On 3 February, Defra published a new PFAS action plan, in line with the commitments made in the UK Government’s 2025 Environmental Improvement Plan (EIP). Acknowledging the need to act to contain the risks posed by PFAS (per- and poly-fluoroalkyl substances) to human health, wildlife and the natural environment, the document sets out, for the first time, a plan aimed at understanding, managing and reducing exposure to these substances.

In its pursuit of this goal, the plan takes what IEEP UK has previously termed a ‘broad’ regulatory view, and is built around three pillars: identifying and understanding the sources of PFAS; tackling the spread of PFAS in society and the environment, which entails taking action to manage the risks of PFAS across their full life cycle; and reducing and managing the ongoing exposure for the PFAS that are already in the environment.

The publication of a plan which takes this ‘broad’ approach to the long-term challenge posed by PFAS and encourages a coordinated approach across government, regulators, academia and industry, is a welcome development. Other positive elements of the plan include its recognition that the transboundary nature of PFAS pollution necessitates monitoring across air, land and water and the related focus on gathering evidence on PFAS sources, pathways and exposure, as well as the commitment to launch a consultation on setting a statutory limit for PFAS in England’s public water supply regulations. This could bring England and Wales into closer alignment with the EU’s recast Drinking Water Directive, which introduced limit values for PFAS concentration.

However, given the scale of the environmental and economic issues that PFAS contamination and cleanup represents, the plan lacks important short-term measures and defers many of the hardest regulatory choices to the future. For example, the document is not explicit on plans for alignment between UK and EU REACH, with the latter having implemented further bans and restrictions on specific PFAS since Brexit that have not been matched by the UK. This lack of clarity in the plan comes despite an announcement during Defra’s oral evidence to the EAC PFAS inquiry on 4 February that UK REACH will be amended to facilitate alignment with the EU.

The policy approach set out in the plan contrasts to that being taken in the EU, which is working towards a blanket ban on PFAS. Currently, the European Chemicals Agency (ECHA) is conducting the scientific evaluation of this proposed EU-wide restriction, which should be concluded in 2026. In the meantime, some Member States have already developed policies to proceed at a national level with partial restrictions of these chemicals ahead of EU-wide action. This is the case, for example, in France, which has pushed forward with bans on PFAS in cosmetics and clothing.

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