Defra's PFAS Plan Includes Addressing PFAS Through Chemical Regulatory Actions

The United Kingdom's (UK) Health and Safety Executive (HSE) announced on February 3, 2026, that the Department for Environment, Food and Rural Affairs (Defra) has published a PFAS Plan, a "cross-government, science-led" plan to understand the impacts of per- and polyfluoroalkyl substances (PFAS) on public health and the environment, with coordinated actions to minimize risks. Defra notes that there is no universally agreed definition of PFAS, but states that the Organisation for Economic Co-operation and Development (OECD)'s definition "is a pragmatic choice on which to base PFAS policy and we will use it to guide the actions in this plan." OECD defines PFAS as "fluorinated substances that contain at least one fully fluorinated methyl or methylene carbon atom (without any hydrogen, chlorine, bromine or iodine atom attached to it). This means that, with a few noted exceptions, any chemical with at least a perfluorinated methyl group (-CF3) or a perfluorinated methylene group (-CF2-) is a PFAS."

The PFAS Plan sets out the government's overall approach, with actions across three main sections:

• Section 1: Understanding PFAS sources — Section 1 relates to understanding PFAS and its sources. It sets out:
  
  
  • What the government knows about PFAS currently; and
    
    
  • Priorities for improving its understanding of PFAS use in society, its prevalence in the environment, and the risks this presents.

• Section 2: Tackling PFAS pathways — Section 2 relates to tackling PFAS pathways, including reducing PFAS at the source and preventing PFAS from entering and circulating in the environment. Using its evidence on PFAS, Defra states that it can:
  
  
  • Take actions to manage risks of PFAS across their full life cycle; and
    
    
  • Support the transition to safer alternatives while recognizing where critical PFAS uses are still currently needed.

• Section 3: Reducing ongoing exposure to PFAS — Section 3 relates to reducing and managing ongoing exposure to harmful PFAS, to protect people and the environment, including from legacy pollution.

To address the use of PFAS through regulatory action, Section 2 of the PFAS Plan lists the following initial indicative actions:

• Action 2.1: Complete work to consider a UK REACH restriction on PFAS in fire-fighting foams. HSE's report on PFAS use in fire-fighting foams in Great Britain (GB) presents HSE's scientific analysis and evidence base, alongside a public consultation, for a potential UK REACH restriction. Once HSE publishes a final opinion on PFAS in firefighting foams, the relevant UK government minister, with the consent of devolved governments, will make a decision on implementing the proposal.

• Action 2.2: Consider its approach toward further UK REACH restrictions. As set out in the Environment Improvement Plan (EIP), Defra states that it will reform UK REACH to enable protections that address chemical pollution to be applied more quickly, efficiently, and in a way more aligned with its closest trading partners, especially the European Union (EU), by December 2028. In this context, Defra will consider further UK REACH restrictions. Existing EU REACH restrictions relate to:
  
  
  • PFAS in firefighting foams;
    
    
  • PFAS in the sub-group perfluorohexanoic acid (PFHxA), including in consumer products (such as textiles, food packaging, and cosmetics); and
    
    
  • A sub-group of perfluorocarboxylic acid PFAS (that have subsequently been listed as persistent organic pollutants (POP) under the Stockholm Convention and will be subject to further GB action through the POPs regulation);

• Action 2.3: Progress towards the addition of more PFAS substances to the UK REACH candidate list of substances of very high concern (SVHC), subject to consultation;

• Action 2.4: Implement its obligations under the Stockholm Convention on POPs. This includes continued regulatory and enforcement action on already prohibited PFAS (perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), and perfluorohexane sulfonic acid (PFHxS), including their salts and related compounds), and prohibiting long-chain perfluorocarboxylic acids (LC-PFCA), including their salts and related compounds, following recent convention-level agreement;

• Action 2.5: Continue to use the current F gas legislation to manage the use and emissions of F gases (some of which are PFAS) through controls on leakage prevention, leak checks, and recovery; and

• Action 2.6: Explore future reforms to raise the ambition of F gas legislation in a way that takes account of the balanced approach described in the Introduction above.

To manage the risks of PFAS in consumer products, the PFAS Plan states that Defra will consider consumer articles as part of any work to consider PFAS restrictions under UK REACH and work to consider potential restrictions or regulatory measures on PFAS use in specific consumer product groups.

The PFAS Plan "is a stepping stone to meet [Defra's] longer-term vision." To monitor implementation, the PFAS Plan includes a table setting out a full list of indicative actions, delivery outlook, and responsible owners. As a commitment set out in the EIP, review and reporting of the PFAS Plan will become part of Defra's statutory reporting cycle for the EIP.

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