPF (Real Food, Healthy Kids Act, 2025). 

Is propyl gallate allowed in organic foods?

No. Under Department of Agriculture organic standards, synthetic substances are prohibited in certified organic foods. 

What are the potential health harms associated with propyl gallate?

Like other synthetic antioxidants, the toxicity of propyl gallate is related to its breakdown in the body and production of ROS, which creates oxidative stress. Oxidative stress damages cells and causes programmed cell death (apoptosis), a process associated with numerous chronic diseases. 

Propyl gallate rapidly metabolizes into gallic acid in the body. At higher levels, a portion can then be decarboxylated by gut bacteria into pyrogallol, a highly reactive oxidizing agent. The formation of pyrogallol may contribute to pro-oxidant toxicity, resulting in glutathione depletion, which leads to hepatotoxicity and nephrotoxicity (Park, 2025). 

While gallic acid is less reactive at low dietary exposure levels, it may become pro-oxidative and hepatotoxic at the elevated concentrations typically found in concentrated herbal supplements (Galati et al., 2006). 

The accumulation of these reactive metabolites and generation of ROS have been associated with cellular DNA breaks (Javaheri-Ghezeldizaj et al., 2023).

Evidence of cell damage induced by propyl gallate extends across multiple studies. One found that propyl gallate induces male infertility and testicular toxicity in mice by disrupting calcium homeostasis, causing mitochondrial and endoplasmic reticulum stress, and suppressing cell viability and steroidogenesis in Leydig and Sertoli cells (Ham et al., 2019). 

Another study found propyl gallate interferes with the production of estrogen (Amadasi et al., 2009), which can affect female reproductive health. In another rodent study, propyl gallate exposure impaired early embryonic development by inducing oxidative stress, DNA damage and autophagy while also disrupting mitochondrial and lysosomal function and altering epigenetic modifications (Yang et al., 2024).

Studies investigating the anti-cancer properties of propyl gallate provide further evidence of its pro-oxidant activity. In lung cancer cell models, propyl gallate increased ROS and depleted glutathione, leading to mitochondrial dysfunction and apoptosis (Park, 2021). 

These mechanisms overlap with the compound’s toxic effects in non-cancer cells, suggesting that oxidative stress may play a central role in both its therapeutic and adverse biological effects. 

A 1982 carcinogenesis bioassay by the National Toxicology Program concluded that propyl gallate was not carcinogenic in rats or mice. However, the study noted evidence of tumorigenesis in low-dose male rats specifically. They exhibited more, mostly benign pancreatic, adrenal and preputial gland tumors that did not occur in the high-dose treatment groups. 

Rare tumors were noted in two of the low-dose female rats (National Toxicology Program, 1982).

In refined exposure assessments conducted by the EFSA in 2014, propyl gallate was estimated to exceed the ADI for the elderly and adults. Higher estimates in adults and the elderly compared to other groups were due to its presence in food supplements (EFSA ANS Panel, 2014). 

The assessment also found exposure to propyl gallate from food contact materials alone likely exceeded the ADI for most children (EFSA ANS Panel, 2014). But because their exposure models were intentionally conservative, the EFSA concluded current real world use of propyl gallate was not a safety concern. 

Uncertainties and the need for more research

The presence of propyl gallate in food contact materials and cosmetics, as well as octyl gallate and dodecyl gallate, should be considered when determining total exposure risk. Concurrent exposure to propyl gallate and related synthetic antioxidants may contribute to overall exposure and should be considered when evaluating potential health risks (Wang et al., 2021). 

To refine future exposure assessments, the EFSA panel noted that additional data are needed on the use of propyl gallate in breakfast cereal, soup, processed nuts and food supplements. 

More research is needed to understand both the cytotoxic and cytoprotective properties of propyl gallate in humans. 

Additional details 

Research shows propyl gallate’s anti-cancer activity appears to involve pro-oxidant and apoptotic pathways that overlap with mechanisms implicated in its toxicity. In cancer cell models, propyl gallate induces severe oxidative stress, cell cycle arrest and programmed cell death (Wei et al., 2019; Park, 2020).

Other product use categories

Propyl gallate is also added to cosmetic products as a preservative. It  scores 4 in EWG’s Skin Deep® database and is not allowed in EWG Verified® products.

References

Global health and regulatory agencies

• EFSA Panel on Food Additives and Nutrient Sources added to Food (ANS). (2014). Scientific opinion on the re‐evaluation of propyl gallate (E 310) as a food additive. EFSA Journal, 12(4), Article 3642. https://doi.org/10.2903/j.efsa.2014.3642

Comprehensive reviews and frameworks

• Monteiro, C.A., Cannon, G., Levy, R.B., Moubarac, J., Louzada, M.L., Rauber, F., Khandpur, N., Cediel, G., Neri, D., Martinez-Steele, E., Baraldi, L.G., & Jaime, P.C. (2019). Ultra-processed foods: what they are and how to identify them. Public Health Nutrition, 22(5), 936–941. https://doi.org/10.1017/s1368980018003762.
• National Toxicology Program. (1982). Carcinogenesis bioassay of propyl gallate (CAS No. 121-79-9) in F344/N rats and B6C3F1 mice (Feed study) (Technical Report Series No. 240; NIH Publication No. 83-1796). Department of Health and Human Services, National Institutes of Health. https://ntp.niehs.nih.gov/sites/default/files/ntp/htdocs/lt_rpts/tr240.pdf
• Park, W.H. (2021). Enhanced cell death effects of MAP kinase inhibitors in propyl gallate–treated lung cancer cells are related to increased ROS levels and GSH depletion. Toxicology in Vitro, 75, Article 105176. https://doi.org/10.1016/j.tiv.2021.105176 
• Wang, W., Xiong, P., Zhang, H., Zhu, Q., Liao, C., & Jiang, G. (2021). Analysis, occurrence, toxicity and environmental health risks of synthetic phenolic antioxidants: A review. Environmental Research, 201, 111531. https://doi.org/10.1016/j.envres.2021.111531 
• Monteiro, C.A., Cannon, G., Levy, R.B., Moubarac, J., Louzada, M.L., Rauber, F., Khandpur, N., Cediel, G., Neri, D., Martinez-Steele, E., Baraldi, L.G., & Jaime, P.C. (2019). Ultra-processed foods: what they are and how to identify them. Public Health Nutrition, 22(5), 936–941. https://doi.org/10.1017/s1368980018003762.

Legislation

• Real Food, Healthy Kids Act, A.B. 1264, Chapter 467, Cal. Stat. (2025).https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB1264 
• 21 CFR 184.1660 – Propyl gallate. (n.d.). https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-184/subpart-B/section-184.1660

Specific health impact studies

• Park, W.H. (2025). A comprehensive review of pyrogallol: from fundamental chemistry to advanced applications and toxicological insights. Biotechnology and Bioengineering, 123(3), 527–543. https://doi.org/10.1002/bit.70115 
• Galati, G., Lin, A., Sultan, A.M., & O'Brien, P.J. (2006). Cellular and in vivo hepatotoxicity caused by green tea phenolic acids and catechins. Free Radical Biology and Medicine, 40(4), 570–580. https://doi.org/10.1016/j.freeradbiomed.2005.09.014 
• Javaheri-Ghezeldizaj, F., Mirza Alizadeh, A., Dehghan, P., & Ezzati Nazhad Dolatabadi, J. (2023). Pharmacokinetic and toxicological overview of propyl gallate food additive. Food Chemistry, 423, Article 135219. https://doi.org/10.1016/j.foodchem.2022.135219
• Ham, J., Lim, W., Park, S., Bae, H., You, S., & Song, G. (2019). Synthetic phenolic antioxidant propyl gallate induces male infertility through disruption of calcium homeostasis and mitochondrial function. Environmental Pollution, 248, 845–856. https://doi.org/10.1016/j.envpol.2019.02.087 
• Amadasi, A., Mozzarelli, A., Meda, C., Adriana, M., & Cozzini, P. (2009). Identification of xenoestrogens in food additives by an integrated in silico and in vitro approach. Chemical Research in Toxicology, 22(1), 52–63. https://doi.org/10.1021/tx800048m 
• Yang, S., Yang, F., Zou, Y., Wang, Y., Ding, Z., Zhang, L., Zhou, X., Liu, M., Duan, Z., & Huo, L. (2024). Propyl gallate exposure affects the mouse 2-cell stage embryonic development through inducing oxidative stress and autophagy. Food and Chemical Toxicology, 185, 114488. https://doi.org/10.1016/j.fct.2024.114488
• Wei, P., Huang, C., & Chang, Y. (2019). Propyl gallate inhibits hepatocellular carcinoma cell growth through the induction of ROS and the activation of autophagy. PLoS ONE, 14(1), e0210513. https://doi.org/10.1371/journal.pone.0210513 
• Park, W. (2020). Propyl gallate reduces the growth of lung cancer cells through caspase‑dependent apoptosis and G1 phase arrest of the cell cycle. Oncology Reports, 44(6), 2783–2791. https://doi.org/10.3892/or.2020.7815 

Dirty Dozen™ food chemicals: Propyl gallate Iris Myers June 29, 2026 EWG’s recommendation

Avoid or limit foods containing propyl gallate.

Propyl gallate is a preservative that has been linked to oxidative stress, which is when reactive molecules build up and damage cells. Laboratory studies have connected propyl gallate and its breakdown products to liver and kidney damage, as well as potential reproductive harm. 

What is propyl gallate?

Propyl gallate is a preservative that prevents oxidation, extending the shelf life of fats and oils in packaged foods. It’s also used as a preservative in cosmetic products.

Which foods contain propyl gallate?

Propyl gallate is most commonly found in processed meat like hot dogs and sausages. It’s also a common ingredient in candy and a range of frozen products, including pizza and other frozen meals.

Look for propyl gallate in product ingredient lists, usually below or next to the Nutrition Facts panel, on the back of the package. Propyl gallate may also be added to food packaging, which companies are not required to disclose.

How is propyl gallate regulated?

The Food and Drug Administration is responsible for overseeing food additives and other ingredients. Propyl gallate was approved for use in food in 1948 and is classified as generally recognized as safe in limited amounts.

The European Union’s European Food Safety Authority reevaluated propyl gallate in 2014 and derived an acceptable daily intake level of 0.5 mg/kg for this single additive. This assessment found that adults and the elderly may have higher exposure due in part to propyl gallate’s presence in food supplements. 

Exposure from food packaging alone was also estimated to exceed the most children’s allowable intake level. But the European authority concluded that because its exposure models were intentionally conservative, the current real world use of propyl gallate was not a safety concern.

Propyl gallate is prohibited in certified organic foods under Department of Agriculture organic standards, which bar synthetic substances.

What does the science say about propyl gallate?

When propyl gallate breaks down in the body at higher levels, it can produce reactive byproducts that cause oxidative stress, damaging cells and DNA. Research shows that one key breakdown product, pyrogallol, is a highly reactive compound that can deplete the body’s natural antioxidant defenses and damage the liver and kidneys.

Propyl gallate has also been linked to reproductive harm in animal and cell studies. One study found it induces male infertility and testicular toxicity in mice at high exposure levels. Another found it to be anti-estrogenic, which can affect female reproductive health. 

A third study showed that higher levels of propyl gallate exposure impaired early embryonic development in mice by triggering oxidative stress and DNA damage. 

A 1982 study by the National Toxicology Program found propyl gallate was not carcinogenic in rats or mice but noted an increased incidence of mostly benign tumors in low-dose male rats. No major regulatory agencies classify propyl gallate as causing cancer. 

Find out more

Learn more about recommendations relating to propyl gallate – and the full EWG Dirty Dozen list of food chemicals – on EWG’s research page.

EWG’s Food Scores provides ratings for more than 150,000 foods and drinks based on nutrition, ingredients and processing concerns, and flags unhealthy ultra-processed foods to help you identify alternatives.

EWG’s Skin Deep® cosmetic database helps to identify harmful chemicals in personal care and beauty products. EWG Verified® products meet the strictest criteria for transparency and health.

And the Healthy Living™ app lets you take these tools with you on the go.

Areas of Focus Food Ultra-Processed Foods Food Chemicals Authors Sarah Reinhardt, MPH, RDN June 30, 2026

EWG testimony before the California Senate Health Committee on AB 2244, to create a ‘non-ultraprocessed’ food label Iris Myers June 25, 2026

Thank you for the opportunity to testify. My name is Scott Faber, and I am testifying on behalf of the Environmental Working Group, a national environmental health organization and a sponsor of AB 2244. I am also an adjunct professor of law at Georgetown University Law Center, where I teach food and farm law. Prior to joining EWG, I was the vice president for federal affairs for the Consumers Brand Association. 

The overwhelming scientific evidence shows that ultraprocessed foods have been linked to serious health harms ranging from diabetes to dementia. 

Processed foods are part of a healthy diet. But ultraprocessed foods, or UPFs, are different from processed foods because they have been engineered in ways that make our food not just delicious but literally irresistible.

Consumers are increasingly trying to avoid UPFs, and there are many processed foods in the grocery store that are not ultra-processed and are lower in saturated fat, sodium, and added sugars. However, consumers are struggling to distinguish between UPFs and these healthier processed foods. 

The voluntary, non-UPF seal authorized by AB 2244 will help consumers by applying the definition you created in AB 1264 to the marketplace, and by asking grocers to make these non-UPF options easier to find. Minimally processed foods like olive oil, nuts and pasteurized milk are all non-UPF options eligible for the non-UPF seal.  

California’s definition of UPF closely tracks the consensus definition published by UPF experts in May, which recommends that UPFs be defined as food containing a “cosmetic” additive, such as flavors, synthetic colors, stabilizers, thickeners, and emulsifying agents. 

Let me reiterate: The non-UPF seal authorized by AB 2244 is completely voluntary. 

By contrast, many other countries, including Mexico and Canada, have required a mandatory warning on the front of unhealthy processed foods. 

Let’s help consumers build healthier diets. I urge you to support AB 2244 to help consumers find better options for their families.

Thank you for the opportunity to testify. 

Areas of Focus Food & Water Food Ultra-Processed Foods Regional Issues California Press Contact Iris Myers iris@ewg.org (202) 939-9126 June 25, 2026