United Kingdom, PFAS Regulation: New Approach Based on Persistence and Mobility

On 4 June 2025, the UK Department for Environment, Food and Rural Affairs (Defra) introduced a new policy aimed at strengthening the risk management of perfluoroalkyl substances (PFAS), adopting an interim approach focused on PMT characteristics . (Persistent, Mobile and Toxic) and vPvM (Very Persistent and Very Mobile).

This approach represents a significant shift from the traditional model based exclusively on PBT (Persistent, Bioaccumulative and Toxic) and vPvB (Very Persistent and Very Bioaccumulative) criteria, recognizing that some PFAS, although not fully conforming to these schemes, still represent a considerable risk due to their high persistence and ability to move in the environment.

Table of contents

1. Why a new approach?

2. A tool for prevention

3. Towards more preventive regulation

United Kingdom, PFAS Regulation: New Approach Based on Persistence and Mobility

Why a new approach?

PFAS are substances widely used in industrial and consumer applications that, due to their chemical structure, degrade very slowly in nature. This persistence, coupled with their high mobility, facilitates their presence in groundwater, aquatic ecosystems, and even remote regions, far removed from their original sources. However, many of these substances escape regulatory restrictions because they do not show significant bioaccumulation or demonstrated toxicity, despite their constant presence in the environment.

The new PMT/vPvM conceptual framework seeks to fill this gap, allowing for the identification and prioritization of substances that, while not falling into the current categories, require further risk assessment and potential regulatory action. In particular, this methodology could be applied in the preparation of restriction dossiers under REACH in the United Kingdom, providing additional criteria to justify their control.

A tool for prevention

This development does not yet entail a regulatory change: the formal PMT/vPvM criteria have not yet been officially incorporated into the UK REACH Regulation or its equivalent classification system (GB CLP). However, Defra has indicated that the concept will serve as a basis for future assessments and will allow risk management to be adapted to cases where existing models are insufficient.

The United Kingdom has also confirmed its active participation in the discussions of the United Nations Globally Harmonized System (GHS), where the international inclusion of this category as a new hazard class is being discussed. If the GHS approves its inclusion, the United Kingdom could consider its implementation in national legislation.

Towards more preventive regulation

The development of the PMT/vPvM concept represents a step toward a more preventive chemical policy, aligned with the emerging challenges of environmental pollution. With this measure, the United Kingdom seeks not only to better manage current risks but also to anticipate future crises arising from the global dispersal of extremely persistent substances.