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The government’s PFAS Plan: “Forever chemicals” - action now?

Leigh Day partner Sarah Moore and her team investigating PFAS pollution share their thoughts on the government's newly released PFAS Action Plan.

Posted on 10 February 2026

On 3 February 2026, the Government released its PFAS Action Plan, which promises to set out a roadmap for future regulatory action and coordinated steps for manufacturers and other stakeholders to reduce the prevalence of PFAS chemicals in the supply chain and environment.

What are PFAS?

PFAS, short for per- and polyfluoroalkyl substances, are coined ‘forever chemicals’ due to the thousands of years they take to break down in the environment. PFOA and perfluorooctane sulfonate (PFOS) are types of PFAS. In 2023, PFOA was classified as carcinogenic to humans by the World Health Organization.

Leigh Day’s investigations into PFAS pollution and government regulatory actions

Lawyers from Leigh Day are investigating the impacts of PFAS pollution. So far, they have represented residents in Bentham in a claim over PFAS pollution from a firefighting foam factory, and are currently investigating pollution from a chemical factory in Thornton Cleveleys which has allegedly impacted residents.

At the beginning of February, an article by ENDS Report [LINK] revealed that residents living near the chemical factory in Thornton Cleveleys had been warned by the local council not to consume eggs produced by animals reared in the area due to dangerously high PFAS levels.

Against this backdrop, the Leigh Day Team were eager to review the Government’s PFAS Action Plan published earlier this month. The Team analysed the “indicative actions” set out in the Plan and have produced a checklist for stakeholders to track the Government’s compliance with its own “to do” list of stated goals.

Promised “indicative actions” include the following: 

Date Action promised
Early 2026 Undertake research on areas of emerging concern relating to PFAS contamination, including in relation to potential stockpiles for current uses. 
Early 2026 Publish a new strategic approach for adding to the UK REACH (regulatory framework for chemicals in the UK) candidate list and consult on this later in the year. 
2026 Launch a consultation on introducing a statutory limit for PFAS chemicals in England’s public supply regulations. 
2026 Carry out PFAS tests on food packaging, like microwave bags and pizza boxes, to trace the presence of PFAS and support future regulatory action. 
End of 2026 Publish a new website to increase public awareness of PFAS and transparency about actions taken by the government. 
2026/2027 Explore how safer alternatives to products containing PFAS chemicals, like sanitary pads and water-repellent clothing, can be developed without the use of PFAS in manufacturing. 
2026/2027 Reduce emissions from industrial sites through new guidance for regulators and site operators on how to handle and dispose of PFAS. 
2026/2027 Improve the monitoring of PFAS chemicals in soils by supporting the British Geological Survey and introducing five new sampling locations in England. 
Expected in 2027 Complete work to consider restrictions on the use of PFAS in firefighting foams. 
By 2027 Develop new guidance for regulators and industries to address legacy PFAS contamination on contaminated land. 
February 2028 Assess the ‘full extent’ of forever chemicals in England’s estuaries and coastal waters for the first time, enabling greater clarity when exploring regulatory action in the future. 
December 2028 Align UK REACH with closest trading partners, particularly the EU. The EU will introduce new rules relating to PFAS in packaging in August 2026 and has been seen to be taking quicker regulatory action than the UK. 

 

Within hours of publication, the plan had already been criticised for a timeline considered by some to be too slow to act on the urgent dangers of PFAS, with the government’s plans to request information being described as "redundant" and "a stalling tactic" by Chem Trust researcher Shubhi Sharma. The PFAS Action Plan has also been criticised for not addressing how many PFAS chemicals are entering the atmosphere and where they are coming from. Professor Patrick Byrne at Liverpool John Moores University, in an interview with the Guardian, said: 

“Simply measuring PFAS concentrations, or increasing monitoring as the plan suggests, won’t solve this problem. What we need instead is to measure PFAS loads – the total amount released from different industries and contaminated sites. This allows us to identify the biggest polluters and target cleanup efforts where they will have the greatest impact.” 

It remains to be seen whether the government will keep to their own timetable and deliver on their promises.  

Leigh Day partner Sarah Moore said: 

‘It is encouraging that the Government is attempting to take action by publishing the PFAS Plan. They are effectively setting out a PFAS “to-do list” which includes some important steps.  However, the timeline, as it stands, appears to lack any real urgency or enforcement actions with protracted consultation phases gathering further information regarding PFAS. This is surprising given that the Government has already spent a year consulting through the EAC PFAS Inquiry.” 

What harms can PFAS cause?

There is emerging evidence that exposure to PFAS can lead to an increased risk of developing serious diseases and some types of cancer, like kidney and testicular cancer. High levels of PFAS exposure can result in the need for phlebotomy, to keep reducing the levels over time and avoid ill health. This is the case in Jersey, where phlebotomy treatment has been recommended for those with high PFAS levels in their blood.

High PFAS exposure has also been linked to high cholesterol levels, which can require medical intervention in the form of colesevelam tablets. As PFAS takes so long to degrade, it is often recommended that those with high exposure undergo regular PFAS blood testing, with multiple blood tests per year to monitor their levels and keep them beneath a safe limit.

What is Leigh Day doing about it?

Leigh Day has a keen interest in environmental litigation and is running several groundbreaking cases in the sector, including the vehicle emissions cases.

As well as its action in Bentham and Thornton Cleveleys, Leigh Day has also provided evidence to the Environmental Audit Committee. In their evidence to the EAC’s inquiry, Leigh Day lawyers raised concerns that the UK is falling behind other countries in the identification, regulation and monitoring of PFAS, and that the Environment Agency lacks the resources to properly monitor contaminated sites.   

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Sarah Moore

Leading environment and product safety lawyer

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