Are we being persistent enough about PFAS? UK Government publishes long awaited plan

Are we being persistent enough about PFAS? UK Government publishes long awaited PFAS plan

We have all read about the exposure of PFAS, that this substance is being found in the world’s most isolated locations as well as the most polluted town in the UK, Thornton Cleveleys near Blackpool. This town has long been suffering from the exposure to PFAS and the effect on the local community is devastating. This could be the tip of the iceberg – one town next to one manufacturing plant - it is therefore welcome news the Government is seeking to tackle this issue along with the EU.

In the wake of the proposed EU ban on Per- and poly-fluoroalkyl substances (“PFAS”), there has been considerable interest around how the UK Government might respond. The “PFAS Plan: Building a safer future together” published on 3 February 2026 outlines the Government’s three pillared approach to tackling these ‘forever chemicals’. Is this a sufficiently robust response to what the Government deems “one of the most pressing chemical challenges of our time”?

The Government’s PFAS Philosophy

Before the plans three pillars are examined, it is important to consider: what is the Government’s end goal?

The Plan outlines the Government’s vision to “reduce and minimise the harmful effects of PFAS while transitioning to safer alternative substances where appropriate”. This will involve acting “decisively but proportionality to manage risks” with an approach “rooted in science and collaboration”.

From these statements, a more cautious mindset has been adopted than we are seeing in the EU, grounded in proportionality and a cost-benefit philosophy.

Pillar 1: Understanding the PFAS Sources:

Given the multitude and complexity of PFAS sources, the Government emphasises the need to accumulate a strong evidence base from which future decisions can be relied upon. The Plan cites ongoing monitoring as to the persistence of PFAS in surface water and wildlife and that going forward there is scope to extend this to air, soils and the marine environment as well as a focus on PFAS sub-groups.

A real focus will be on understanding the exposure pathways to people and the associated health impacts this may bring. The Plan describes health impacts as an area of uncertainty and that there is evidence to suggest its impacts are felt differently across society.

Key action points proposed include:

· By the end of 2026, the Environment Agency will make its PFAS GIS prioritisation map accessible to all public sector bodies in England, with a potential interactive website by 2027, while Scotland considers adopting a similar approach.

· Work to improve PFAS soil monitoring through a British Geological Survey feasibility study and pilot sampling at a minimum of five sites.

· A comprehensive assessment of PFAS in England’s estuarine and coastal environments to be completed by February 2028, examining sediment, fish and benthic invertebrates.

· The Government will consider adding more PFAS substances to the UK Pollutant Release and Transfer Register (expected as part of Government’s response to the consultation on industrial emissions published August 2025)

Pillar 2: Tackling PFAS pathways

Here, the Plan addresses actions to tackle PFAS pathways including the production and emission of new PFAS and interventions to address PFAS already in circulation. This will be conducted on a cost-benefit basis managing the harmful impacts of some PFAS substances whilst not losing the benefits that cannot be viably replaced by non PFAS alternatives.

Key action points proposed include:

· Chemicals regulation: Completing the consideration of a UK REACH restriction on PFAS in firefighting foams and explore further UK REACH restrictions as part of wider reforms due by December 2028. Working towards adding more PFAS to the UK REACH candidate list of substances of very high concern, subject to consultation.

· Global collaboration: Supporting work to address PFAS as an Issue of Concern under both the Global Framework on Chemicals and the OECD. Consider requesting a global assessment report on PFAS through the new Intergovernmental Science‑Policy Panel on Chemicals, Waste and Pollution.

· Reducing emissions from industrial sites: Developing cross‑sector guidance and using this to evaluate and where necessary strengthen measures controlling PFAS, including through reviews of environmental permits. Developing scientifically robust environmental thresholds and standards for PFAS emissions and working to identifying Best Available Technique specifically in respect of this issue.

· Preventing emissions from landfill and waste: Researching and engaging with industry on emerging technologies and continuing to implement existing waste controls.

· Supporting innovation to find PFAS alternatives: Promoting forums through the Chemical’s Innovation Forum, adding PFAS as a focus area within existing platforms and supporting international work.

· Improving public awareness: Publication of a webpage on PFAS in 2026 and including PFAS in the new ‘Chemical risks to human health’ website.

· Harnessing public sector purchasing power: Consider options for introducing PFAS guidance as part of Government’s Buying Standards, review Department for Education Guidance on procurement of school uniforms and review inclusion of requirements in tendering processes for Ministry of Defence suppliers.

Pillar 3: Reducing ongoing exposure to PFAS

The purpose of this pillar is to reduce the public health and environmental risks from PFAS exposure and work towards regulations to achieve this. The Government also hopes to promote a joined-up approach in respect of regulations and approaches to reduce exposure to wildlife.

Key action points proposed include:

· Assessing risk to human health: This will be conducted through a review of evidence.

· Managing risks in food: Testing PFAS in food contact materials including developing tests that aren’t available. Using this data to support any future regulatory measures. Bottled water prioritised for focus within the next year

· Improving drinking water quality: Consulting on the introduction of a statutory limit for PFAS in England’s public supply regulations

· Improving quality of our waters: Developing toxicological thresholds for PFAS to support future regulation and environmental quality standards. Also, evaluating the feasibility of developing improved testing methods for persistent, mobile and toxic substances to support risk management.

· Reviewing risks of PFAS in sewage sludge: Continue work being undertaken as part of the Water Industry’s Chemicals Investigations Programme, consult on reforms in respect of sewage sludge use in agriculture and whether these should be part of the Environmental Permitting Regime, bringing stakeholders together to identify research priorities by Q2 2026.

· Addressing legacy PFAS pollution: Setting out a framework for prioritisation of risks, providing updated information to local authorities carrying out contaminated land responsibilities and developing technical guidance.

· Managing the risks of PFAS in consumer products: Considering consumer articles as part of any work to consider PFAS restrictions under REACH, work to consider potential restrictions on regulatory measures on PFAS use in specific consumer product groups.

What are the implications of the Plan going forward?

The next couple of years are clearly envisioned as an evidence gathering period. Whilst grounding our approach on scientific evidence is sensible, there is a real risk of stalling much needed action. Particularly if resourcing becomes an issue, as so often is the case. To mitigate this the Government should seek to strengthen existing data sharing with other countries to accelerate this process and not seek to reinvent the wheel.

Further, research should be meaningfully directed at establishing the appropriate environmental standards to underline all government and industry action on PFAS going forwards. The Plan will no doubt raise questions for those with related statutory responsibilities (such as Local Authorities in relation to contaminated land), questions that will need answering quickly.

A focal point of the plan is clearly reducing exposure to PFAS through drinking water, fuelled by concerns regarding human health impacts. The Plan signals an intention to introduce a statutory limit for PFAS in public supply regulations. This could mark one of the biggest tests for the new water regulator who will be responsible for overseeing this and monitoring the need for further action going forward (in addition to grappling with the many other responsibilities the new body will assume).

Lastly, in respect of public awareness, the Plan is light on detail. Ironically, this is the one area where the Plan does not commit to further research i.e. into what current levels of public awareness are and what can be done to ensure all strands of society are aware of risks which PFAS poses.

Conclusion

The Government’s Plan does well to capture the complexity of the challenge PFAS poses and sets out useful starting points in a comprehensive range of areas. However, there is cause for concern regarding the transition period between evidence gathering and action and how long this will last. The Plan identified the number one characteristic of PFAS as “persistent”. In the face of the challenge PFAS poses, this is a quality the Government will need to embody and encourage others to adopt.