PFAS (per- and polyfluoroalkyl substances) are a group of over 10,000 chemicals internationally recognised for their adverse environmental and human health impacts [1]. They are highly persistent, mobile and can accumulate along food chains to harmful concentration levels [2]. Whilst many PFAS remain understudied, those that have been research in-depth have been connected with significant health concerns, including cancer, immunotoxicity and fertility issues [3], [4], [5]. PFAS continue to be used across a wide range of products, including textiles, cosmetics, food packaging and pesticides. These so called ‘forever chemicals’ now pollute soils [6], waterways [7], wildlife [8] and people across the UK [9].
In response to the growing health and environmental concerns related to PFAS pollution, the EU is currently progressing towards a restriction on all 10,000+ PFAS. Here we outline why a universal PFAS restriction is also essential for the UK.
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With over 10,000 known PFAS [1], addressing them one by one is impractical and has fuelled a cycle of regrettable substitution, where banned PFAS are replaced by structurally similar, unregulated substances from the same family, with comparable potential for harm [10]. This piecemeal approach not only undermines health and environmental protections, it also burdens regulators by requiring individual assessments and creates uncertainty for UK businesses. In fact, our 2021 survey found that some UK retailers have voluntarily adopted group-based approaches to restrict harmful chemicals, citing ‘improving environmental and human health protections’, as well as ‘future proofing against further legislation’ as their primary motivations [11].
The UK’s current definition, as outlined in the Regulatory Management Option Analysis (RMOA) for PFAS [12], covers only several hundred substances, offering a much narrower scope than the definition developed by the Organisation for Economic Co-operation and Development (OECD), which encompasses over 10,000 PFAS. Continuing with this narrow definition therefore risks contributing to further regulatory divergence[13] and additional trade barriers with countries adopting a broader PFAS definition, such as that used within the proposed EU-wide PFAS restriction [14].
Scientists worldwide agree on the need for a broad definition of PFAS, as these chemicals share similar structures that make them extremely persistent in the environment, leading to rising concentrations and growing risks from both known and unknown effects [15], [16]. By adopting a comprehensive definition, the UK can act swiftly to safeguard public health and the environment, and ensure robust, future-proof regulation.
To ensure effective protection from PFAS pollution, fluoropolymers and fluorinated gases (f-gases), must be included in the scope of regulation. These substances are classed as PFAS under the OECD definition [1], and their production, use, and disposal are major sources of PFAS emissions. For example, it is estimated that f-gases are responsible for 63% of all PFAS emissions in the EU[17], [18]. Additionally, between 1950 and 2004, 72% of global emissions of PFOA and PFOS – two extremely harmful PFAS – were linked to fluoropolymer production [19]. These impacts don’t stop at production —studies have shown that disposing of common fluoropolymers like PCTFE through incineration can generate over 50 harmful PFAS by-products [20].
Despite frequent claims that fluoropolymers are of ‘low concern’, this assertion is unfounded and largely based on misinterpreted communications from the OECD. The OECD recently clarified that criteria for ‘polymers of low concern’ were never formally agreed upon and thus are not applicable to fluoropolymers or any other polymer groups [21]. Claims made on this basis are therefore inaccurate and misleading given the harmful PFAS emissions generated throughout fluoropolymer lifecycles [21], [22], [23].
Whilst sector-specific bans could support an immediate reduction in PFAS emissions while broader PFAS restrictions are pursued, alone they are not enough. For example, the recently announced French restriction on PFAS in cosmetics, clothing and ski waxes offers a great way to begin reducing emissions whilst the EU universal PFAS restriction is in progress. However, it has been estimated that, should the French ban be implemented on an EU scale, this would still only account 20% of PFAS emissions [24].
Many sector-specific regulation also fail to consider the full spectrum of impacts throughout a product’s lifecycle. For example, food packaging, which falls under the Food Standards Agency (FSA) and Food Standards Scotland (FSS), focus primarily on the health impacts of packaging materials rather than the environmental pollution created throughout production or disposal of these items[25]. This therefore can also overlook contamination within the circular economy, given many food packaging items containing PFAS in the UK are marketed as recyclable and compostable[26]. Similarly, the UK’s current fluorinated gases (f-gas) regulation focuses solely on climate-warming potential and fails to consider the presence of persistent and harmful PFAS [27]. Many f-gases are a major source of PFAS pollution, even though numerous PFAS-free natural refrigerants—such as CO₂ and ammonia—are already widely available, safe, and cost-effective[18], [28], [29], [30]. A comprehensive, group-based approach to PFAS regulation is necessary to close these gaps, ensure consistency across sectors, and deliver robust, long-term protection for both people and the environment.
We now have nearly a century of research into the properties and behaviour of PFAS. What is already clear—and has been for decades—is that PFAS are, by definition, highly persistent in the environment. This persistence, combined with their mobility and bioaccumulative nature, makes their continued use inherently high-risk, especially as those PFAS that have been studied in-depth have been associated with significant health concerns [31].
While ongoing research has value, further studies confirming existing trends should not be a prerequisite for action; scientific experts are clear on this as outlined in a recent letter to UK Government [32]. Instead, future research should operate within the framework of a precautionary approach and a universal PFAS restriction, shifting the burden of proof to demonstrate safety rather than harm. Environmental monitoring offers valuable insights into the continuous state of PFAS pollution but should not be used as a justification for delaying action. The widespread use and persistence of PFAS mean that most ecosystems are on a worsening trajectory of contamination. Delayed regulatory action risks causing further, potentially irreversible, environmental damage.
Given that PFAS cover over 10,000 substances, we do not have sufficient resources to continue our existing approach of reviewing each substance on a case-by-case basis. Instead, resources should prioritise a group-based approach to source control and investment into safer alternatives. These efforts also present long-term economic and trade advantages by fostering innovation and aligning with global regulations.
The characteristic carbon to fluorine bond found in PFAS is one of the strongest bonds in organic chemistry and makes them alike in the fact that they are extremely resistant to environmental breakdown. This means that the continued use of these chemicals will inevitably result in widespread and long-lasting environmental contamination of PFAS [16]. Increasing concentrations of ‘forever chemicals’ in the natural resources on which we depend, such as water and soil, will ultimately increase public exposure, worsen known health effects, and increase the risk of wider effects not yet fully understood [33]. PFAS pollution is also incredibly difficult to reverse, as remediation is technically challenging, energy intensive and costly [34]. Costs of PFAS cleanup in the UK are estimated at £9.9bn a year if restrictions are not introduced [35]. Leading scientists agree – as demonstrated in a prominent letter to the UK Government in 2024 [32]– the persistence of PFAS alone is cause for significant concern and supports calls for a universal PFAS restriction.
PFAS are extremely difficult to destroy because of their resistance to degradation. Incineration or pyrolysis are the most frequently touted approaches for destroying of PFAS in waste. However, the success of these approaches depends on numerous factors such as the feedstock, temperature, or chemical structures of the PFAS involved [36]. The complete breakdown (mineralisation) of PFAS can only occur at temperatures >1000 °C [37], [38], and even then, PFAS residues have still been found in the outputs of incinerators operating at these temperatures [38]. Incineration is also energy intensive, especially for high temperatures, and can release further PFAS emissions if conditions are not optimal, resulting in multiple environmental trade-offs [39].
In landfill, some PFAS can partially breakdown into other, sometimes more hazardous PFAS and leach into the surrounding environment. For example, in the UK there are suggestions that landfilling of PFAS-containing products is leading to the formation of the banned forever chemicals, PFOA and PFOS [40]. Once in the environment, PFAS are extremely difficult and costly to clean up. In the Netherlands, removing just 34g of PFAS from groundwater cost over 1 million euros [41]. In the UK, PFAS remediation is estimated to cost up to £9.9bn a year should a restriction not be introduced [16], [35].
Recycling PFAS-containing products is also problematic and risks contamination of materials and PFAS becoming locked into the circular economy, threatening the UK’s broader growth and sustainability targets [42].
With this in mind, it is imperative to prevent further production of PFAS waste by introducing a group-based restriction and supporting uptake of sustainable alternatives.
Many PFAS-free alternatives are readily available across numerous sectors. For example, Denmark introduced a restriction on PFAS use in paper and board food packaging back in 2020, with PFAS-free food packaging items being available for many years [43], [44], [45]. In fact, a 2025 study identified 530 functional PFAS-free alternatives that already exist, acknowledging that this is just a minimum estimate and is likely to grow significantly over time [46]. Over 100 companies, including IKEA, H&M, Ralph Lauren and New Balance have signed up to ChemSec’s ‘No to PFAS’ movement [47], and industries such as semi-conductors [48], solar cells [49] and lithium-ion battery sectors [50] are also exploring PFAS-free alternatives. A universal PFAS restriction would therefore not only help reduce exposure to people and the environment, it would also present a strategic opportunity for the UK to lead in innovation and support economic growth.
Implementation periods could also allow for innovation of alternatives where they are not yet readily available, ensuring critical services continue while the country transitions toward a fully PFAS-free economy [51]. Progress in other countries shows the direction of travel is clear, the UK must take advantage of this opportunity and ensure we are leading the way in the transition to a PFAS-free society.
A group-based restriction is required to avoid regrettable substitution of one PFAS with another. Safe and feasible alternatives to many PFAS already exist [52], and numerous sectors are transitioning to PFAS-free solutions. For example, green sector technologies like PFAS-free natural refrigerants, such as CO₂ and ammonia, are widely available, cost-effective, and increasingly used to replace PFAS-based fluorinated gases [53], [54], [55]. Clear regulatory commitments to phase out PFAS will create a level playing field for UK businesses, support existing voluntary action and boost further innovation and production of sustainable alternatives.
Steps can also be taken to improve the safety and sustainability of other chemicals on the market. This could include phasing out known chemicals of concern, such as persistent substances and endocrine disrupting chemicals (EDCs). This is currently being pursued in the EU [56], with targets set to restrict the most harmful substances and to boost investment into the design of safe and sustainable chemicals [57]. Aligning UK chemical regulations with these world leading standards would support the broader phase-out of harmful chemicals, helping to prevent continued cycles of regrettable substitution, and ensure the safety of products. To future-proof regulatory efforts, this should be coupled with improved chemical transparency along supply chains to help identify contaminated substances should new toxicity data be published throughout the lifespan of products already on the market. This would also support efforts towards a clean and sustainable circular economy.
Although PFAS are often touted for their durability, their presence does not necessarily increase a product’s lifespan. In fact, PFAS are often unnecessarily used in short-lived or single-use items like food packaging [58]. A grease-resistant cardboard container coated with PFAS may offer short-term convenience but is discarded within minutes. The PFAS it contains however could persist in the environment for hundreds of years [59].
Even in longer-lasting products, PFAS don’t always lead to a lengthier product life. For example, PFAS can be added to school uniforms for their stain resistant properties, supposedly enhancing the longevity of garments [60]. Yet, in a Fidra survey of over 600 parents and guardians, we found no significant difference in how often school uniform items were replaced in relation to stain-resistant treatments [61]. Many PFAS are also lost from products throughout their use, contaminating indoor environments with PFAS-laden particles and fibres, and contributing to wider PFAS pollution [62], [63].
A PFAS restriction in the UK will require industries to adapt and shift toward innovative, PFAS-free alternatives. As seen in sectors such as renewable energy [64] or the electric vehicle market [65], this kind of transition can unlock long-term, sustainable growth. The UK is not a large manufacturer of PFAS — as of 2021 only two UK-based companies made ‘forever chemicals’ themselves [66]. As a result, the vast majority of PFAS used in the UK are likely imported or already embedded in products. This contrasts with other EU countries such as France and Germany, that have 5 and 6 large PFAS manufacturers, respectively [35]. A dependence on a PFAS supply chain, rather than PFAS manufacture, means that UK industries may be in a better position to transition away from PFAS or even lead innovation in the PFAS-free sector.
PFAS pollution is also eroding the UK’s natural capital, undermining the ecosystems that support economic activity and public well-being. Rivers and wildlife across the UK, including otters, harbour porpoises, and seabirds, have all been found to be contaminated with PFAS[67]. Between 2014 and 2018, 46% of English rivers failed the Water Framework Directive threshold for PFOS [68], and the River Mersey has some of the highest recorded levels of PFOS and PFOA globally[69]. As highlighted in the Dasgupta Review, such environmental damage should be treated as a depreciation of the natural assets our economy depends on [70]. Continued contamination risks weakening the long-term productivity and resilience of sectors reliant on healthy soils, clean water, and biodiversity.
With many PFAS-free alternative products now widely available [43], [46], the UK has an opportunity to drive further innovation in this sector and support businesses in developing and adopting sustainable alternatives. Crucially, the long-term costs of environmental remediation should also be factored into economic impacts—UK cleanup costs are estimated at £9.9 billion per year if restrictions are not introduced [35], which doesn’t include economic losses incurred due to loss of natural resources. The wider healthcare costs are also expected to be significant, with PFAS-associated health costs projected to cost the EU 84 billion euros annually [71].
Consumers cannot opt out of PFAS exposure. Whilst it should not be the responsibility of the public to seek out products free from harmful chemicals, lack of chemical transparency makes it near impossible for those wishing to do so. There is very limited information available on chemicals used in products, and so identifying PFAS-free products can be a near impossible task. As these chemicals are so abundant in our environment, PFAS exposure is inevitable via the air we breathe[72], the water we drink[73] and food we eat[74] and so cannot be consciously avoided regardless of purchasing choices.
The idea that individuals can protect themselves through purchasing decisions alone also assumes equal access to time, resources, and information, which is not the case. The only effective way to ensure equal access to PFAS-free products is to phase PFAS out of use through a comprehensive, group-based restriction. This approach creates a level playing field for all consumers, regardless of income or awareness.
Chemical transparency can offer a complimentary mechanism to ensure long-term safety of product use and disposal, as well as supporting a consumer’s ‘right to know’. However, it is not a substitute for restricting harmful chemicals and should not be used to justify a reliance on consumer choice to prevent PFAS and wider chemical pollution.
While there is no clear evidence that a group-wide PFAS restriction would significantly increase costs for consumer products, there is mounting evidence that continued reliance on PFAS will impose substantial financial burdens on taxpayers through remediation and healthcare.
Many sectors have already begun moving away from PFAS, such as food contact materials[75], refrigerant gases[30], and waterproof clothing[76], demonstrating that safer, cost-effective alternatives are both available and scalable [52]. Innovation is underway and regulatory clarity will only accelerate market confidence and investment in cleaner technologies, presenting a clear opportunity for growth. This is reinforced by a recent call from investors, managing over US$8 trillion in assets, urging chemical producers to phase out PFAS [77], [78], [79]. The price for continuing to rely on PFAS however is significant. Research estimates clean-up costs for PFAS pollution could reach up to £9.9 billion per year in the UK should restrictions not be introduced[80], [81]. In addition, a report prepared for the Environment Agency estimated that remediating high-risk PFAS contamination sites in England could cost between £31 billion and £121 billion[82]. In Europe, the healthcare costs linked to PFAS exposure are estimated at €52–84 billion annually [71]. A group-based PFAS restriction would therefore drive innovation and growth for alternatives, as well as reducing long-term healthcare and remediation costs, ensuring a more sustainable and economically resilient future for both businesses and consumers.
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