United Kingdom Launches Its First National Strategy to Tackle PFAS
In Short
The Background: On February 3, 2026, the UK Department for Environment, Food & Rural Affairs, or Defra, published the first comprehensive, UK‑wide policy paper ("PFAS Plan") on per‑ and polyfluoroalkyl substances ("PFAS"), which are sometimes called "forever chemicals." It sets a coordinated national strategy and establishes a long-term, science-based and proportionate framework to address PFAS and minimise their purported impacts on public health and the environment.
The Result: The PFAS Plan is structured around three core pillars: Section 1 (Understanding PFAS sources), which focuses on improving understanding of where PFAS are used, how they enter the environment and the purported risks they pose; Section 2 (Tackling PFAS pathways), which aims to reduce usage and prevent releases through chemical regulation and support for purported safer alternatives; and Section 3 (Reducing ongoing exposure to PFAS), which concentrates on managing legacy contamination and current exposures to protect the environment, people and animals.
Looking Ahead: The PFAS Plan sets out indicative next steps for each pillar, including detailed descriptions, territorial scope (UK‑wide or devolved), anticipated delivery timelines and responsible bodies. It marks a shift toward a more proactive UK approach that brings together regulatory and non-regulatory measures, with expanded monitoring, targeted restrictions, tighter permitting and waste controls and potential statutory limits for drinking water.
PFAS Definition and Regulatory Intent
Although there is no single universally agreed definition of PFAS, the PFAS Plan aligns the UK with emerging international practice by adopting the Organisation for Economic Cooperation and Development ("OECD")'s definition. This definition, which covers substances with at least one fully fluorinated methyl or methylene carbon atom (without any hydrogen, chlorine, bromine or iodine atom attached to it), goes beyond the narrower working definition used by the UK Health and Safety Executive ("HSE") in its Regulatory Management Option Analysis published in March 2023. This framing signals the UK's intention to actively regulate a larger set of potential PFAS, bringing more substances into scope for monitoring, permitting and future restrictions.
Planned Regulatory Actions: UK REACH, POPs and F‑gases
The PFAS Plan places UK REACH at the heart of UK action, supported by the existing persistent organic pollutants ("POPs") regime and F-gas controls. The policy direction is toward tighter restrictions and a managed shift away from PFAS in manufacturing and consumer products, with industry expected to transition to purported safer alternatives.
In particular, the proposed UK REACH restriction on PFAS in firefighting foams is currently being considered, with the public consultation open until February 18, 2026. HSE aims to issue its opinion in 2026, with a government decision expected in 2027. Further UK REACH measures are in development, including possible additions of more PFAS substances to the "Substances of Very High Concern" candidate list to drive substitution and prepare the ground for future restrictions.
The UK also plans to reform UK REACH by December 2028 to deliver faster and more efficient chemical protections, while enabling closer alignment with key trading partners, particularly the EU. As part of this reform, the government is assessing potential restrictions on PFAS sub‑groups, potentially drawing on approaches already adopted or proposed within the EU. Any resulting UK measures could have significant implications across multiple sectors, including chemicals, manufacturing, textiles, electronics and a wide range of consumer products that rely on PFAS for water, stain or heat resistance.
The question of whether and to what extent the UK may align with the EU's expansive PFAS restriction proposal is uncertain. However, as the proposal progresses through the European Chemicals Agency's Risk Assessment and Socio‑Economic Analysis Committees, the UK is expected to closely consider these developments as it shapes its own regulatory approach.
PFAS Regulation Across Environment, Waste and Drinking Water
The UK continues to expand its work on PFAS within waste streams, with a growing focus on landfill leachate, sewage sludge and treatment residues. A consultation is planned for 2026 on potential reforms to the regulatory framework governing the use of sewage sludge in agriculture, including whether these activities should be brought within the environmental permitting regime. Enforcement will also remain targeted at PFAS substances which are already listed as POPs.
The Environment Agency is expected to apply a national prioritisation framework, supported by its PFAS risk‑screening tools, to identify and sequence action on contaminated sites. Further measures anticipated in 2026 include a consultation on statutory PFAS limits for drinking water, an expansion of testing for food and food‑contact materials and the launch of a dedicated government PFAS information webpage to enhance public transparency and awareness.
Three Key Takeaways
- Expect broader PFAS regulatory exposure. The UK is adopting the OECD PFAS definition and expanding UK REACH controls, bringing more substances into scope for monitoring and future restrictions. Businesses using PFAS should map all direct, indirect and legacy PFAS uses to understand which operations or products may fall into scope and begin planning for potential substitution, reformulation and market impacts.
- Expect stricter scrutiny across waste, emissions and permitting. The PFAS Plan signals tighter environmental controls, including monitoring waste streams (sludge, leachate) and possible expansion of environmental permitting requirements. Businesses with waste intensive processes should prepare for new reporting duties, enhanced treatment requirements and scrutiny of legacy contamination risks.
- Prepare for increased litigation and consumer claims related to PFAS. Growing public awareness and expanded government testing of PFAS in water, food and consumer products are likely to drive heightened scrutiny and potential collective claims from consumers or downstream customers alleging harm or exposure. Businesses should proactively assess PFAS‑related risks in their products and supply chains, strengthen documentation and traceability and ensure they can demonstrate due diligence to mitigate potential liability.
