Understanding the UK's new PFAS Plan

At the end of 2025, the UK government released its updated Environmental Improvement Plan, which included a pledge to publish a ‘PFAS action plan’ [1]. Sooner than many anticipated, the Department for Environment, Food & Rural Affairs (Defra) published the UK's first PFAS Plan on 3 February 2026 [2]. But what is PFAS, what does this new PFAS plan set out, and what does this mean for industry?

What is PFAS?

Per- and polyfluoroalkyl substances (PFAS) are synthetic chemicals commonly added to everyday products because of their resistant properties. For example, PFAS can be found in fire-fighting foams, textiles, medical devices, food packaging, and cookware. However, the same qualities that make PFAS so useful also mean they do not break down easily, causing them to accumulate in the environment. Often called ‘forever chemicals’ there is increasing concern about the effects these substances have on health and our ecosystems.

What is the UK’s PFAS Plan?

As the government seeks to transition UK industry away from forever chemicals towards safer alternatives, the PFAS Plan aims to provide a foundation for decisive but fair action to manage the risks associated with PFAS emissions. It acknowledges that there are no quick fixes but proposes regulation based on shared evidence and learning from other countries to address the many challenges associated with this transition in a pragmatic and proportionate manner. This includes considering critical PFAS uses for which there are currently no practical non-PFAS alternatives, and avoiding the new environmental problems associated with such alternatives.

The PFAS Plan presents “initial indicative actions” that government and devolved administrations will adopt, grouped into three core themes.

Theme one: Understanding PFAS

This theme focusses on what we know about PFAS and priority areas where more understanding is needed. Proposed actions include:

• Expansion of environmental monitoring programmes for PFAS and making pertinent data available to relevant regulatory bodies and the public
• An assessment of PFAS impacts on UK estuarine / coastal environments
• Asking businesses to report on their use of a wider range of PFAS
• Evaluation of the ecological impacts of PFAS in the UK
• Expanding research to understand the fate and risks posed by emission of ultra-short (e.g. trifluoroacetic acid - TFA) and ultra-large PFAS (e.g. fluoropolymers).

Theme two: Tackling PFAS pathways

This theme focusses on preventing PFAS entering and circulating in the UK environment and is the primary thrust of the Plan with a total of 23 proposed actions. These include:

• Controlling PFAS-based firefighting foams via the UK registration, evaluation, authorisation and restriction of chemicals (REACH) regime, which regulates chemicals that are manufactured in or imported into Great Britain.
• Considering control of other PFAS (or groups of PFAS) using REACH particularly in light of the UK’s obligation to implement changes to the Stockholm Convention and to align with controls implemented within the EU.
• Continue to control the use and emission of fluorinated gases (F gases).
• Environmental permits will be used more actively to identify and control PFAS pollution. For example, new guidance will be issued requiring operators to be open with regulators about how they use PFAS and what they release into the environment. It will also set best practice standards for controlling and treating PFAS and require existing permits to be reviewed and updated, where needed.
• There are aspirations to address the much-publicised lack of scientifically robust and defensible environmental thresholds for emissions to air, land, and water for relevant PFAS in the UK, and to better understand and control PFAS within UK wastes and waste management.

Theme three: Reducing ongoing exposures to PFAS

This theme focusses on understanding and reducing people’s current exposure to PFAS. The recommended actions include:

• A rapid review of the possible health effects of PFAS and support for the Committee on Toxicology’s work to develop health-based and environmental guideline values that can inform risk assessments and regulatory decisions.
• Local authorities will be given technical guidance on how to regulate land affected by PFAS contamination under both the planning system and contaminated land regulations (Part 2A), which would facilitate the identification and clean-up of PFAS-impacted sites.
• Tackling PFAS in our food by developing suitable testing methods and monitoring PFAS in ‘food contact materials’ (including paper and plastic packaging) and in the foods themselves, including in bottled water.  Understanding what contaminants are present in sewage sludge, how their impacts can be reduced, and the spreading of sewage sludge on agricultural land should be regulated.
• Tackling PFAS in drinking water by consulting on new statutory limits for PFAS in drinking water in England.
• Tackling PFAS in consumer articles (such as textiles, food packaging and cosmetics) by considering restriction of such uses via UK REACH.

What are the implications of the PFAS Plan for the UK?

While the Plan proposes  49 actions for UK government, it is also very clear that all UK industries need to share the burden, stating that "Government regulatory action to address the sources of harmful PFAS should also be matched by action from industry, including reducing the demand for PFAS in products and processes by proactively switching to safer alternatives" and that "As a precautionary action to reduce potential risks from PFAS, industry and retailers should assess whether the use of PFAS is essential to achieve the desired function and should consider alternatives where possible".

The Plan has been criticised by some stakeholders for a lack of concrete measures and many of the proposed actions have already been implemented in Australia via the PFAS National Environmental Management Plan (NEMP) [4] and increasingly by federal and state authorities in the US and EU. However, the Plan does represent concrete proposals for the UK to go beyond its current evidence gathering exercise towards actual regulatory action.

It’s clear that the Environment Agency (EA) intend to use the environment permitting regime as a key regulatory lever to address industry emissions of PFAS, and SLR are aware of clients who are already seeing this new and more proactive focus.

The Plan’s tacit acknowledgement of the hazards and harms posed by PFAS and the need for tighter regulation may also embolden and facilitate legal groups looking to bring civil and class action cases against suspected PFAS polluters – a process that is already been well established in the US courts and one that UK companies should probably now take more seriously than ever.

Another conclusion is that the wholesale transition away from PFAS is still some time away, so PFAS will continue to be present within the environment for years to come, requiring long-term plans to monitor and manage legacy contamination and corporate liabilities. However, considering the ubiquity of these ‘everywhere chemicals’, poses an important question to the environment sector; not whether PFAS may be an issue at any given site, but whether there are any sites where PFAS liabilities can be discounted completely?

Closing thoughts

The PFAS Plan represents a welcome step forward in the UK’s evolving approach to ‘forever chemicals’. While some criticise the Plan for its lack of tangible measures, it nonetheless provides a clear direction of travel: increased scrutiny, greater transparency, and a tightening of controls across the entire PFAS lifecycle. The transition away from PFAS will be complex, and the key challenge for both regulators and industry will be determining how to prioritise action in a landscape where PFAS are embedded deeply into modern supply chains. Ultimately, the PFAS Plan reflects a balancing act: driving meaningful progress toward safer, more sustainable chemical use, while recognising the essential functions some PFAS still provide.

How SLR can help

SLR has global experience in managing the transition away from PFAS, monitoring and mitigating current emissions to land, air, water, and wastes and assessing and remediating legacy emissions. SLR will continue to support our clients, share our global knowledge and experience with regulators, and strive to create a more sustainable future for all.