Addressing the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

PFAS are highly persistent, bioaccumulative chemicals with the potential for long-term environmental and human harm, despite ongoing scientific uncertainties around the toxicity of different PFAS. (Conclusion, Paragraph 22)

The Government’s PFAS Plan disproportionately focuses on expanding PFAS monitoring rather than preventing or remediating contamination. Applying the Government’s own environmental principles demands decisive action now to limit further release and exposure. (Conclusion, Paragraph 23)

Voluntary action on PFAS and self-regulation by industry are not sufficient to ensure transparency, accountability or reduce PFAS emissions. (Conclusion, Paragraph 24)

The Government must act in line with the environmental principles, taking preventative and precautionary action to reduce cumulative PFAS exposure to both people and the environment. We expect the Government to set out in its response how its approach to PFAS has been developed with due regard to precautionary principle within the environmental principles policy statement. (Recommendation, Paragraph 25)

UK REACH, in its current lagging and slow-moving form, risks leaving the UK behind international best practice and limits the Government’s ability to respond swiftly to emerging scientific evidence on PFAS. This increases the likelihood of further regulatory divergence between Great Britain and Northern Ireland, creating trade barriers both ways, and detrimental consequences for UK goods in the EU market. (Conclusion, Paragraph 35)

The Government should make use of existing EU-UK dialogue mechanisms to support UK alignment with EU REACH to avoid unnecessary regulatory divergence. Whilst UK Government may choose a different approach in some areas, without such alignment, UK manufacturers risk accidentally being placed at a competitive disadvantage, and the UK public may face greater exposure to PFAS due to the absence of the more precautionary approach being pursued in the EU. (Recommendation, Paragraph 36) 43

UK REACH must be reformed to enable swifter restrictions on PFAS to ensure the UK can align with emerging evidence to act more quickly on substances of concern. (Conclusion, Paragraph 37)

The Government should reform UK REACH by March 2027 to avoid further delay in restricting PFAS. The Government should set targets at half the statutory maximum timescales and ensure that the Health and Safety Executive has the resources to meet these accelerated timelines. (Recommendation, Paragraph 38)

The Government should adopt an essential-use approach to regulating PFAS, prioritising the rapid restriction of PFAS in non-essential applications. Clearly defined exemptions should be set for essential uses, with time-limited derogations where substitutes are still being developed. (Recommendation, Paragraph 46)

The Government should commission the Health and Safety Executive under UK REACH to bring forward restrictions on PFAS in non-essential consumer products (e.g. food packaging, cookware and school uniforms) without delay and begin a phased restriction from 2027. (Recommendation, Paragraph 47)

Replacing one PFAS with another can perpetuate long-term environmental and health risks and can lead to regrettable substitutions, whereby banned substances are rapidly replaced by chemically similar and potentially harmful alternatives. (Conclusion, Paragraph 54)

Due to the impracticality of assessing thousands of PFAS one by one, and the risk that new substances emerge faster than they can be evaluated, the UK’s current approach leaves regulators struggling to keep pace with industry innovation. While the burden of proof currently rests with Government before substances are banned, it is likely that without adopting a more ambitious approach the UK will continue to suffer significant PFAS contamination for many more decades. (Conclusion, Paragraph 55)

Without a broad, group-based restriction on PFAS, the Government risks a “whack-a-mole” approach. (Conclusion, Paragraph 56)

The Government should draw on independent scientific and regulatory expertise in taking a group-based approach for PFAS regulation within three months of the EU’s forthcoming assessment. This should include assessing options for grouping PFAS with similar structures, so that future restrictions can be applied more swiftly, and effectively as new evidence emerges. (Recommendation, Paragraph 57)

The Government should consult on the establishment of an industry-funded mechanism to rapidly assess the properties and risks of newly developed PFAS before they are permitted for use, and invest in the development of 44 safer alternatives. This mechanism should prevent regrettable substitutions, incentivise safer alternatives and enable faster, more effective regulatory decisions, with proposals published within 12 months of the publication of this report. (Recommendation, Paragraph 58) Human exposure and risk management

While gaps remain in understanding the toxicity of every individual PFAS, the evidence indicates that several PFAS are associated with a wide range of adverse health effects. Studies of highly exposed groups show clearer and more immediate risks, underscoring the need for precautionary action, given the extreme persistence and bioaccumulation of PFAS in the body, to protect the public. (Conclusion, Paragraph 64)

The Government should invest in long-term research on the health effects of PFAS exposure in the UK population. Within 12 months, it should publish a delivery plan setting out epidemiological studies to assess the cumulative impact of multiple PFAS and the establishment of biomonitoring programmes for groups with higher exposure. For communities and occupations with known or suspected elevated PFAS exposure, the Government should also provide enhanced health screening, enabling early detection of health impacts, identification of trends, and reduced anxiety for affected individuals. (Recommendation, Paragraph 65)

The challenges of managing the risks of PFAS and associated health impacts are not issues faced by the UK alone. Many of the lessons relevant to the UK are already emerging from studies and regulatory processes across the European Union and beyond. (Conclusion, Paragraph 66)

The Government should draw on international best practice and collaborate with established PFAS research programmes to ensure that the UK is fully aligned with and contributing to this global evidence base. This will enable the Government to make evidence-based decisions more quickly and reduce the cost to the UK taxpayer. A synthesis report summarising the UK’s international engagement, findings and planned actions should be published within six months of this Committee’s report. (Recommendation, Paragraph 67)

Although the Government has begun setting statutory limits for PFAS in drinking water, which is a welcome step, significant gaps remain in managing and limiting human exposure to PFAS through food and agricultural pathways. (Conclusion, Paragraph 76)

The Government should set limits on the levels and types of PFAS permitted in food, giving producers, retailers, and regulators a consistent basis for protecting public health. This should include establishing and monitoring 45 limits on PFAS entering the food chain through agricultural processes. The Government should publish these limits within three months of the publication of the Committee on Toxicity’s review to draw on the expertise. (Recommendation, Paragraph 77)

Whilst PFAS-containing consumer products remain on the market, the Government should introduce interim limits on PFAS levels and require standardised labelling to ensure consumers are fully informed. Implementation should be led by the Department for Environment, Food and Rural Affairs, working with the Food Standards Agency and the Office for Product Safety and Standards. This should take effect within six months and remain in place until PFAS are restricted in non-essential consumer goods. (Recommendation, Paragraph 78)

Whilst the PFAS Plan sets out monitoring commitments, it lacks the specificity needed to inform and deliver action. Without clear requirements on what to monitor, the methods to use, and the thresholds for concern, and without adequate funding and laboratory capacity, the Environment Agency cannot enforce limits or identify risks in time to act. (Conclusion, Paragraph 83)

The Government should provide full detail, in its response, on how its PFAS monitoring strategy will support enforcement and remediation. This should include a clear explanation of how monitoring results will be used to identify risks, guide remediation activity, and underpin regulatory enforcement. (Recommendation, Paragraph 84)

The Government should accompany this with an assessment of the resources required for the Environment Agency to deliver their responsibilities outlined in the PFAS Plan and commit to providing the associated funding in its response. (Recommendation, Paragraph 85) Addressing pollution

Lack of supply chain transparency fundamentally undermines the UK’s ability to manage PFAS at end-of-life, leaving councils, waste operators and regulators unable to prevent products with PFAS entering landfill, and leading to further pollution of waterways, soil and the wider environment. (Conclusion, Paragraph 93)

The Government should consult on mandatory PFAS disclosures across supply chains within six months, requiring manufacturers and importers to report the presence and purpose of PFAS in products placed on the UK market to support safe handling and disposal. (Recommendation, Paragraph 94) 46

The Government must set out in its response a timeline to divert PFAS waste from landfill towards safer treatment or destruction technologies to manage increasing volumes of PFAS waste without causing further environmental contamination. (Recommendation, Paragraph 95)

Remediating PFAS contamination in the environment is expensive and technically complex. The current regulatory approach that permits continued use of PFAS until harm is proven means that these substances can legally continue to accumulate in the environment, steadily increasing the long term environmental and financial burden. (Conclusion, Paragraph 106)

The Government has not applied the polluter pays principle adequately to deter future PFAS emissions nor has it allocated sufficient government funding to tackle the remediation of PFAS in the environment where liable parties cannot be identified. (Conclusion, Paragraph 107)

The Government should apply the polluter pays principle to prevent ongoing and historic PFAS contamination and consult by March 2027 on establishing a national PFAS Remediation Fund. The Government should: • explore the implications of an emissions levy for PFAS on the UK REACH candidate list, to deter ongoing environmental contamination and hold polluters responsible; • consider options for extending the polluter pays principle to products manufactured overseas and imported into the UK; • ensure that when the Government extends the polluter pays principle that UK manufacturers are not at a disadvantage to overseas manufacturers of products; • increase dedicated central government funding for local authorities to remediate where no responsible party can be identified; and • ensure that the Remediation Fund and associated enforcement are overseen by the Environment Agency, and ensure that the Environment Agency has the necessary resources and skills required to implement any monitoring and enforcement responsibilities. (Recommendation, Paragraph 108)

Existing PFAS contamination in the environment must be addressed alongside prevention. Even with strong restrictions on future PFAS use, the UK already faces significant legacy contamination. Without action now, this legacy burden will pose long-term risks to public health and the environment, and mounting costs will continue to fall on government (and taxpayers) and water companies (and water bill payers). (Conclusion, Paragraph 113) 47

Industry urgently needs clear direction and Government approval on viable remediation methods so that contaminated materials can be treated safely and at scale. (Conclusion, Paragraph 114)

The Government should support the development and deployment of scalable, cost-effective PFAS remediation technologies by directing investment through UK Research and Innovation into research, innovation and practical support. (Recommendation, Paragraph 115)

The Government must publish formally approved guidance for PFAS remediation to provide businesses, local authorities and regulators with the certainty needed to deliver timely, safe and effective remediation. (Recommendation, Paragraph 116)

PFAS contamination cannot be addressed without reliable destruction capacity. Current UK incineration capacity is insufficient to treat the increasing volume of PFAS containing waste diverted from landfill, and significant gaps remain in the availability, scalability, and verification of other destruction technologies. (Conclusion, Paragraph 123)

The Government should assess the volume of PFAS containing waste expected from forthcoming restrictions and determine whether UK high- temperature incineration capacity is sufficient. The Government should write to the Committee with its findings and proposed actions within six months. (Recommendation, Paragraph 124)

The Government must commit, within six months, to funding the research and development of non-incineration PFAS destruction technologies through UK Research and Innovation and Innovate UK. (Recommendation, Paragraph 125) 48