The UK Government has announced a new plan to address per- and polyfluoroalkyl substances (PFAS), including actions that specifically address human dietary exposure and food and water contamination.

The PFAS Problem

PFAS are a class of chemicals used for industrial purposes and in a wide range of consumer products, including, but not limited to, food packaging and nonstick cookware. Often referred to as “forever chemicals” due to their inability to break down in the human body or environment over time, PFAS are subject to increasing scrutiny due to the growing body of evidence demonstrating their pervasiveness, harms to human health, and accumulation in water, air, soil, animals, food, and people.

According to environmental monitoring data collected by the UK Department for Environment, Food, and Rural Affairs (DEFRA), PFAS have been found in approximately 80 percent of surface water samples, 50 percent of groundwater samples, and all fish samples tested across the country.

The UK Government’s PFAS Plan

Addressing the public health threats associated with PFAS, the UK Government has announced a sweeping PFAS Plan that defines a series of risk management actions designed to:

1. Understand the sources of PFAS pollution
2. Tackle the pathways through which PFAS spread through the environment and support the transition to safer alternatives where possible
3. Mitigating ongoing human, animal, and environmental exposure to harmful PFAS.

Specific to food and water safety, initial actions the UK Government intends to conduct under the PFAS Plan include steps to better understand human dietary exposure to PFAS and the health consequences of exposure; testing PFAS in food contact materials and food packaging; and considering the introduction of a statutory limit for PFAS in public drinking water. The UK Government also intends to continue and expand environmental monitoring for PFAS, consider restricting PFAS uses; and other actions.

More broadly, the initial actions outlined in the PFAS Plan across the three focus areas include:

1. Understanding PFAS Sources

• Environmental monitoring: Continuing to monitor and report PFAS samples from freshwater; improving PFAS monitoring in soils; considering adding more PFAS to the UK Pollutant Release and Transfer Register (PRTR); delivering a multi-year assessment of PFAS contamination in estuarine and coastal environments, including fish, by 2028; increasing availability of PFAS data across the public sector; and commissioning research to better understand the ecosystem and wildlife consequences of environmental contamination
• Researching areas of emerging concern: Including evidence on sources of trifluoroacetic acid (TFA), a pervasive ultra-short-chain PFAS formed by the breakdown of other chemicals, and analysis of the historic and current use of fluoropolymers (or other PFAS) in the UK.

2. Tackling PFAS Pathways

• Addressing PFAS uses through regulatory actions: Such as the consideration of potential Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulations for firefighting foams, perfluorohexanoic acid (PFHxA) in consumer products, and uses of a sub-group of perfluorocarboxylic acid (PFCAs) considered to be persistent organic pollutants (POPs) under the Stockholm Convention; progress toward the inclusion of additional PFAS to the UK REACH candidate list of substances of very high concern (SVHCs); implementing obligations under the Stockholm Convention on POPs, including continued enforcement of already-prohobited PFAS like perfluorooctanoic acid (PFOA), perfluorooctanesulfonic acid (PFOS), and perfluorohexane Sulfonic Acid (PFxS) and prohibiting long-chain perfluorocarboxylic acids (LC-PFCAs); and managing the use and emissions of PFAS fluorinated gases (F-gases) through existing F-gases legislation while exploring future expansions of F-gas regulations
• International collaboration: Continuing to engage in the Stockholm Convention and supporting work addressing PFAS by the UN Environment Program (UNEP) and the Organization for Economic Co-operation and Development (OECD)
• Reducing emissions from industrial sites: By developing guidance for industry and potential control measures, science-based environmental thresholds and standards for emissions, and requiring the use of Best Available Techniques (BAT) to prevent or minimize emissions and impacts of PFAS on the environment
• Preventing PFAS waste from entering the environment: By continuing to improve understanding of the management of PFAS in waste and risk associated with disposal to support potential regulatory actions on waste management and implementing existing waste controls for PFAS classified as POPs
• Supporting industry adoption of safer alternatives: Through engagement with industry and researchers to promote innovation and international work to assess PFAS alternatives
• Improving public understanding of PFAS and harnessing purchasing power: By publishing information on Government webpages and reviewing Government Buying Standards.

3. Reducing ongoing exposure to PFAS—Including Food and Water Safety

• Assessing risks of exposure to human health: By completing a PFAS review of evidence to support human health risk assessment
• Mitigating risks from dietary exposure: Including testing of PFAS in food contact materials (FCMs) and enhancing analytical capabilities, developing and validating tests for PFAS in foods where tests are not yet available, implementing monitoring programs to collect data on PFAS in foods and FCMs to inform risk assessments and support regulatory measures, and potentially collecting data on the risk of PFAS in bottled water 
• Ensuring drinking water safety: By launching a consultation on the introduction of a statutory limit for PFAS in England’s public supply regulations
• Improving water quality: By developing toxicological thresholds for PFAS that may impact water sources in support of potential regulatory reforms and new environmental quality standards (EQS) for PFAS, as well as developing improved testing methods for persistent, mobile, and toxic (PMT) substances, including PFAS
• Expanding investigation risks of PFAS in sewage sludge being spread to land: Under the Water Industry’s Chemical Investigation Program (CIP), which already monitors PFOS, PFOA, and perfluorobutane sulfonate (PFBS)
• Addressing legacy PFAS pollution: Through the development of a risk prioritization framework to support control efforts; providing updated information, advice and guidance on PFAS to local authorities; developing technical guidance for regulators and industry on dealing with land affected by legacy PFAS contamination; and exploring opportunities to work with partners toward developing standards and guidelines for different PFAS substances.
• Managing the risks of PFAS in consumer goods: Considering consumer articles as part of potential PFAS restrictions under UK REACH and restrictions or regulatory measures on PFAS use in specific consumer product groups.

The full PFAS Plan can be read here.