A group of 59 UK and international scientific experts have written to the UK Government calling for tighter regulation of the use of per and polyfluoroalkyl substances (PFAS). Concern from scientists stems from the strong persistence of these so called ‘forever chemicals’ [1], their widespread uses throughout society [2], [3] and their demonstrable negative impacts on human health and our environment [4],[5]. The letter states that the scope of current UK regulation is too narrow, increasing the potential to trigger negative health and environmental outcomes. We support their asks for the regulation of all PFAS as one group and urgently call on the UK Government to align with the EU’s proposed universal PFAS restriction.
The letter highlights the following key points:
- PFAS pollution in the UK is a serious and widespread problem, with significant environmental and health risks, and high costs of remediation.
- The current UK definition for PFAS is too narrow and will not provide effective protection from this large group of chemicals.
- Aligning with the EU’s universal PFAS restriction is the best way to tackle PFAS pollution in the UK and prioritise human health and the environment.
- PFAS alternatives already exist and the transition to a PFAS-free economy can promote economic growth and drive innovation.
Why using a broad definition for PFAS is essential for effective regulation
The Organisation for Economic Co-operation and Development (OECD) has defined over 10,000 PFAS [6]. However, the UK’s Regulatory Management Option Analysis (RMOA) [7] published in 2023, uses a far narrower definition of PFAS, encompassing only a few hundred substances. The letter outlines how this leaves regulatory efforts vulnerable to ‘regrettable substitution’, the replacement of restricted PFAS, with other PFAS that fall outside of scope for regulation but are likely to be equally harmful. Scientists argue that the assumption that the absence of evidence of harm means no harm exists is illogical, especially given the wide-ranging health impacts already shown from a limited number of PFAS studied [8].
“Regulating just a few hundred PFAS will not tackle the scale of pollution we face from these chemicals.”
We agree that the scientific evidence demonstrates an urgent need for stronger PFAS-wide regulation in the UK. At present, PFAS can pose risks from a wide variety of sources, from the manufacture, use and disposal of PFAS-containing products such as food packaging [9], textiles[10] and cookware [11], to their direct addition to our food, soil or and water sources through pesticides and sewage sludge. We therefore support calls for the UK Government to adopt the OECD definition of PFAS to ensure regulatory efforts are effective and offer true protection for public and environmental health.
Lack of UK action means weaker protections for people & the environment
The letter outlines the EU’s proposed ‘universal’ restriction for PFAS, which takes a broad, group-based approach aligning with the OECD definition, and argues that the UK needs to do the same. Other EU countries have already proposed to act on PFAS ahead of an EU restriction, with both France [12] and Denmark [13] imposing restrictions on PFAS in certain products in just two years’ time. Despite this, there are currently no commitments from the UK Government to follow the example that is being set in the EU.
“The EU takes a broad grouping approach to PFAS based on their extreme persistence and ubiquitous presence in the environment, combined with other hazardous properties that trigger additional concerns.”
Given the serious impacts associated with this group of chemicals, we cannot risk waiting to see further negative effects of PFAS in the UK before tightening regulations. We therefore support calls for the UK to take “a more ambitious approach to regulating PFAS”, in the form of whole-group restriction, as the only option to fully prioritise human and environmental health.
The transition to a PFAS-free economy means innovation and opportunities
Fortunately, scientists note that there is already a strong evidence base for the use of PFAS alternatives, with many PFAS-free solutions readily available across numerous sectors, from wind turbines and electric vehicles [14] to food packaging and textiles [14], [15].
“A PFAS ban would open great market potentials for PFAS alternative suppliers and reward companies that have already invested in alternative technologies.”
In many cases, eliminating PFAS from products can cut costs and it is clear that stronger regulation could provide opportunities for innovation. We now need the UK Government to show leadership and support this innovation through stronger regulation of PFAS.
To find out more, read the full letter sent to the UK Government by leading scientists. You can help to push for tougher PFAS restrictions in the UK by writing to your MP and make sure you stay up to date with latest PFAS developments through following us on social media.
References
[1] I. T. Cousins et al., “The high persistence of PFAS is sufficient for their management as a chemical class,” Environ Sci Process Impacts, vol. 22, no. 12, pp. 2307–2312, 2020, doi: 10.1039/D0EM00355G.
[2] Pesticide Action Network UK, “PFAS: The forever chemicals.” Accessed: Nov. 13, 2024. [Online]. Available: https://www.pan-uk.org/pfas-forever-chemicals/
[3] J. Glüge et al., “An overview of the uses of per- and polyfluoroalkyl substances (PFAS),” Environ Sci Process Impacts, vol. 22, no. 12, pp. 2345–2373, 2020, doi: 10.1039/D0EM00291G.
[4] Z. Habib, M. Song, S. Ikram, and Z. Zahra, “Overview of Per- and Polyfluoroalkyl Substances (PFAS), Their Applications, Sources, and Potential Impacts on Human Health,” Pollutants, vol. 4, no. 1, pp. 136–152, Mar. 2024, doi: 10.3390/pollutants4010009.
[5] M. N. Ehsan, M. Riza, Md. N. Pervez, M. M. O. Khyum, Y. Liang, and V. Naddeo, “Environmental and health impacts of PFAS: Sources, distribution and sustainable management in North Carolina (USA),” Science of The Total Environment, vol. 878, p. 163123, Jun. 2023, doi: 10.1016/j.scitotenv.2023.163123.
[6] Organisation for Economic Co-operation and Development (OECD), “Reconciling Terminology of the Universe of Per- and Polyfluoroalkyl Substances.” Accessed: Nov. 13, 2024. [Online]. Available: https://www.oecd.org/en/topics/sub-issues/risk-management-risk-reduction-and-sustainable-chemistry.html.
[7] UK Health and Safety Executive, “Regulatory management option analysis (RMOA).” Accessed: Nov. 13, 2024. [Online]. Available: https://www.hse.gov.uk/REACH/assets/docs/pfas-rmoa.pdf
[8] “Per- and Polyfluoroalkyl Substance Toxicity and Human Health Review: Current State of Knowledge and Strategies for Informing Future Research,” Environ Toxicol Chem, vol. 40, no. 3, pp. 606–630, Mar. 2021, doi: 10.1002/ETC.4890.
[9] A. R. Carnero, A. Lestido-Cardama, P. V. Loureiro, L. Barbosa-Pereira, A. R. B. de Quirós, and R. Sendón, “Presence of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) in Food Contact Materials (FCM) and Its Migration to Food,” Foods 2021, Vol. 10, Page 1443, vol. 10, no. 7, p. 1443, Jun. 2021, doi: 10.3390/FOODS10071443.
[10] S. Schellenberger et al., “An Outdoor Aging Study to Investigate the Release of Per- and Polyfluoroalkyl Substances (PFAS) from Functional Textiles,” Environ Sci Technol, vol. 56, no. 6, pp. 3471–3479, Mar. 2022, doi: 10.1021/ACS.EST.1C06812/ASSET/IMAGES/LARGE/ES1C06812_0006.JPEG.
[11] N. Wolf, L. Müller, S. Enge, T. Ungethüm, and T. J. Simat, “Analysis of PFAS and further VOC from fluoropolymer-coated cookware by thermal desorption-gas chromatography-mass spectrometry (TD-GC-MS),” Food Additives & Contaminants: Part A, 2024, doi: 10.1080/19440049.2024.2406007.
[12] ministre de la transition écologique et de la cohésion des territoires de france, “Ministerial Action Plan on PFAS.” Accessed: Nov. 14, 2024. [Online]. Available: https://www.ecologie.gouv.fr/sites/default/files/documents/22261_Plan-PFAS.pdf
[13] Danish Ministry for the Environment, “Update of the National Implementation Plan (NIP) for the Stockholm Convention on Persistent Organic Pollutants (POPs) 2024.”
[14] ChemTrust, “Frequently Asked Questions: PFAS and the green transition.” Accessed: Nov. 14, 2024. [Online]. Available: https://chemtrust.org/wp-content/uploads/FAQ-Green-Transition-2024-1.pdf
[15] Fidra, “PFAS Free Products.” Accessed: Nov. 14, 2024. [Online]. Available: https://www.pfasfree.org.uk/pfas-free-products#food-packaging