The PFAS Plan and What it Means for UK Businesses.

The PFAS Plan, released on 3 February 2026, provides the UK Government's proposed plan and approach to PFAS, a type of prevalent ‘forever chemical’ that persists in the environment and carries risk to human health and environmental health.

What is PFAS?

Per- and poly-fluoroalkyl substances (PFAS) are a group of chemicals with similar features: they contain at least one fully fluorinated methyl or methylene carbon atom. They get called 'forever chemicals' because they persist, meaning they never break down in the environment and accumulate in water sources, soil, and organisms. They commonly appear in everyday items, including non-stick pans, stain-resistant materials, flame-retardant textiles and furniture, medical devices in hospitals, and some fire-extinguishing foams. Their properties are valuable in society, but these benefits must be suitably balanced with the significant risks that they pose.

PFAS affect human health in multiple ways: they disrupt hormone systems, affect immune function, damage the liver and kidneys, and have been linked to increased cholesterol levels and reduced vaccine response. The evidence and understanding around the risks of PFAS is still developing. Some substances (such as PFOA and PFOS) are well researched, but the health effects of many other PFAS remain uncertain. Understanding how PFAS affects different groups is also still developing, but it is understood that children may be particularly vulnerable during early development.

PFAS damage the environment and the organisms living within it. PFAS are highly mobile, meaning they move freely through air, water, and land, and can accumulate in plants, animals, and ecosystems. They have been found in approximately 80% of surface water samples, approximately 50% of groundwater samples, and in all fish samples tested across the UK. PFAS are widespread even in remote parts of the globe, such as Antarctica. Evidence shows that levels of some PFAS in the environment are harmful to certain species of wildlife, and there is ongoing research to determine the extent of this impact on ecosystems and biodiversity.

PFAS are a newer area of regulatory focus, and the full risk profile remains uncertain. This uncertainty is precisely why the UK Government has acted now.

What does the PFAS Plan set out to do?

The three headline objectives of the PFAS Plan are to:

1. 1. Understand where PFAS comes from, how prevalent it is, and what the risks are.
   2. Reduce PFAS at source, prevent PFAS from entering the environment, transition to safer alternatives where possible, and manage risks throughout PFAS lifecycles.
   3. Reduce ongoing exposure to PFAS due to substances that are already in society and the environment.

The PFAS Plan will be delivered using a 'science-based and evidence-led' approach, ensuring that a balance can be struck between required uses of PFAS and management of the risks they pose. The PFAS Plan sets out five environmental principles that will guide its implementation:

1. 1. The Integration Principle: Environmental protection must be integrated into the definition and implementation of other policies and activities.
   2. The Prevention Principle: Environmental damage should be prevented at source rather than remedied after the fact.
   3. The Rectification at Source Principle: Environmental damage should be rectified at its source, placing responsibility on those causing the harm.
   4. The Polluter Pays Principle: The costs of pollution prevention and control should be the burden of those responsible for causing the pollution.
   5. The Precautionary Principle: Where there is uncertainty about potential environmental harm, precautionary measures should be taken to prevent damage.

What will the PFAS Plan change for businesses?

Regulation of PFAS is needed to protect people and the environment, but the precise form of those regulations is still being determined through consultation and evidence-gathering. The Plan sets out a series of "indicative actions," many of which are still in their early stages.

Here are the key regulatory directions identified by the PFAS Plan:

• • Chemical restrictions:
    • The UK is reviewing restrictions on PFAS through UK REACH (the chemicals regulatory regime).
    • There is currently a public consultation on a potential restriction for PFAS in firefighting foams.
    • The government is also considering further UK REACH restrictions on specific PFAS sub-groups, aligning the UK approach with EU measures by December 2028. Additional PFAS substances are being considered for addition to the UK REACH candidate list of substances of very high concern.
  • International obligations:
    • The UK is implementing global agreements under the Stockholm Convention on Persistent Organic Pollutants. This includes prohibitions on PFOS, PFOA, perfluorohexane sulfonic acid (PFHxS), and long-chain perfluorocarboxylic acids (LC-PFCAs) and their salts and related compounds.
  • Industrial emissions:
    • The government is developing guidance for regulators and industry on reducing PFAS emissions from industrial sites, with plans to develop scientifically robust environmental thresholds and standards for emissions to air, land and water.
    • Environmental permits may be reviewed to ensure appropriate controls are in place.
  • Drinking water:
    • England's drinking water regulator is consulting on introducing a statutory limit for PFAS in public supply regulations (currently, there is guidance at 0.1 µg per litre, with no exceedances recorded). Scotland already has a statutory standard of 0.1 µg per litre for 20 named PFAS compounds.
  • Sewage sludge and waste:
    • The government is consulting on reforms to how sewage sludge use in agriculture is regulated, and whether it should be included in the Environmental Permitting Regime, given PFAS contamination concerns.
  • Consumer products:
    • There is a commitment to consider potential restrictions on PFAS use in specific consumer product groups.
    • A joint government roundtable is planned for early 2026 to discuss PFAS risks in consumer goods.

The transition away from PFAS will take time, as will putting new regulations in place. The government recognises that trade-offs must be carefully considered. For example, where critical functions are provided by PFAS (such as in medical devices), these should be maintained if no viable non-PFAS alternatives currently exist.

How can iCOR support organisations with the incoming legal changes relating to PFAS?

The 2026 PFAS Plan is a long-term commitment, reflecting the scale and persistence of the challenge. For businesses, the PFAS Plan signals that regulation is coming, the evidence base is strengthening, and the transition away from harmful PFAS is underway.

iCOR’s self-audit tool, bespoke legal register, and monthly updates enable organisations to catch legal updates quickly, assess relevance to their organisation, and understand their status of conformity as regulations emerge.

Book a demo here to learn how iCOR can support organisations in understanding and complying with new PFAS legislation and changes to existing chemicals, waste, and water regulations.