(3 min read)
The UK Government’s first national PFAS Action Plan establishes a foundational framework to understand and manage risks from persistent ‘forever chemicals’. Positioned as a stepping stone toward a longer term regulatory vision, the Plan introduces no new PFAS standards but commits to developing scientifically robust environmental thresholds. Its three pillars focus on identifying PFAS sources through improved monitoring, assessing and tackling environmental pathways via potential UK REACH restrictions, enhanced waste and emissions management, and addressing legacy contamination, and finally reducing exposure by reviewing PFAS risks in consumer products, food contact materials and drinking water. Emphasising proportionate, evidence based intervention, the Plan expects industry to play a proactive role. While preliminary in nature, it signals future, more stringent regulatory measures as the evidence base grows.
The UK Government has introduced its first national PFAS Action Plan, establishing a framework to better understand and manage the risks associated with per and poly fluoroalkyl substances (PFAS) —commonly known as ‘forever chemicals’, against a backdrop of growing scientific concern that these persistent chemicals pose long term risks to both public health and ecosystems.
The concluding remarks summarise accurately what the Plan is - a stepping stone to meet the government’s longer-term vision. There are no new standards for certain PFAS or concrete regulatory reforms, but there are commitments to develop “scientifically robust and defensible environmental thresholds and standards for emissions to air, land and water” for PFAS of concern. Planned measures include launching a consultation on a statutory drinking water limit, expanding environmental testing, and developing guidance for regulators and industries on managing emissions and legacy contamination. This approach aims to ensure that regulatory action is targeted, enforceable and responsive to emerging evidence.
The PFAS Action Plan sets out coordinated measures across government, regulators and industry, structured around three core pillars.
Pillar 1: Identify the sources of PFAS
To improve understanding of where PFAS originate and the scale of their impact, the Plan proposes several actions:
- Enhanced monitoring: Continued sampling and reporting of PFAS in freshwater, alongside improved monitoring in soils.
- Public transparency: Exploration of a dedicated interactive PFAS website by end of 2027.
- Environmental assessment: A comprehensive, multi year assessment of PFAS contamination in estuarine and coastal environments across England.
- Regulatory tracking: Consideration of adding additional PFAS substances to the UK Pollutant Release and Transfer Register (PRTR).
Pillar 2: Assess and tackle how PFAS spread through the environment
The government identifies three key intervention areas covering the full lifecycle of PFAS:
(a) Address ongoing PFAS production and emissions
Measures include:
- Potential UK REACH restrictions and additions to the candidate list of substances of very high concern.
- Implementing obligations under the Persistent Organic Pollutants Regulation.
- Continued (and potentially reformed) F gas legislation.
- Cross sector guidance for regulators, operators and industry on reducing PFAS emissions and improving handling, monitoring and disposal under environmental permits.
- Developing scientifically robust thresholds and standards for PFAS emissions to air, land and water.
- Requiring the use of Best Available Techniques (BAT) (as part of UK BAT Tranche 2 [1]) to minimise PFAS emissions and impacts.
- Supporting innovation to promote safer PFAS alternatives across UK industry.
(b) Address PFAS already circulating in society and the environment
Actions include:
- Preventing PFAS in landfill and waste streams from entering the environment.
- Improving understanding of PFAS waste management and disposal risks through research and industry engagement.
(c) Control emissions from legacy sources
Focus areas include:
- Managing contamination from historic uses such as fire fighting foams.
- Developing technical guidance for regulators and industry on land affected by legacy PFAS contamination across planning, voluntary remediation, Environmental Permitting Regulations (EPR) and Part 2A frameworks.
- Ensuring a consistent and practical approach to legacy PFAS management.
Pillar 3: Reduce and manage ongoing PFAS exposure
The Plan aims to minimise exposure for people, animals and the environment through:
- Public awareness initiatives to improve understanding of PFAS risks.
- Completion of an independent review of PFAS chemicals and human health risks.
- Considering new restrictions or regulatory measures on PFAS in specific consumer product groups (including under UK REACH).
- Testing PFAS levels in food contact materials and improving data collection.
- Consulting on introducing a statutory drinking water limit for PFAS.
- Developing toxicological thresholds, such as predicted no effect concentrations (PNECs), to support new environmental quality standards.
- Consulting on reforms to the regulation of sewage sludge use in agriculture, including potential inclusion under the Environmental Permitting Regime.
A core message of the Plan is the government’s emphasis on proportionate, risk based intervention as there are no quick fixes, but also an expectation that industry will be proactive in improving the understanding of PFAS risks and taking steps to manage those risks. Throughout the Plan there is an emphasis on the need for further evidence to justify and support regulatory actions that may follow and that underscores the government’s commitment to a proportionate transition toward safer alternatives. Whilst the Plan is only a foundation, as evidence builds, the trajectory is clear – we are very likely to see harder edged regulatory actions down the line which will address how PFAS is used, when such substances can be emitted and how and who needs to clean it up.
Footnote
[1] Tranche 2 covers the final sectors required to conclude the Industrial Emissions Directive revisions, which includes chemicals.
Next steps
The PFAS Action Plan was a commitment set out in the government’s Environment Improvement Plan (EIP), so the review and reporting of the plan will become part of the government’s statutory reporting cycle for the EIP.
For further information or support on managing PFAS in your business or supply chain, do contact Victoria Barnes or your usual Environment & Sustainability Team contact.
