Non-polymer PFAS can build up in blood protein of animals, and is not always removed quickly. This means that predators eating PFAS-contaminated food will have higher levels in their bloodstream, and concentrations can increase up the food chain. Studies suggest that build up of PFAS is similar to those of other Persistent Organic Pollutants such as DDT.PFAS are estimated to be settling in arctic regions at rates of tens to hundreds of kilograms per year (25-850kg per year), depending on the specific PFAS chemical in question. Certain PFAS are released as gases to the environment and are blown a long way by wind and air currents in the atmosphere,. These gas PFAS will over time degrade to more persistent chemicals like PFOS and PFOA. This may be one reason why PFAS of environmental concern have been found in remote regions such as the Arctic as well as near PFAS production sitesPFAS including PFOS and PFOA have been found in air samples around Europe. The chemicals are found in small quantities, but appear in almost all samples tested. PFAS enters the atmosphere both from factories and the air inside our homes. https://www.ncbi.nlm.nih.gov/pubmed/17554424 PFAS is found in treated waste water from industrial and domestic sources and has been found in both rivers and groundwater. Conventional drinking water processes will not remove PFAS.PFAS-coated clothes that are thrown away will often end up either incinerated or in landfill. Unless incinerated at very high temperatures (>1000oC), fluorinated polymers could release more harmful PFAS during burning. PFAS of environmental concern have also been found in landfill leachate. Non-polymer PFAS are used in the production of fluorinated polymers. The manufacture of stain-resistant finishes generally releases these PFASs into the environment, both by air and water emissions. They are very hard to remove during water treatment. Workers in textiles factories are some of the population most exposed to these potentially harmful chemicals. Small quantities of PFAS will be removed during wash and wear of products containing PFAS. This includes fluorinated polymers used on stain-resistant coatings, and non-polymers that remain on clothes after production (Lassen et al. 2015).Most UK waste still ends up in landfill, and this includes PFAS-containing products. Studies have shown that the liquid coming from landfills (known as leachate) often contain non-polymer PFAS chemicals. In the USA the total quantities were estimated at 563-638 kg in 2013. To properly break down PFAS chemicals high temperature (1000oC or more) incineration is recommended. Incineration of municipal waste does not necessarily reach these temperatures (min temp. required is 850oC), and the incomplete breakdown could release non-polymer PFAS.Wash and wear of clothing that contains PFAS-based stain-resistant or water repellent finishes release PFAS to the environment. Coatings are thought to lose effectiveness after 20-30 washes. This can include non-polymer PFAS, remnant from production or as a break-down product of side-chain polymers (Lassen et al. 2015). The manufacture of stain-resistant finishes releases PFAS into the environment, both by air and water emissions. PFAS are very hard to remove during water treatment. Industrial emissions are estimated to be the biggest source of these chemicals to the environment.

The UK Government PFAS plan

In February 2026, the UK Government released its long‑awaited national plan to tackle PFAS. This plan represents the first coordinated UK-wide effort to understand and attempt to reduce the risks posed by PFAS.  

The PFAS Plan sets out how the Government intends to identify sources of PFAS, manage risks linked to their use, and support a shift toward safer alternatives. 

However, further scrutiny raises concerns as to whether the plan goes far enough to prevent PFAS pollution at source.   

The PFAS plan

The UK’s PFAS Plan is a clear acknowledgement of the risks posed by these forever chemicals and is an important step in the right direction. The plan recognizes the need to address PFAS as a group using the OECD definition1, the importance of full lifecycle assessments for chemicals, and the need for regulatory intervention to address legacy and on-going PFAS pollution. It also makes some promising commitments to action, such as improved monitoring and research regimes, and consideration of statutory limits on PFAS in drinking water. But is this enough? 

Whilst the EU progresses towards a proposed universal restriction on PFAS2, the UK PFAS Plan notably lacks any commitment to introduce new restrictions on PFAS use, beyond existing proposals to restrict PFAS in firefighting foams. As acknowledged within the plan, PFAS pollution is already widespread across the UK, with evidence mounting of significant health and environmental impacts.  In order to ensure effective protection and prevent a widening gap between UK and EU standards, decisive, preventative measures are essential to address PFAS pollution at source.  

The plan is acknowledged to be a ‘stepping stone’ towards a ‘longer-term vision’. There is therefore still opportunity to build upon the commitments laid within the current plan, and for the UK to match the ambition urgently needed to address PFAS pollution.  

¹ The Organisation for Economic Co-operation and Development (OECD) revised its definition of PFAS in 2021 to include any fluorinated substance containing at least one fully fluorinated methyl (–CF₃) or methylene (–CF₂–) carbon atom. This broad definition encompasses over 10,000 PFAS.
² A universal restriction proposes to ban the manufacture, import and use of all PFAS, as defined by the OECD definition. This includes implementing clear timelines and appropriate derogations for critical uses should alternatives not yet be available.

What does the PFAS plan cover?

This section aims to outline what is currently known about PFAS and the Government’s priorities to improve understanding of PFAS use in the UK, their prevalence in the environment and the risks they present.  

Work will broadly focus on investigating: 

  • Prevalence and impact of PFAS in the environment  
  • Human exposure  
  • Improving understanding of the extent and impact of PFAS in the environment 
  • Improving understanding of where PFAS is and has been used 

This section aims to identify and address PFAS pathways by managing the risk across their full life cycle. This includes efforts to reduce PFAS emissions entering and circulating in the environment, as well as supporting transitions to safer alternatives.    

Broad areas of work considered include:  

  • Addressing the use of PFAS through regulatory action  
  • Working internationally to address PFAS as a global problem 
  • Reducing emissions of PFAS to air, land and water from industrial sites 
  • Preventing PFAS in landfills and waste from entering the environment 
  • Supporting industry’s innovation in alternatives to harmful PFAS 
  • Improving public awareness and understanding of PFAS 
  • Harnessing public sector purchasing power 

This section aims to address existing PFAS pollution through improved monitoring frameworks, testing and permitting regimes, guidance and other regulatory interventions.  

Broad areas of work considered include:  

  • Assessing the risk to human health 
  • Managing the risks from PFAS in the food we eat 
  • Continuing to improve the water we drink 
  • Improving the quality of our waters 
  • Reviewing the risks of PFAS in sewage sludge being spread to land 
  • Addressing legacy PFAS pollution 
  • Managing the risks of PFAS in consumer products 

Opportunities for further action

Subject area
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  • Consumer products:

    The plan acknowledges widespread PFAS use in consumer products, the opportunity to support adoption of safer alternatives & the need for improved chemical transparency along supply chains.

    The plan emphasises how improved public awareness “should not replace the need for industry & the government to ensure products placed on the market are safe”, including through government regulation.
  • Sources of PFAS:

    The plan acknowledges the need to tackle PFAS pathways, including reducing PFAS at source. 
  • Food packaging:

    The plan acknowledges PFAS use is in some food packaging items and the potential for food packaging to be a source of exposure, but notes uncertainty and data gaps.
  • Pesticides:

    The plan acknowledges that PFAS pesticides are a potential source of the ultrashort-chain PFAS, TFA.
  • TFA:

    The plan acknowledges that TFA is widely found in UK rivers and is a breakdown product of many PFAS sources, including use in pesticides, pharmaceuticals and refrigerants.
  • Sewage sludge:

    The plan acknowledges sewage sludge is a source of PFAS pollution. 
  • Drinking water:

    The plan acknowledges drinking water as a PFAS exposure risk but maintains that current UK levels remain within safe limits.
  • F-gases:

    The plan acknowledges that some F-gases contribute to PFAS pollution and states that there is limited availability of alternatives.  
  • Fluoropolymers:

    The plan includes fluoropolymers within its definition of PFAS and emphasises the need to assess lifecycle emissions throughout their production, use, and disposal.
Initial key actions proposed in the PFAS plan
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  • Publish webpages on PFAS to improve awareness. 

    Consider potential restrictions or regulatory measures on PFAS use in specific consumer product groups.

    Support industry and international work to promote the use of safer PFAS alternatives including in consumer products.

    Host a roundtable with a range of stakeholders, to discuss PFAS risks in consumer goods, such as period products.
  • Complete work to consider a proposal on restricting PFAS in firefighting foams.

    Consider potential restrictions or regulatory measures on PFAS use in specific consumer product groups.

    Consider approach towards further UK REACH restrictions and reform UK REACH to be more closely aligned with the UK’s closest trading partner, especially the EU, by Dec 2028.  

    Increase monitoring of PFAS in the environment and commission further research to help understand and identify sources of PFAS pollution.
  • Continue investigating PFAS in food packaging to gather more data to inform any future regulatory intervention.
  • No actions proposed for PFAS pesticides.
  • Expand research and monitoring of TFA and other ultrashort-chain PFAS to assess health and environmental risks and inform any future regulatory interventions.
  • Review and consult on reforms to current outdated sewage sludge use in agriculture regulations and consider regulating sludge spreading within the Environmental Permitting Regime. 

    Continue working with the water industry and other key stakeholders to strengthen understanding of contaminants and assess treatment options for reducing contaminants in sludge.
  • Consult on the introduction of a statutory limit for PFAS in England’s public supply regulations. 

    Explore collecting data on the risk of PFAS in bottled water.
  • Continue to use current F-gas legislation to manage the use and emissions of F-gases through controls on leakage prevention, leak checks and recovery. 

    Explore future reforms to raise the ambition of F-gas legislation. 
  • Assess current & historic use of fluoropolymers to inform policies to mitigate potential negative impacts.
Fidra's recommendations
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  • Address the source of the issue by restricting PFAS in consumer goods under a universal restriction on PFAS and support uptake of safer alternatives. 

    To future-proof products for safe use in a a circular economy circular economy, improve chemical transparency along supply chains through digital product labelling.
  • Commit to a universal restriction on PFAS through alignment with EU chemical regulation.

    In the meantime, use sector-specific restrictions to begin reducing PFAS emissions immediately where alternatives are already widely available, such as in food packaging and textiles.
  • Use existing evidence of PFAS in UK food packaging and widespread availability of safer alternatives to introduce a sector-specific restriction on PFAS use in food packaging. This would align the UK with EU regulations, where a restriction on PFAS use in food packaging is underway, and should complement a wider commitment to a universal PFAS restriction in the UK.
  • Restrict the use of PFAS in pesticides as part of a universal restriction on PFAS.

    Countries like Denmark are already withdrawing the approval of multiple PFAS pesticide active substances due to their potential for harm and association with TFA pollution. The UK should also address this major source of PFAS pollution through effective source control and support uptake of sustainable alternatives.
  • Commit to phase out PFAS across all sectors under a universal restriction, including use in pesticides, pharmaceuticals and refrigerants to prevent further TFA and wider PFAS pollution. This should include clear timelines and appropriate derogations for critical uses should alternatives not yet be available. 
  • Phase out the application of sewage sludge to agricultural land until it can be proven to be a clean and safe resource.

    Commit to enforcing stronger environmental protection through updated regulations and extending regulated contaminants in sludge to include PFAS. 

    Introduce restrictions on PFAS and other contaminants to prevent further contamination of resources (wastewater and sewage sludge).
  • Introduce statutory limits for PFAS in drinking water without delay and complement this action with restrictions on PFAS use to prevent further pollution at source.

    Though we welcome the introduction of a statutory limit for PFAS in drinking water, without commitments to source control through a universal restriction on PFAS, people will continue to be exposed through their environment and food.  
  • Commit to phase out all PFAS-containing F-gases, including HFOs, where alternatives are already widely available, under a universal restriction on PFAS.

    Policies that encourage and enable the use of non-fluorinated alternatives should also be implemented. Contrary to the PFAS plan, many PFAS-free alternatives, like CO2 and ammonia, are already widely available, safe and cost effective for some uses.
  • Commit to a universal restriction to phase out PFAS across all sectors, including fluoropolymers. 

Our call to action

Though the PFAS Plan is a step in the right direction, protecting people, the environment and the economy from forever chemicals demands far greater urgency and ambition. To address this issue at source, the UK Government must commit to phase out PFAS from all non-essential uses. This could be achieved through alignment with EU chemical regulation, including the EU’s proposed universal PFAS restriction.

In the meantime, reducing PFAS emissions immediately through sector-specific restrictions should be prioritised. For example, progressing with the proposed restriction on PFAS in firefighting foams, as outlined in the plan, and introducing restrictions on PFAS use in products with well-established and widely accessible alternatives, such as food packaging and textiles.

Turning off the tap remains the most critical and immediate action required to tackle PFAS pollution and protect public and environmental health for future generations.

Further reading