New era for chemical risk: UK unveils first-ever PFAS plan

May 2026  |  FEATURE | RISK MANAGEMENT

Financier Worldwide Magazine

May 2026 Issue

The threat posed by per- and polyfluoroalkyl substances (PFAS) – commonly referred to as ‘forever chemicals’ – represents one of the most pressing environmental and public health challenges of the modern era.

ClientEarth defines PFAS as a group of more than 14,000 synthetic chemicals that are resistant to heat, water, oil and grease. Their molecules contain a chain of linked carbon and fluorine atoms, which together form one of the strongest chemical bonds in organic chemistry.

Because of their durability and their non-stick, water resistant and grease repellent properties, PFAS are present in many everyday products, ranging from frying pans and baking equipment to outdoor clothing, shoes, textiles, cosmetics and food packaging.

“PFAS are a very large, chemically diverse, group of synthetic substances,” affirms Francesca Puttock, an associate at Squire Patton Boggs (UK) LLP. “They share the trait of having a strong carbon-fluorine bond, which gives them desirable properties in industrial and consumer applications.”

PFAS are widely used on an industrial scale across sectors including aerospace, automotive manufacturing, construction, electronics, biotechnology, energy production, pharmaceuticals and textile production. They also feature in firefighting foams used to combat high-intensity fires.

A kaleidoscope of risks

While PFAS support economic growth and innovation, growing scientific evidence has linked their widespread use to potential harm to ecosystems and human health.

“The damage caused by PFAS far exceed the value they generate,” asserts Megan Kirton, senior project officer at Fidra. “Annual health-related costs in the European Economic Area alone are estimated to be in excess of €52bn, while remediation costs across Europe are estimated to exceed €100bn per year.”

PFAS damage ecosystems by persisting in the environment, steadily building up in soil and water and accumulating in the bodies of plants and animals. Their concentrations intensify further up the food chain, leading to documented harm in wildlife, including reproductive and developmental problems, reduced sperm quality and weakened immune systems.

PFAS contamination also degrades soil and water quality, disrupting insects, plants and microorganisms. In agricultural settings, PFAS can enter fields through biosolids and PFAS pesticides, allowing crops to absorb them and livestock to become contaminated, thereby extending their impact across both natural ecosystems and food production systems.

PFAS pollution is increasingly understood as widespread, persistent and costly to remedy, with the chemicals able to travel far from their original sources through rainfall, groundwater and even atmospheric movement. This mobility means that areas with little industrial activity can become contaminated over time, placing particular pressure on communities that depend on local water supplies or small-scale agriculture.

As monitoring expands, scientists expect to find PFAS in locations that have not been tested before, revealing the full scale of their environmental reach. Human health studies link PFAS exposure to reproductive and developmental issues, heightened cancer risks, weakened immune responses, hormonal disruption and increased cholesterol and obesity, underscoring their broad and lasting impact.

Despite the levels of risk, the regulation of PFAS varies around the world, with some countries banning certain types of PFAS altogether, while others have established limits on their use or set maximum acceptable concentrations in drinking water.

In the UK, PFAS pollution is extensive, with over 10,000 ‘high risk’ sites identified, including rivers such as the Mersey in Liverpool and the Kelvin in Glasgow, as well as groundwater sources in Bentham, North Yorkshire.

Without urgent source control, contends Ms Kirton, the UK faces decades of environmental degradation and escalating public health and remediation costs. “A commitment to transition to safer alternatives, many of which are already available, is therefore essential to protect public health and the environment for future generations,” she adds.

UK proposals

Efforts by the UK government to regulate the use of PFAS were virtually non-existent until the February 2026 announcement of a dedicated PFAS Plan – one of the most highly anticipated measures announced in the Department of Environment, Food and Rural Affairs’ (DEFRA’s) revised Environmental Improvement Plan 2025.

In the first-ever plan to protect public health and the environment from risks posed by PFAS, the UK government (led by DEFRA) sets out the coordinated action that will be undertaken by governments, businesses and regulators to understand where these chemicals are coming from, how they spread, and how to reduce public and environmental exposure.

“In a post-Brexit world, the UK no longer has recourse to the work on PFAS driven forward by the European Commission and European Chemicals Agency,” says Ms Puttock. “Therefore, it has to develop its own plans. Given the discussions around the ‘universal’ PFAS restriction contemplated in the European Union (EU), and the anticipated impact it will have on businesses trading with and in the EU, attention has naturally turned to what the UK government would do on this issue.”

Introducing the plan, Emma Hardy, parliamentary under-secretary of state at DEFRA, described it as a “cross-government, science-led plan to understand impacts of PFAS on public health and the environment, with coordinated actions to minimise risks”.

The PFAS Plan outlines a series of interventions. These include developing new guidance for regulators and industry on tackling legacy PFAS contamination on land to ensure a consistent approach, and consulting on whether to establish a statutory limit for PFAS in England’s public drinking water regulations.

The government will test food packaging, such as microwave popcorn bags and pizza boxes, to identify PFAS and inform future regulation. It will also launch a public awareness website, introduce guidance to limit industrial emissions of PFAS, improve soil monitoring through the British Geological Survey and conduct new sampling in England. Furthermore, it will complete work on potential restrictions for PFAS in firefighting foams.

In addition to these measures, the plan signals a broader shift in how chemical risks will be governed in the UK. DEFRA has indicated that future policy decisions will draw more heavily on long term environmental datasets and independent scientific reviews, reflecting a desire to build a more adaptive regulatory framework. The plan also acknowledges the need for stronger cross-border collaboration, particularly with trading partners whose own PFAS controls may influence UK supply chains.

Early discussions within industry have shown a willingness to explore material substitution, although businesses have emphasised the importance of clear timelines and proportionate requirements. As PFAS have become emblematic of wider concerns about chemical persistence, the PFAS Plan is expected to shape how the UK considers other substances of emerging concern, laying the groundwork for more comprehensive chemicals regulation in the years ahead.

Essentially, by combining transparency, scientific evidence and partnership, the UK government is aiming to minimise the risks posed by PFAS – which are highly persistent and can remain in the environment for centuries – and protect both people and the environment for generations to come.

“DEFRA will generally want to show that it has a considered and grounded plan for coordinated action on PFAS, while preserving some flexibility, and to this end the PFAS Plan is stated to be DEFRA’s ‘first step to meet its long-term vision’,” observes Ms Puttock. “In some ways, the plan is more a statement on the government’s intended approach than a set of detailed arrangements.”

Implications for regulators, businesses and governments

Although welcomed as a necessary step forward, the plan also raises questions about how and when its measures will be implemented, how regulators, businesses and government departments will coordinate their efforts, and whether the proposed actions are ambitious enough.

Ms Puttock notes that regulators will need to determine the content of new guidance and integrate it into enforcement activity, which may require additional training or resources within bodies such as the Environment Agency and local authorities.

For businesses, the plan provides direction but limited certainty. Without detailed timelines or requirements, much remains aspirational. However, it offers an indication of future regulatory trends, particularly regarding statutory limits in drinking water, potential amendments to UK REACH, and the need for businesses with PFAS in their supply chains to seek alternatives, especially where restrictions abroad already affect operations.

For government, publication of the plan invites heightened scrutiny. DEFRA is likely to face significant pressure to progress the outlined measures at pace.

“The PFAS Plan contains some positive steps, including improvements to monitoring, research, promotion of alternatives and consideration for a statutory drinking water standard,” says Ms Kirton. “However, a crucial omission is the lack of any new restrictions on PFAS, without which pollution cannot be addressed at source.

“With many PFAS-free alternatives already available, and growing evidence highlighting the risks associated with PFAS, it is concerning that preventative action has not been prioritised,” she continues. “Because these chemicals persist in the environment, delaying action will only intensify the consequences we ultimately face.”

Turning off the tap

The UK government’s PFAS Plan is rooted in scientific evidence and aims to reduce public health and environmental risks while supporting innovation and economic development. However, some stakeholders, including The Wildlife and Countryside Link, argue that the absence of binding phase-out commitments and alignment with the EU undermines its effectiveness.

“The plan is not intended of itself to be the solution to the known issues around PFAS, but rather to serve as a ‘framework’ or ‘platform’,” points out Ms Puttock. “However, it is not surprising to see campaign groups call out for more action given the growing sensitivity around this issue and the fact that it will be years before we are able to judge the effectiveness of the measures in the plan.”

Many argue that the government must commit to more immediate and decisive action. “While the plan represents a step in the right direction, its impact will remain limited without firm commitments to address PFAS pollution at its source,” opines Ms Kirton. “Every day of inaction locks in additional contamination that will persist and continue to spread for generations.

“Adopting a proactive approach, such as the EU’s proposal to phase out all non-essential uses of PFAS, would tackle the problem at its root rather than managing its consequences. Ultimately, turning off the tap is the most urgent and effective step to prevent further PFAS pollution in the UK,” she adds.

As the UK embarks on this new chapter of chemical management, the PFAS Plan marks a shift in both ambition and public expectation. It signals a growing recognition that chemical stewardship is a societal commitment to safeguarding shared resources.

The coming years will test how effectively that commitment can be translated into practice, particularly as scientific understanding evolves and new forms of contamination emerge. What is clear is that PFAS have pushed environmental governance into a new era, one in which transparency, accountability and long-term thinking carry greater weight than ever before.

Yet the plan’s ultimate legacy will depend on the willingness of government, industry and civil society to remain engaged long after the initial announcements fade. The transition to safer materials and cleaner production systems requires persistence, innovation and sustained political will.

If the UK can maintain that momentum, the PFAS Plan may become both a policy milestone and a catalyst for a broader and more resilient approach to chemical risk in the decades ahead.

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Fraser Tennant