Emerging Contaminants: When compliance is no longer enough

EMERGING CONTAMINANTS: When compliance is no longer enough

The gap between what science can detect and what legislation regulates is opening up a new area of risk for the food industry. Staying ahead will require better data, new technologies and R&D&I projects capable of bringing together those who understand the problem and those who can solve it.

Enrique M. García García · Evolution Europe

Estimated reading time: 12 min

There is an uncomfortable paradox in food safety. Laboratories can detect more and more substances at ever lower concentrations, while regulation needs time to assess the evidence, characterise the risk and translate it into an enforceable limit. Science moves at breakneck speed; the law, by its very nature, proceeds more cautiously.

This difference in pace creates a grey area. The fact that a substance does not yet have a specific legal threshold does not mean it is harmless; equally, detecting it does not automatically make a food unsafe. Between those two extremes lies a complex space in which decisions must be made with incomplete information. A significant part of a food company’s reputation is now at stake in that space.

01 Regulation inevitably comes later

The expression “regulatory vacuum” is often used, but it needs qualification. Regulation is not entirely absent. Some groups of compounds already have parametric values, limits or monitoring requirements; others are under assessment; and some still lack harmonised thresholds across all matrices and uses. What exists is less a complete vacuum than a gap between the ability to detect and the ability to regulate.

The term emerging contaminants covers very different realities: residues of human and veterinary medicines, hormones and other endocrine disruptors, PFAS, microplastics and nanoplastics, pesticides and transformation products, bisphenols, phthalates, flame retardants, UV filters, detergents, personal-care compounds, certain nanomaterials and indicators associated with antimicrobial resistance. They do not all present the same hazard, follow the same route into food or require the same controls.

That distinction matters. In food safety, detection does not automatically demonstrate meaningful exposure, and evidence of exposure alone is not enough to establish harm. Concentration, toxicity, frequency of consumption, persistence, bioaccumulation potential and the matrix in which a compound appears can completely change the assessment. The absence of a simple answer, however, is no reason to look the other way.

02 From water to the plant: the route that is often overlooked

At first sight, emerging contaminants in water may seem like an environmental issue far removed from a food-processing plant. They are not. Water is involved in irrigation, livestock drinking water, aquaculture, washing raw materials, cleaning equipment, producing ice or steam, cooling and, in many products, the formulation itself.

Pharmaceutical residues are a useful example. Active ingredients and metabolites can reach water after human or animal consumption and excretion, through hospital or industrial discharges, livestock activities or improper disposal of medicines. From there, they may follow different pathways. Some degrade, some are retained and others persist long enough to come into contact with crops, fish, shellfish, livestock or raw materials.

None of this means that detecting a pharmaceutical in a body of water implies that it will later be found in the finished food. The pathway depends on concentration, the treatment applied, uptake by organisms, transformation during processing and the consumer’s actual exposure. It does, however, make it essential to understand where water comes from and how it is used, particularly when reclaimed water is involved or when the supply chain depends on areas under agricultural, livestock, urban or industrial pressure.

For a food company, the risk may lie outside its own walls: in water used by a supplier, animal feed, a livestock farm, an ingredient, packaging or an ancillary process. Following internal procedures does not always protect a business from something that was never included in its risk map.

03 Risks a standard audit may miss

The regulatory gap does not create a single problem. It creates several, and not all of them are strictly related to health. Some materialise long before any formal ban is introduced.

The consequences may range from an urgent supplier review to a precautionary withdrawal, the loss of a strategic customer or a direct blow to the brand. Reputation takes years to build and can deteriorate within hours.

04  End-product controls have not failed – but they come too late

Conventional control plans remain essential. Testing the product, verifying specifications and comparing results against regulatory requirements are still the foundations of the system. The problem begins when this approach becomes the only line of defence.

If a substance is not included in routine testing, no one looks for it. And when controls are concentrated at the end of the process, the company discovers the problem after raw materials have been consumed, production capacity used, product quarantined and costs incurred that may never be recovered. Prevention requires a wider field of view: regulatory signals, supplier data, geographical origin, climate conditions, logistics changes, new materials and both targeted and non-targeted analytical techniques.

The answer is not to test indiscriminately for thousands of compounds. That would be economically unviable and, in many cases, generate more noise than insight. The aim is to prioritise: which substances are relevant to each product, which routes of entry are plausible, which suppliers or processes concentrate exposure and where in the chain action will have the greatest value.

05  Three technological fronts for staying ahead

The answer will not come from a miracle technology. The strongest projects combine early detection, treatment and predictive capability. These are three distinct but connected layers: detect earlier, reduce or remove where possible, and learn from data to decide where to look.

A. Biosensors and early-warning systems

A biosensor combines a biological recognition element with a transducer that converts its interaction with a contaminant into a measurable signal. Recognition may rely on an enzyme, antibody, aptamer, genetic sequence, protein or living cell. The resulting signal may be electrical, optical, acoustic or thermal.

Their value to the food industry is clear: rapid checks on water, raw materials, surfaces or processes, with the possibility of moving part of the analysis closer to the sampling point. In many cases, they are particularly effective as screening or early-warning tools. They should not, however, be presented as universal substitutes for laboratory analysis. Confirmatory testing will still be required when a substance must be identified and quantified accurately or when a decision has to be defended before a customer or authority.

Their real-world usefulness will depend on sensitivity, selectivity, the stability of the biological element and interference from the sample matrix. A sensor that performs well in ultrapure water may behave very differently in a beverage, a plant extract or a sample containing fat, proteins and salts.

Classification by biological recognition element

Classification by signal transduction method

B. Advanced degradation and filtration

When a contaminant is already present in process water, a liquid raw material or an ingredient, conventional treatments may prove insufficient. The response depends on the compound’s structure and concentration, particle size, charge, persistence and the matrix in which it is found.

That is why the most promising developments combine several barriers. Advanced oxidation processes – ozone, photocatalysis, UV/peroxide systems and certain electrochemical solutions – generate reactive species capable of transforming specific organic contaminants. Ultrafiltration, nanofiltration and reverse-osmosis membranes, meanwhile, separate substances according to their size and physicochemical properties. Targeted adsorbents, activated carbon and functional materials can complete the treatment train.

With microplastics and nanoplastics, separation and destruction must be clearly distinguished. A membrane may retain a particle, but it will generally transfer it to a concentrate stream, sludge or surface that must then be managed. Degradation requires an additional stage and still presents challenges in energy consumption, reaction speed, by-products and scalability.

Researchers are also investigating enzymes and microorganisms capable of transforming specific contaminants or polymers. Their potential is considerable because they may operate under less aggressive conditions, but industrial applications still need to demonstrate stability, performance and compatibility with real matrices. In food production, removal is not enough: it must be achieved without altering sensory, nutritional or functional properties and without generating transformation products that are more problematic than the original substance.

C. Artificial intelligence and digital twins

R&D&I is not only about hardware; it is also about software. Machine-learning models can combine analytical results, the origin of raw materials, supplier history, logistics routes, climate variables, processing conditions, packaging types, incidents and health or regulatory alerts.

Even geopolitics can provide an indirect signal. A crisis does not predict a contaminant by itself, but it may force a change of country, supplier, route or raw material and thereby introduce a risk that has never appeared in the company’s historical data.

The objective is not for an algorithm to declare a batch contaminated without testing it. The value lies in estimating where risk is more likely, prioritising sampling and focusing laboratory resources where they can prevent a late decision. Quality teams can then move beyond reacting to incidents and begin using information to anticipate them.

Digital twins take that logic a step further. A virtual representation of a raw material, production line, product or supply chain can be updated with real data and used to simulate scenarios: a change of supplier, a climate anomaly, a packaging modification or a process variation. They are powerful tools, but only when fed with reliable data and validated against real results. A digital twin does not fix poor traceability; it makes it visible.

06  The decisive step: innovating through collaboration

Few of these challenges can be solved by a single organisation. The food company understands the plant, the matrix, the operational problem and the conditions a solution must withstand. A biotechnology company may contribute the recognition element; an equipment manufacturer, process integration; a laboratory or technology centre, validation; and a digital company, data processing and predictive models.

Collaborative R&D&I brings those capabilities together, shares technological risk and enables the solution to be validated under real operating conditions. It also supports something that is often underestimated: designing the technology from the outset with industrialisation, cost, maintenance and future acceptance by customers and authorities in mind.

A consortium, however, is not built by collecting logos. It needs a shared problem, complementary roles, clear responsibilities, properly structured intellectual property and an exploitation route that makes sense for every partner. When that architecture fails, the project becomes little more than a list of tasks. When it works, it can create a technology that none of the participants could have developed alone.

A project ecosystem built around a real purpose

07  From a technical need to a fundable project

A technical need does not automatically become an R&D&I project. The challenge must be formulated, the limitations of existing market solutions demonstrated, the novelty established, measurable milestones defined, work packages structured and a budget allocated in line with each partner’s contribution. Then comes the second decision: how to finance it.

Potential routes include national calls for collaborative business R&D, regional programmes, instruments for innovative SMEs and European programmes focused on food systems, the environment, water, digitalisation and the bioeconomy. The right fit will depend on technological maturity, consortium size, partner locations, budget, duration and proximity to market.

Public funding does not have to be the only layer. Unfunded costs, or activities that continue beyond the grant period, can be assessed for R&D&I tax incentives and, where relevant, other tools such as the monetisation of tax credits, social-security rebates for research staff or tax-based financing mechanisms. Any combination must be reviewed for compatibility, maximum aid intensity, incentive effect and cost traceability. These instruments cannot simply be stacked without limits.

Evolution Europe’s role

At Evolution Europe, we help turn a specific food-safety concern into an innovation strategy. The work begins before a funding call opens: understanding the problem, assessing its technological content, identifying missing capabilities and finding partners with a genuine role in the project.

From there, we structure the consortium, organise the technical and economic objectives, identify the most suitable funding route and support proposal preparation. Once the project is under way, that support continues through management, monitoring and reporting, together with an assessment of tax incentives that may complement the funding secured.

The objective is not to submit an isolated funding application. It is to build an ecosystem capable of developing a useful solution, taking it into the plant and sustaining it financially throughout its journey.

08 Turning the gap into competitive advantage

Compliance will remain the starting point. But in an environment where analytical capabilities and commercial expectations are moving so quickly, compliance alone may not be enough to protect the supply chain or the trust built around a brand.

Companies that combine monitoring, technology and collaboration will be able to detect earlier, respond more effectively and help shape the solutions the market will later adopt. Those that wait for each risk to become a regulatory obligation will have less room to manoeuvre and, in all likelihood, face a higher cost.

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Technical background references