As the current scrutiny on the risks and impacts of per- and polyfluoroalkyl substances (PFAS) on human health and the environment intensifies, the UK government has published a plan setting out its proposals to address such issues. What remains to be seen, however, is exactly how and when this policy response will translate into affirmative action (including stricter regulation and measures to tackle legacy PFAS in the environment), with much of the plan being predicated on the outcome of further research and consultation. In this article, we outline the key aspects of the plan and explore some of the potential implications for industry.
What are PFAS and what are the concerns?
PFAS are a very large group of around 14,000 synthetic chemicals used in many industries and products for their ability to repel water, oil and stains and resist heat. Indeed, as part of their work linked to the potential restriction of PFAS in the EU, the European Chemicals Industry produced a useful PFAS Use-mapping document, which identified that most (if not all) industrial sectors use PFAS, if not in their products, then in their equipment, machinery and production processes.
PFAS are often referred to as "forever chemicals" because they typically persist in the environment for a long time. This, coupled with their widespread use and the known toxicity of some PFAS, have raised concerns about potential health effects and environmental impacts, leading to calls for their restriction and the clean-up of legacy PFAS contamination.
UK PFAS Plan: a first step on the road?
On 3 February 2026, DEFRA published its PFAS Plan which sets out the UK framework for understanding and addressing risks from PFAS. The government’s vision is “to reduce and minimise the harmful effects of PFAS while transitioning to safer alternative substances”. The intention of the plan (as outlined in the government’s Environmental Improvement Plan in December 2025), is to draw together a number of initiatives already underway across a range of areas and to address both legacy PFAS issues and the ongoing use of PFAS into a more coherent cross-government plan, incorporating collaboration with industry and building public awareness of the risks.
The plan (which is divided into three sections each with a list of “indicative actions”) is described as a “stepping stone” to meet the longer-term vision.
Section 1: Understanding PFAS sources
The government aims to build a better understanding of where PFAS come from, how they behave, and what risks they pose to people and the environment. It contends that by improving monitoring, research and transparency across supply chains, it will generate the evidence needed to guide effective regulation and targeted interventions that reduce harm, while recognising where different PFAS have different uses, benefits and risks. Whilst additional data is of course welcome, PFAS are a very broad spectrum of chemicals and amassing such detailed data will take a considerable amount of time and resources. A recent comprehensive study of PFAS in English waterbodies[1] found widespread occurrence of PFAS at concentrations posing potential ecological risks and noted that both point and diffuse sources of PFAS contribute to PFAS load in waterbodies. As well as the complexity of sources, it also highlighted the complexity of assessing PFAS concentrations in waterbodies nationally, given the diversity of environmental conditions and limitations of sampling within a single time period. Therefore, gathering data will not be an easy task. What we do know is that these substances are very long-lived in the environment and can bio-accumulate. So, while production continues, the amount of PFAS in the environment is continuing to increase.
For this reason, some jurisdictions, including the EU, are looking at introducing broad PFAS bans (with transition periods) to prevent the issue worsening, alongside measures to manage PFAS already in the environment. The UK government appears to be suggesting that its approach is to wait for further scientific data before adopting a more targeted approach to regulation, likely addressing different PFAS groups (rather than either PFAS as a whole or individual PFAS).
One of the few concrete actions within this section of the plan (beyond further monitoring) is to publish the Environment Agency’s list of high risk PFAS sites by the end of 2026, with the launch of an interactive website by the end of 2027. Many readers will remember the concerns levied around public anxiety, land values and long-term “blight” that accompanied the proposal to publish lists of potentially contaminated sites when the contaminated land regime was introduced in 2000. If such publication is to happen, there will likely be calls for detailed contextual information to be provided to prevent these issues arising here, particularly given the widespread sources of PFAS, their ability to migrate and the current uncertainty as to background levels and acceptable limits. Landowners and developers will be monitoring these plans closely and with some concern.
Section 2: Tackling PFAS pathways
Section 2 focuses on identifying how PFAS enter and move through the environment, and suggests how a mixture of regulation, industry action and better-informed consumer choice might be used to reduce these pathways. It aims to tackle PFAS across their entire lifecycle—production, use, disposal and legacy contamination—while balancing the need to retain certain PFAS where they are essential and currently deemed irreplaceable. There is mention of the need to develop “sustainable substitutes” but nothing explicit regarding managing the risk of “regrettable substitutions” (where the substitute chemical has alternative unknown hazards associated with it). Ultimately, it states that the government seeks to cut emissions, shift industry towards safer alternatives, strengthen international cooperation, and improve public understanding and transparency around PFAS risks.
There are a large range of indicative actions listed in this section, but interestingly one is an aim to align UK REACH with its “closest trading partners, especially the EU” by December 2028. Given the UK government’s proposed approach, there is going to need to be a vast amount of research over the next couple of years to work towards that target and both funding and effective government support would be vital to achieve this. The PFAS plan does indicate areas of future PFAS restrictions by listing existing EU REACH restrictions, as well as suggesting that more PFAS would be added to the UK REACH candidate list of substances of very high concern “subject to consultation”. The development of cross-sector guidance is suggested as a means of achieving a reduction in PFAS emissions (and a possible review of existing environmental permits) alongside the development of standards for emissions to air, land and water. These are essential to allow the effective regulation and management of PFAS-affected sites. The government will also consider options for including PFAS requirements in public procurement to seek to drive the market for alternatives.
Section 3: Reducing ongoing exposure to PFAS
The final section of the plan focuses on reducing ongoing exposure to PFAS by managing major routes of exposure—drinking water, food, consumer products, the environment and occupational settings. Much of this links to areas where work is already happening, such as the current consultation on the regulation of sewage sludge, and the proposed consultation on the implementation of statutory drinking water limits for PFAS (which will likely reflect the current non-statutory guidelines).
However, there is much that is absent. There is a lack of concrete regulatory plans (either in terms of scope or timings) and many suggested actions depend on future evidence and reviews. In addition, the plan acknowledges the need to improve co-ordination between multiple public and private bodies but does not detail how this will be achieved nor how different regulators will co-ordinate their efforts. There is also little detail on when or how the use of PFAS in consumer products might be regulated. In terms of legacy PFAS contamination, there is mention of prioritising sites and developing guidance on dealing with clean-up, but no mention of further funding or resources. Given the estimated clean-up costs for the UK of £31bn-£121bn this is a fundamental omission.
Does it amount to a “plan” for PFAS?
There has been much critical commentary around the plan from all sides, given the lack of concrete actions it sets out. Interestingly, the current Environmental Audit Committee inquiry, which is looking at whether the current regulatory regime for PFAS is fit for purpose, is still on-going. Emma Hardy M.P (Parliamentary Under-Secretary for DEFRA) was subjected to a grilling by the committee about the PFAS Plan shortly after its release, who were sceptical as to whether this plan even amounted to a “plan” and not simply a “plan to make a plan”. The committee pointed to the cost burdens relating to legacy clean-up of PFAS and on-going health impacts and questioned whether the PFAS plan has proper regard to the “polluter pays” principle and the “precautionary principle” as required by the Environment Act 2021. They also questioned whether the UK’s decision not to follow the EU’s approach of an overall ban with derogations would be of benefit to either the environment and human health or to the chemicals industry. Concerns were also raised about how long the UK’s alternative route to regulation would take, highlighting the issues that such divergence would cause both in terms of EU imports and exports and the complexity for business in Northern Ireland under the Windsor Framework. In response, Emma Hardy M.P. characterised the plan as a “first step” rather than a settled approach.
Indeed, perhaps the plan should be viewed less a “plan” and more as a “finger in the air” which gives a sense of which way the wind is blowing. Whilst the attempt to bring together many disparate areas of policy and regulation relevant to PFAS is welcome, the UK government needs to act quickly to develop this into a more effective and coherent plan, as the on-going uncertainty as to the detailed approach makes it difficult for the wide range of stakeholders make effective plans for managing PFAS risks.
CMS continues to actively monitor PFAS policy and regulation, both in UK and beyond and will provide updates accordingly. Our previous updates include discussion of PFAS risks and regulation around packaging, land ownership and development, toys, water industry and industrial permitting including site condition reports. If you would like to discuss any aspect of the above which is relevant to your business or project, do reach out to your usual CMS contact or to any of the authors listed.
[1] A national-scale preliminary overview study of poly- and perfluoroalkyl substances (PFAS) occurrence in aquatic environments of England, UK. R.J.Patel , D.C.Gooddy, B.Marchant, D.J.Lapworth, A.James, M.Cook, K.Darby, T Besien. Chemosphere 394 (2026)144804 https://doi.org/10.1016/j.chemosphere.2025.144804
