To study the potential associations between fetal brain functions and the early essential polyunsaturated fatty acid (ePUFA) status, fetal learning and memory were assessed by repeated habituation rate measurements (HR) in fetuses of 30, 32, 34 or 36 weeks gestational age (GA). HR tests were repeated 10 min later. Both measurements were replicated in a second session at GA 38. Fetal short-term memory (STM) and long-term memory (LTM) were calculated from these habituation rates and related to concentrations of ePUFAs and their status markers, measured in umbilical artery wall phospholipids. The only relevant associations observed were positive trends (0.010<p<0.050) between STM measured before 38 weeks GA and concentrations of the ePUFA status markers Mead acid and Mead acid+dihomo-Mead acid, and between LTM and levels of Osbond acid, a marker of the n-3 LCPUFA status. Although these weak associations may imply some negative relationships between fetal brain functions and the early ePUFA status, we concluded that physiological differences in the availability of these fatty acids may probably not determine the differences in these primitive brain functions during the third trimester of fetal development.