The PFAS plan: how will it affect your industry?

Summary

The government has published a plan to understand the impacts of per- and poly-fluoroalkyl substances (PFAS) on public health and the environment, with co-ordinated actions to minimise risks across many industries and sectors (the PFAS plan). The plan sets out a clear framework for understanding, identifying, reducing and managing the risks from harmful PFAS.

Background

PFAS are man-made chemicals with beneficial properties including tolerance to extreme temperatures and pressures, ability to repel oil and water, and chemical resistance. This has resulted in their widespread use, however PFAS contamination threatens public health and the natural environment. 

These chemicals are: highly mobile in air, water and land; able to accumulate in soils, plants and animals; and persistent, hence being described as forever chemicals. Advanced techniques are usually required to detect PFAS, and people can be exposed to PFAS from a variety of sources, for instance, drinking water, food, air and the use of PFAS-containing products. 

The Secretary of State is legally required to prepare and maintain an Environmental Improvement Plan (EIP), with supporting legally binding targets. In December 2025, the government announced in the revised 2025 EIP a commitment to take action on PFAS, which involved the publication of the PFAS plan. The government is legally obligated to annually review and report on progress towards commitments made in the EIP. In February 2026, the PFAS plan was published, and it sets out approximately 50 actions to tackle PFAS that will affect nearly every industry.

Practical implications

• Consumer goods: PFAS are used in numerous consumer goods and the use and presence of these goods in homes results in exposure to PFAS. These include stain- and water repellent textiles including clothing and footwear, non-stick products such as cookware, and paints, cleaning products and cosmetics and personal care products. In the PFAS plan, the Health and Safety Executive will consider restrictions or regulatory measures on PFAS under UK's Registration, Evaluation, Authorisation and Restriction of Chemicals (UK REACH) regulatory regime to align with existing EU REACH restrictions, in particular for a PFAS sub-group in textiles, food packaging and cosmetics products.
• Energy and manufacturing: In an effort to minimise emissions of PFAS, the government will develop environmental thresholds and standards for emissions to air, land and water for PFAS and require the use of the best available techniques (BAT) to prevent or minimise emissions and impacts of PFAS on the environment. It'll also develop guidance for regulators, operators, and others regulated through environmental permits to reduce emissions of PFAS and improve their handling, monitoring, and disposal. Environmental permits could be reviewed as well.
• Food, agriculture and food packaging: PFAS can be found in food, hence the Food Standards Agency (FSA) is developing and validating PFAS tests for food to support future regulatory measures. Furthermore, the government will consult on how sewage sludge use in agriculture is regulated, and whether this should be included in the environmental permitting regime. PFAS can also be found in food packaging such as food wrappers, bags, boxes and some paper-based containers as they make materials resistant to grease, oil and moisture. The FSA has concluded that there is negligible PFAS in takeaway boxes and will continue assessing whether PFAS are present in food packaging and food contact materials.
• Procurement: The government recognises the purchasing power of public authorities, and in particular government procurement of textiles. Research into the development of PFAS alternatives is already being funded, for example, in the past year the Ministry of Defence and Home Office jointly held an open competition to find alternatives to PFAS in protective materials. In the PFAS plan, the government committed to review the requirements in tendering processes for suppliers to provide information on the use of PFAS within their products supplied to the Ministry of Defence. Additionally, it has committed to considering options for introducing PFAS guidance as part of Government Buying Standards, specifically in relation to procurement of school uniforms and consideration of PFAS-free alternatives.
• Real estate and construction: The UK faces a large scale of legacy PFAS land contamination. As a result, the government intends to provide updated guidance on PFAS to support relevant local authorities in carrying out their responsibilities under the contaminated land regime, and develop guidance for regulators and industry on dealing with land affected by legacy PFAS contamination across all relevant regimes, including planning and voluntary remediation.
• Technology: The PFAS plan identifies the importance of innovation in the invention of suitable, safe and sustainable PFAS alternatives. PFAS are prevalent on account of their beneficial properties, thus it is challenging to develop alternatives which meet the high technical and performance requirements in some applications, notably those used in the healthcare sector. The government proposes to promote the innovation of PFAS alternatives in UK industry through collaborative events and forums and publish a webpage on PFAS to raise awareness and understanding of PFAS and work occurring across the government.
• Waste: Many wastes containing PFAS are permanently deposited in landfills that haven't been engineered to contain pollutants emitted through leachate and landfill gas. The Environment Agency has conducted research on the effectiveness of incineration, and the government will research and engage with industry on emerging technologies and the assessment of destruction and disposal methods. 
• Water (drinking and waste): Drinking water must not contain any micro-organisms, parasites or substances at concentrations or values which would constitute a potential danger to human health. This includes PFAS. There is currently no evidence of PFAS above the reportable level of 0.1 µg per litre in drinking water supplies, although the government will consult on the introduction of a statutory limit for PFAS in England's public supply regulations. A wide range of regulatory measures will contribute to strengthening the management of future sources of PFAS into the water environment, for example the government will continue to develop toxicological thresholds for PFAS that may impact on the quality of the water environment, continue to monitor 2,400 PFAS samples from the freshwater environment, and assess PFAS contamination in estuarine and coastal environments in England. Moreover, water companies are trialling new technologies to remove contaminants such as PFAS from sludge, and the government will research wastewater treatment options to reduce contaminants in sludge.
• All industries: Steps in the PFAS plan also include commitments to complete a PFAS review of evidence to support human health risk assessments, and to commission research to better understand the consequences of environmental contamination by PFAS on ecosystem health and wildlife.

Legal implications

The plan aims to reduce and minimise the harmful effects of PFAS while transitioning to PFAS-free alternative substances to protect public health and the environment, while building upon existing environmental regulation. The environmental permitting regimes across the UK give environmental regulators the powers to control emissions of pollutants such as PFAS. The manufacture and use of some harmful PFAS have already been restricted in the UK through various items of legislation. 
The UK is party to the UN Stockholm Convention on Persistent Organic Pollutants, which has resulted in prohibitions on the manufacture, placing on the market and use of several PFAS substances, and obligations to take measures to ensure the environmentally sound disposal of waste containing them. In July 2025, the government published a policy paper following convention-level agreement considering the expansion of PFAS within scope. 

UK REACH places prohibitions and conditions on manufacture, placing on the market and use of chemical substances. UK REACH candidate list indicates publicly if a substance has properties of very high concern. Some PFAS are already in this list, and the government is currently considering the addition of further PFAS substances. In August 2025, a potential UK REACH restriction on PFAS in firefighting foams was proposed.

Pursuant to the Fluorinated Greenhouse Gases Regulations 2015, a cap has been placed to progressively reduce the quantity of hydrofluorocarbons placed on the market in Great Britain, including some PFAS. The current schedule targets a 79% reduction by 2030, compared to the 2015 baseline. In November 2025, the government launched a consultation on a proposal to achieve a 98.6% reduction by 2048. 

How we can support you

It's crucial that businesses engage with the PFAS plan, and understand their emerging regulatory obligations, assess their exposure to PFAS‑related risks, and develop compliance strategies aligned with the PFAS plan. We can help with this and advise on the implications of the forthcoming consultations and interpreting new guidance for regulators and industry on the production, use, and disposal of PFAS. We can also support businesses with transactions involving the transition to PFAS-free alternatives, addressing legacy contamination, and enhancing supply‑chain transparency. 

Our firm comprises a number of specialists in each of the above industries, and we can provide sector-specific advice to guide you through the extensive PFAS regulatory reforms. In addition to industry expertise, we offer a full-service environmental team with vast knowledge of PFAS, the environmental permitting regime, persistent organic pollutants, UK REACH and greenhouse gas regulation.

For further information on how PFAS may affect your business and supply chain, please contact Rob Biddlecombe, Callum Ross, or Alysha Patel.

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