Angling Trust                            PFAS0050

Angling Trust Response: Environmental Audit Committee Call for Evidence.

Addressing the risk of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

The Angling Trust

The Angling Trust are recognised by Government as the national governing body for angling in England, and we partner with Visit Wales and Natural Resources Wales to promote fishing in Wales. We are a not for profit organisation, representing anglers, fighting for fish, fishing and the environment.

The Scale of the Problem

Per- and polyfluoroalkyl substances (PFAS) represent a major threat to the environment, wildlife and environmental targets to achieve good status and secure nature recovery. They constitute a vast and complex class of synthetic organofluroine chemicals, with some 4,700[1] and potentially up to nearly 15,000[2] chemicals currently available around the world. Used since the 1940-50s, PFAS are applied in a variety of products and industries from non-stick coatings on cookware, water-resistant packaging through to fire-fighting foam, and the production of certain plastics and polymers. The threat from PFAS is that they contain multiple carbon-fluorine (C-F) bonds, which are among the strongest known chemical bonds in organic chemistry. This exceptional bond strength gives high chemical and thermal stability but also makes these ‘forever chemicals’ highly resistant to degradation in the environment, enabling them to persist for exceptionally long periods. It is this persistence and their increasing accumulation in our rivers, lakes and oceans which represents a major, ever-growing threat to the environment, wildlife and human health.

Monitoring by the Environment Agency (EA) has revealed the pervasive nature of PFAS in English aquatic environments. Some PFAS such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) have largely been phased out or restricted in the UK, EU and US due to health and environmental concerns. However, detectable levels of PFOS were detected at over 99% of surface water samples, and detectable levels of PFOA in over 99% of sampled freshwater sites and over 96% of estuarine and coastal sites[3] .The extremely low Environmental Quality Standard (EQS) set for PFOS (0.65 ng/L annual average in freshwater) under the Water Framework Directive (WFD) means that its widespread presence at concentrations above this level results in a technical failure to achieve "good chemical status" for virtually all English rivers.

Similarly, groundwater monitoring has confirmed the presence of PFAS, with one-fifth of the sampled sites containing at least seven different PFAS chemicals[4]. This includes PFAS that are not currently registered under UK REACH.

PFAS and their Impact on the Environment

PFAS can enter the environment through various pathways linked to their production, use and disposal. This includes their use in industrial facilities, aqueous film-forming foams (AFFFs), leaching from landfill, effluent discharges from wastewater treatments plants (WWTPs) and the application of contaminated sewage sludge from WWTPs.

Once released, their resistance to biological, chemical, and physical degradation ensures their persistence in soil, water (surface water, groundwater, estuaries and coastal), and potentially air[5]. Many PFAS are mobile in the environment, particularly the more water-soluble shorter-chain variants, allowing them to travel significant distances through the water environment leading to widespread contamination[6].

PFAS bioaccumulate in the tissues of wildlife and humans. This process can lead to biomagnification, where concentrations increase at higher trophic levels in the food web. This has been evidenced in various wildlife species in the UK and globally including fish, mammals[7] and birds demonstrating exposure across food webs.

Freshwater and Marine Impacts

The impacts of PFAS have been widely reported in freshwater and marine wildlife including fish species[8]. PFAS are persistent, bioaccumulative chemicals that can impair aquatic organisms. Laboratory and field studies (globally) link PFOS/PFOA to liver damage, endocrine disruption, reduced fertility and negative developmental effects in fish. PFAS contamination undermines Good Environmental Status (GES) goals for UK seas. PFOS in sediments exceeds ecotoxic thresholds (protective of 99% of benthic invertebrates) at some English sites. This means marine worms and shellfish near PFAS hotspots may suffer harm. In higher trophic levels, wild apex predators show PFAS burdens: long-term monitoring found PFOS dominating the PFAS profile in UK gannet eggs. The implication for marine fish stocks is that PFAS likely affect reproduction and survival across the food web, potentially reducing fish health and abundance over time.

Persistent PFAS may also impair commercially important species (cod, flatfish, etc.), though UK-specific fish toxicity data are lacking. At minimum, PFAS in sediment and plankton could translate into contaminated prey for fish. The Angling Trust is especially worried that PFAS could undermine the recovery of marine fish stocks by contaminating nursery grounds and reducing reproductive success.

Similar worrying levels of PFAS have been reported in freshwater environments and species[9]. At two-thirds of the sites sampled by the EA, concentrations of PFOS in freshwater were found to exceed the proposed EU new safe levels by more than 100 times, with fish from one river recording levels more than 1000 times the proposed EU EQS. Critically, this analysis was only undertaken on one forever chemical. Therefore, there may be many more chemicals that exceed safety limits. With the possible interactive, and exacerbating impacts of multiple forever chemicals as outlined above, this presents a growing toxic time bomb that requires urgent attention.

UK Case Studies of Freshwater and Marine PFAS Contamination

• Sewage and Stormwater Overflows: Sewage discharges are a major PFAS source in coastal seas. In the SSSI, SPA and Ramsar site Langstone Harbour, Hampshire scientists sampled water before and after a storm overflow from Budds Farm wastewater treatment work plant (WWTP)[10]. PFAS levels rose dramatically after discharge: only one PFAS compound was detectable before, but eight different PFAS were found after, including PFOS and PFOA at concentrations exceeding safe water standards. Seaweed collected near the outfall had PFBA up to 6,000× the surrounding water, suggesting coastal macroalgae can capture and concentrate PFAS, posing risks up the food chain. These findings indicate that millions of hours of untreated sewer overflows (ESA: 3.6 million hours in 2023) inject PFAS into estuaries and bays, and that current UK targets to eliminate harmful discharges must address PFAS specifically.
• Industrial Discharges: At the AGC Chemicals site near the Wyre Estuary (Lancashire), Environment Agency data show the plant discharges large volumes (~783kg per year) of a novel PFAS (EEA‑NH₄) into the River Wyre in 2022, water monitoring revealed extremely high PFAS concentrations (12,000 ng/L of PFOA) in effluent from that site. Although these discharges were within permit limits, they introduced “very persistent” and toxic PFAS into downstream marine waters. Notably, fish in the Wyre have recorded extraordinarily high PFAS: flounder contained up to 11,000 ng/kg – hundreds of times above background. This illustrates how even point-source releases can contaminate coastal food webs: local anglers catching flounder or other fish in the Wyre estuary would risk ingesting high PFAS levels.
• Firefighting Contamination: An EA commissioned report by WSP in Feb 2024 performed sampling at 10 points surrounding the Fire Service College in Moreton-in-Marsh. PFOS levels were consistently above the EQS 0f 0.65 ng/l, with the highest reading of 1,320ng/l taken at the Fire Service College stream – more than 2,000 times the EQS. This study informed Cotswold District Council’s consultation on the building of 310 homes on the Fire Service College’s grounds. With the significant risks to human health associated with these levels of PFOS contamination, the EA’s monitoring capacity must be greatly expanded to provide this essential information for all planning processes, where risks to human health are posed, especially in areas near to known polluters such as fire services.

Impact on Human Health

We are supportive of Blueprint’s response which has outlined the health risks from PFAS. In addition to this, a particular concern we wanted to highlight is the direct risk to people who eat seafood – including recreational anglers. PFAS in fish can transfer to humans, and health authorities have set extremely low safety thresholds. For example, the European Food Safety Authority’s new tolerable intake is 0.0044 μg/kg bodyweight per week for key PFAS (PFOA, PFOS, PFNA, PFHxS). Studies indicate such levels are easily exceeded by contaminated fish[11]. One US study found that a single portion of contaminated freshwater fish could equate to drinking PFAS‑polluted water every day for a month. In other words, regularly eating fish from a PFAS‑impacted waterbody might far exceed safe exposures. UK freshwater fish have already been shown to contain PFOS hundreds of times above proposed EU safety values[12]. For recreational sea anglers, where catch to take represents an important aspect of the sport, the consumption of marine fish could present similar risks. However, with no routine testing, the scale of this issue remains unknown. The UK Government has a responsibility to safeguard public and environmental health but at present the UK has no specific PFAS food standards. Research and monitoring are urgently needed to establish the extent of this risk to human health.

Need for Stronger Regulation

UK Reach

The current regulatory regime for the use and disposal of PFAS is inadequate. Since our departure from the EU, the UK has not kept pace with advances in regulation on PFAS 1.

For example, the EU is pursuing a broad 'universal’ restriction on thousands of PFAS based on persistence. This would prohibit the manufacture, use and sale of a significant proportion of PFAS. The UK’s approach is currently more targeted, focused on specific uses through the RMOA process. The UK REACH assessment needs to be urgently accelerated and for more regulatory ambition and pace to the UK’s approach to PFAS. This includes adopting group strategies based on chemical structure and persistence rather than relying solely on substance-by-substance assessments.

Linked to this, there is an urgent need for a more precautionary approach to the restriction of PFAS, to ban the use of multiple PFAS based on groups rather than individual chemicals. Unless the former is adopted, there is the risk of continual replacement, with the ‘phasing out’ of certain PFAS resulting in the use of other PFAS such as shorter-chain variants or fluorinated alternatives.

We welcome the UK government’s decision to completely ban PFOA in firefighting foams on 4th July 2025. However, there remains no legal restrictions on C6 fluorotelometer-based extinguishers, and insufficient understanding of the pathway to reduce, or eliminate forever-chemical pollution from firefighting, which is a major contributor to the problem. The UK REACH undertook a consultation on PFAS firefighting foam which closed on the 24th of June 2024. The response was due in March 2025 but has not yet been published. We urge for the outcomes of this consultation to be published to inform decision-making on this issue.

PFAS and sewage treatment

Sewage treatment plants do not routinely remove PFAS. In practice, UK policies still largely treat PFAS as novel pollutants rather than priority hazardous substances – a shortfall in protection. In contrast, The EU recently revised its laws to introduce a ‘polluter pays’ principle with industries such as pharmaceuticals and cosmetics that cause chemical pollution funding their removal from wastewater treatment plants.  The UK needs to explore a similar approach to secure the urgently needed monitoring and treatment of PFAS from WWTPs, which represent major sources in aquatic environments (see our case studies for an example).

The Environment Agency and devolved bodies must be empowered and resourced to enforce new PFAS controls. Enforcement will require significant expansion in monitoring and surveillance, both in the environment (water, wastewater, soil, and sludge) and through biomonitoring programs to track PFAS exposure in humans and wildlife.

Drinking Water

In August 2024, the Drinking Water Inspectorate set a new limit of 100ng/L as ‘high risk’ for the cumulative total of 48 types of PFAS. However, this is a voluntary standard. In comparison, the EU drinking water and food standards for PFAS are more stringent (e.g. total PFAS limit in water of 0.5 µg/L). The US EPA is also moving to tighten PFAS standards in drinking water (final national limits of 4ng/L for PFOS/PFOA). The UK should follow the best practices being implemented elsewhere and set legal ambitious drink water requirements.

Environmental Improvement Plan

The UK’s Environmental Improvement Plan (2023) outlined the need for stronger PFAS controls. The EIP 2023 committed to an overarching Chemicals Strategy that explicitly mentions PFAS as priority emerging group of persistent chemicals of concern, alongside endocrine disruptors. It was announced in May 2025 that the government has scrapped the Chemical Strategy, but a future approach will be outlined within the new EIP. The EIP is currently under review and will be published shortly. It is vital that this new strategic approach includes a comprehensive risk‑based regulatory approach to chemicals and incorporates the precautionary and polluter pays environmental principles to restrict and monitor multiple groups of PFAS.

Monitoring, Research and Innovation

Monitoring predominately focuses on PFOA, PFOS and the 48 substances stated in the Drinking Water Inspectorate (DWI) guidance. However, there are thousands of other chemicals which remain largely unmonitored. There is also the absence of a comprehensive, publicly accessible inventory detailing the sources, locations, types and quantities of PFAS being used and released into the environment. This represents a significant gap in data to understand the full extent of the problem in the UK. It will also limit the ability to implement robust measures and policies to achieve environmental targets such as ‘good’ status under the WFD.

The UK’s Marine Strategy (under the Marine Strategy Regulations 2010) requires achievement of Good Environmental Status (GES) in UK seas. Descriptor 8 of GES (Contaminants) demands that anthropogenic pollutant levels (including PFAS) do not cause harm. The 2025 Programme of Measures explicitly acknowledges PFAS as emerging chemicals of concern. Whilst this recognition is welcome, the strategy’s measures focus on broad pollutant controls (oil spills, mercury, CSO reduction) and only general monitoring of “emerging contaminants”. Notably, UK marine fish are not currently required to be routinely tested for PFAS beyond the limited biota surveys noted above. In comparison, in the US, the Environmental Protection Agency (EPA) guidance (July 2024) explicitly adds PFAS to the list of contaminants for fish consumption advisories. Many US states now test freshwater (and increasingly coastal) fish for PFAS and issue public health warnings, recognising PFAS in fish as a significant exposure route. To meet GES, the UK must apply more targeted measures to PFAS sources (e.g. storm overflows, industrial effluents) and ensure marine fish monitoring for PFAS specifically adopting approaches such as NOAA PFAS national screening for marine wildlife. Research is also needed to understand the full effects of PFAS in marine environments and on fish health. Otherwise PFAS will continue to violate GES objectives despite nominal compliance with other standards.

There is also an urgent need to continue support for innovative treatment R&D (such as the UK cavitation reactor) but also pilot proven technologies on a scale. Some US utilities use granular activated carbon or reverse osmosis to reduce PFAS; the US Department of Defense is investing heavily in PFAS cleanup at military sites. The UK can learn from this to invest in proven water treatment approaches. The scale of PFAS cleanup challenge means governments must also procure and deploy existing technologies (e.g. activated carbon filters, high-temperature incineration under strict controls, plasma or electrochemical systems being tested elsewhere) to remove PFAS from discharges. Public funding for such innovation and infrastructure (as seen in the US and EU green deal initiatives) will be needed.

The transformation of sewage sludge into green energy shows promise of an effective solution to reduce the spreading of sludge onto agricultural land and use a waste product to drive the transition to net zero. Technologies like pyrolysis and hydrothermal oxidation could transform sewage sludge from being a major contributor to PFAS pollution to a major economic and environmental asset.

Pyrolysis has shown great promise for treating sewage sludge by transforming it into bio-char, bio-oil and syngas. Rather than spreading PFAS-rich sludge onto fields directly, these outputs can be used to produce energy. Ofwat’s funding of Cranfield and several water companies to test the viability of this emerging process is welcomed. However, there are a number of risks. Namely, it is extremely energy-intensive and destroys useful materials at the same time as the contaminants.

It must be understood that there will not be a silver bullet technology for the treatment of PFAS pollution. A balance must be found between transforming sewage sludge and transforming the sewage treatment process itself. Recent research at Oxford Brookes University developed a hydrodynamic reactor, which was tested at Hammarby Sjostad wastewater treatment plant in Sweden and achieved a 36% degradation rate of 11 PFAS chemicals in just 30 minutes, without the need for additional chemicals. Greater funding for research and innovation is needed to accelerate the development of technologies which have shown promise to remove PFAS at the point of sewage treatment, and sludge treatment.

Conclusions and Recommendations

The Angling Trust is deeply concerned that PFAS pollution is already impacting UK aquatic environments, fish and anglers. We urge the Committee to recommend:

• Enhanced monitoring: Monitoring for PFAS is ad hoc and patchy. Need for adequate resourcing for the Environment Agency to enable enhanced, routine testing for PFAS and other chemicals to establish risk and document progress on reduction. Mandate regular testing of commercially and recreationally caught marine fish for a broad suite of PFAS and include PFAS in the new storm overflow assessment.
• Precautionary regulation: The UK government must stop PFAS at its source. Follow the precautionary principle and move beyond a purely “risk‑based” stance to restrict non‑essential PFAS uses (in line with UK REACH RMOA advice and EU/US precedent). Restrictions should also be applied to PFAS groups rather than individual chemicals.
• Legislative integration: Ensure PFAS control is integrated into all marine and water legislation. The upcoming UK Water Framework Directive monitoring (CIP4) should include PFAS in estuaries. The UK Marine Strategy and EIP must explicitly target PFAS under their hazardous substances goals (GES Descriptor 8).
• Enhance coordination and data sharing: Improve mechanisms of coordination and data sharing between Defra, DWI, EA, HSE to ensure integrated ‘source-to-receptor' approach to PFAS management.
• Research support: Urgent need for further funding into PFAS, their impacts, the supply chain and management of sludge. There also needs to be greater research to understand the effects of PFAS in aquatic environments and on fish health.
• Public information and health guidance: Inform anglers, and the wider public, of potential PFAS risks and issue guidance on seafood consumption if PFAS exceedances are found. The absence of UK food limits for PFAS should be addressed urgently.

These steps will help meet the Committee’s goal of protecting the aquatic environments and public health. PFAS are a global problem, but delayed action at home will mean contaminated waters, unhealthy fish stocks, and risks to people who fish or eat seafood around the UK. The Angling Trust stands ready to work with government, scientists and other stakeholders to tackle PFAS in our waters.

May 2025