PFAS0120

Written evidence submitted by Water UK

Water UK is the trade association for water and wastewater companies across Scotland, England, Wales and Northern Ireland.

Water policy is a devolved matter but as the Committee is primarily concerned with the Westminster government, we focus our comments accordingly, while noting that certain aspects will necessarily require consideration by devolved administrations.

Executive Summary

The vast majority of human exposure to PFAS ‘forever chemicals’ is from sources other than water[1]; however, the water industry fully recognises its important role in protecting the public against the risk of harm. That is why, despite England’s tap water regulator (the Drinking Water Inspectorate (DWI)) concluding “the low levels of PFAS detected in some untreated water abstracted for public drinking water supplies has no acute or immediate impact on human health”[2], companies are currently investing £355 million on advanced treatment and abstraction changes to maintain the UK’s world-leading quality of drinking water. 

Over the medium term, as understanding grows of the increasing accumulation of PFAS compounds in the environment, and with some European countries already starting to ban PFAS in certain consumer products[3], we hope the Environmental Audit Committee’s inquiry will encourage the UK government to take new action to prevent concentrations of PFAS increasing further in the environment.

In light of the evidence included in this response, we are of the view that the UK Government should consider urgently implementing a National Plan for PFAS. This plan should include:

1. Specific measures to end pollution from PFAS. These measures should include:

a.      A public commitment from the UK Government to end all non-essential uses of PFAS, with encouragement for manufacturers to make early voluntary moves towards alternative chemicals in advance of restrictions.

b.      The introduction, within the next twelve months, of new legislation to act as a framework for starting to phase out all PFAS across the economy, drawing on international research to set deadlines for specific categories and uses of PFAS.

c.       Accelerating funding and resources to develop alternative substances to replace PFAS chemicals, including through projects such as those mentioned in the “Industry Action” section of this response.

d.      Cleaning up existing pollution through the introduction of “producer responsibility” financing mechanisms to be used during the period of phase-out, requiring any company placing PFAS-containing products on the market to contribute to a Restoration Fund that would help provide:

1. Environmental restoration work (e.g. cleaning landfill leachate and old contaminated industrial sites)
2. Additional resources for local authorities and the Environment Agency to enforce the cleaning of contaminated land under Part 2A of the Environmental Protection Act 1990.
3. Treatment to remove PFAS via the water and sewage systems.
4. Investment in research and scaling-up of innovative treatment technologies that may be able to deal with residual PFAS wastes once they have been removed from circulation (further detail on these technologies can be found below).

2. A systematic and sustained national testing programme of PFAS across different sources, with the data made public. The UK Government and relevant regulators should conduct new testing (and share existing data) on PFAS levels across the environment, including in soil, dust, air, water bodies, clothing, consumer goods, cosmetics and food and beverages to understand the levels of PFAS and their sources, and to inform and prioritise actions to reduce levels.
3. Introduction of a new mandatory registration requirement for polymers under UK REACH, in particular those that are likely to contain PFAS or see use as PFAS precursors.
4. New standards on PFAS for protecting health and the environment. We want to see science-based PFAS standards introduced into both national and international regulation to protect human health and the environment - against which manufacturers, PFAS users and those responsible for transmission pathways can take action, plan investment, and be held to account.

Background

PFAS is a group of over 9,000 industrial chemicals[4]. They are used extensively in consumer products such as non-stick cookware, waterproof clothing and carpets, as well as in industrial products such as firefighting foams and as industrial processing aids.​ They are known as ‘forever chemicals’ because they persist in the environment for up to several thousand years.[5]

In answer to the Committee’s first question regarding the benefits and extent of PFAS usage in the UK, PFAS have been manufactured or imported into the UK for over 90 years.[6]  Significant environmental pollution has been identified around former industrial sites and airfields where PFAS chemicals have been allowed to escape to the wider environment.[7]  In some locations, such as Buncefield and Jersey, significant pollution of groundwater has been identified.[8]

There is growing evidence linking some PFAS chemicals to serious public and environmental health impacts;[9] these include links to vaccine efficacy, various cancers, and altered cholesterol levels.[10]​ However, due to their number and complexity, many more of these chemicals are poorly understood at present.

In 2009, the Conference of the Parties[11] listed perfluorooctane sulfonic acid (PFOS) in Annex B to the Stockholm Convention[12]. The Stockholm Convention on Persistent Organic Pollutants – also referred to as POPs - was adopted in 2001 and is a global treaty to protect human health and the environment from chemicals that remain intact in the environment for long periods, become widely distributed geographically, accumulate in the fatty tissue of humans and wildlife, and have harmful impacts on human health or on the environment.  

In 2019, following the evaluation of the continued need for PFOS, its salts and perfluorooctane sulfonyl fluoride (PFOSF)[13], the Conference of the Parties amended Annex B to remove several of the specific exemptions and acceptable purposes for PFOS, its salts and PFOSF[14]. In 2019, POPs was updated to include perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds, with a further update in 2022 to include perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds.  Most recently, the POPs Committee has recommended also including long-chain perfluorocarboxylic acids (PFCAs), with the final decision set to be taken at the next Conference of the Parties meeting this month (May 2025).

The first regulatory steps on PFAS at a national level were taken in 2023, when Defra published a Regulatory Management Options Analysis on PFAS[15]. The analysis concluded that restrictions of PFAS under REACH should be introduced for firefighting foams, as well as for “the manufacture and placing on the market of consumer articles from which PFAS are likely to be released into air, water or soil” directly[16]. HSE have been tasked with investigating this further and their restriction dossier[17]is due to be published in Spring 2025[18].

Due to their extreme persistence in the environment, PFAS pollution has been found in most water environments around the world[19]. The water industry continues to adhere to and, where possible, surpass strict regulations and guidance[20]. These standards ensure public water supplied in the UK remains the highest quality drinking water in the world, as ranked by Yale University’s 2024 Environmental Performance Index.[21]

Economy-Wide Presence and Uses of PFAS

In response to the Committee’s second, third and fourth questions, robust economy-wide evidence on the variety of PFAS, their volumes, uses and emissions in the UK is limited, which presents a challenge when considering further regulatory action. 

Gaps remain in our understanding of the sources and uses of PFAS in the UK, but the three main applications identified by the Environment Agency are:

• protective treatments – for example paper, packaging and textiles such as oil and waterproof clothing and carpets;
• in polymer manufacturing; and
• as surfactants – including aqueous film fire-fighting foams (AFFFs) and use as mist suppressants in chrome plating.[22]

Overall, the Environment Agency lists 12 individual PFAS substances that are commonly detected through its monitoring activities.[23]

The European Chemicals Agency (ECHA) public registration database and the UK REACH database are the only readily accessible sources of information about potential production and use of chemicals in the UK. However, neither include any substance (including PFAS) manufactured or imported by individual companies below one tonne per year. Furthermore, the UK REACH database is still under development and does not identify UK companies that may be importing PFAS from EU-based suppliers.  ECHA identified only 36 individual PFAS that are supplied in quantities greater than 10 tonnes per year.[24] 

It is likely that PFAS are present in small quantities in semi-finished or finished imported goods, but there is no requirement to register these imports unless the articles are designed to intentionally release the PFAS during service life and the aggregate import exceeds one tonne per year[25]. In many cases, importers/suppliers may be unaware of their presence due to commercial confidentiality.  In addition, there is currently no registration requirement for polymers under UK or EU REACH.

This lack of a registration requirement represents an important gap, because polymers containing residual PFAS additives or processing aids are a source of PFAS in the environment due to their degradation and/or weathering over time. It is not currently possible to estimate the contribution of such polymers to the environmental burden of PFAS. 

There is also limited understanding of the potential for release during chemical life cycles, including during recycling and waste disposal. The intrinsic physical and chemical properties of PFAS also make them particularly challenging to analyse in environmental media, including water, soil and air. Analytical methods with sufficiently low detection limits only became widely available in the early 2010s, and most methods focus on only the relatively small number of perfluoroalkylated acids (PFAAs). 

In the rest of this response, we focus on the risks specific to the water industry for the purposes of our response, i.e. drinking water, treated effluent and bioresources.

Drinking Water

The World Health Organization estimates that around 80% of human exposure to PFAS comes from food, air, indoor dust and textiles[26], with around 20% coming from drinking water[27] - though there is currently limited research on this topic and the academic literature shows that exposure does vary depending on location (and may in some places fall as low, for example, as <1% from drinking water).[28] According to the Drinking Water Inspectorate, “Based on our current knowledge, the low levels of PFAS detected in some untreated water abstracted for public drinking water supplies has no acute or immediate impact on human health.”[29]

Despite this comparatively low assessment of risk, the Drinking Water Inspectorate (DWI) has taken a sensible precautionary approach and has set guidance levels for PFAS that provide a precautionary margin of safety in advance of further international research results on compound toxicology. Water companies are required to comply with this guidance, and where necessary take specific actions such as additional treatment and/or blending with other sources to reduce PFAS concentrations in water prior to supply. The DWI’s recent revisions to guidance, published in 2024, put in place a risk-based, tiered guideline for water companies[30] to adhere to, with sources of water allocated to a ‘tier’ depending on the prevalence of PFAS measured in nanogram/litre, as follows:

• Tier 1 < 0.01 µg/L
• Tier 2 < 0.1 µg/L
• Tier 3 > 0.1 µg/L

Depending on the tier, companies may be required to take remedial action. For instance, companies with sources that fall into tier 2 will be required to design a proactive and systematic risk reduction strategy. This could include a prioritised mitigation plan to progressively reduce PFAS concentrations in drinking water. Where sites fall into tier 3, companies should put in place emergency measures to reduce concentrations to below the 100 ng/l in water supplied to consumers. If necessary, this could include the provision of alternative water supplies. Importantly, the DWI’s guidance includes combined PFAS on a ‘sum of’ basis; this means measuring the combined concentration of multiple PFAS compounds in a water sample.

This guidance, which took effect in January 2025, applies only to England and Wales and covers a list of 48 named PFAS. In Scotland, the Public Water Supplies Regulations 2014 were amended in 2022 to set a 0.1 microgram limit to a group of 20 named PFAS.

Water companies have committed £355 million between 2025 and 2030 to combat PFAS in drinking water, including efforts to remove and reduce PFAS levels at wastewater treatment works and to conduct additional investigations and sampling in drinking water sources. More than £100 million of this funding will be geared towards developing granular activated carbon processes to remove PFAS at drinking water treatment plans. 

Granular activated carbon process, largely agreed to be the most effective method for removing PFAS from drinking water sources secured via abstraction[31], functions through filters. The filters apply activated carbon to adsorb organic compounds in drinking water treatment systems, in this instance PFAS[32]. In essence, filters act like a sponge or magnet for PFAS: the untreated drinking water flows through a bed of specially treated carbon particles, which the PFAS particles stick to, which allows for their removal. Granular activated carbon treatment is also preferred as it offers the possibility of regeneration of the removed PFAS, without creating an additional waste stream[33]. Granular activated carbon filters store the PFAS carbon mixture until they are full, after which the mixture can be destroyed.

Even before the DWI’s guidance came into force, water companies had begun to sample and monitor PFAS levels in drinking water. From 2019 to 2023 they performed over one million analyses of samples for PFAS to ensure compliance with safety limits set out in previous DWI guidance.[34]   In 2023 alone, companies in England collectively carried out over 600,000 analyses of individual PFAS [35] providing a “significant dataset to understand the challenges in drinking water.”[36]

Treated Effluent and Bioresources

While conventional wastewater treatment practices may capture some PFAS, they were not originally designed to remove and destroy PFAS. By long-established practice, the resulting ‘sludge’ left over at the end of treatment is spread to agricultural land as an excellent source of nutrients for crops. Such practice avoids alternative disposal routes such as incineration and is a practice that is regulated by the Environment Agency and is subject to an assurance scheme[37]. However, reflecting its near-universal presence in the environment, it is likely that some sludge product contains a level of PFAS compounds.

The water industry has been working with the Environment Agency on a ‘Chemical Investigations Programme’ to improve the evidence base and the understanding on the presence of chemicals in the influent and effluent that are not captured and eliminated by the current sewage treatment process, including some PFAS. The Chemical Investigations Programme phase 4 is expected to complete in 2027 and will also include an investigation on the impact of spreading sludge to soil, surface and groundwater. The results of this investigation will help to inform future policy and water industry requirements.

We have also been working closely with the Environment Agency to support their assessment of the regulatory framework for spreading sludge, which may introduce future requirements to manage emerging risks from this activity.

Industry Action

Every single day, water companies across the UK treat and distribute the best drinking water in the world. Companies adhere to high standards set by regulators, with 99.98% of samples meeting their strict tests.[38] With regard to question seven, companies have been proactively researching innovative proposals, via Ofwat’s Innovation Fund and other routes, on ways in which they can support government in reducing PFAS levels in the water environment. For example, Anglian Water is supporting Cranfield University research[39] into the efficacy of treatment wetlands in reducing levels of PFAS entering the environment. The research is showing promising results, with surface flow wetlands contributing to PFAS removal. A further study will also quantitatively assess the contributions of nature-based solutions in protecting rivers, alongside identifying the actual sources of pollutants in the streams.

Affinity Water has been supporting Brunel University to investigate sources of pollution affecting river ecology and untreated drinking water supplies across catchments. The catchment used for the research is characterised by high-drainage topographical features such as swallow holes, which can allow surface to groundwater connectivity, potentially affecting groundwater sources in the area under certain hydrogeological conditions. While still at an early stage, the intention is to enter partnership with members of the local catchment action group and investigate potential pollutant sources in the catchment, including PFAS, which might be impacting drinking water supplies and river ecology.

Wessex Water are also working at the catchment level to identify techniques to establish whether sources of PFAS contamination can be identified; these include passive sampling, forensics tracking tools, fingerprinting and data analytics. If identified, this will then enable companies to review whether catchment management could be used as an effective tool to mitigate PFAS risk. This project aims to complete by the end of 2025.

Regarding PFAS detection, Dŵr Cymru (Welsh Water) is looking into developing Electrochemical Biosensors for pollutants in water, with the current work focused on PFAS chemicals and starting with PFOS. The project is part of a three-year PhD study working with Swansea University students, making printed carbon electrodes using waste coffee grounds with the aim of attaching PFAS chemicals to the biosensor. The biosensors can then be washed off, and if PFAS chemicals are detected, reattached, releasing an electrical signal proportional to the concentration of PFAS chemicals. This project is still at proof-of-concept stage and is not yet available for commercialisation, though water companies have sought to scale the project and will be taking this idea through to development via an Ofwat Innovation bid in the autumn.

Severn Trent, in collaboration with Spring Innovation and five other water companies, is offering over £1.7 million to bids on projects that seek to remove and destruct PFAS from waterways[40]. This project, in collaboration with Spring Innovation and five other companies, continues the work conducted by Cranfield University to assess the best removal options, pairing it with the optimal destruction technology, and will also investigate the regeneration of solid adsorbents (materials that can attract and hold molecules through adsorption). The project is expected to be completed by September 2027 and will include small scale pilot trials demonstrating PFAS destruction technology.

Water companies have shared all of this work with each other through a PFAS-specific forum coordinated by Water UK, combining resources and collaboratively progressing the actions required to progressively reduce PFAS in drinking water (beyond existing Drinking Water Inspectorate expectations).

International Action

With regard to questions 12 and 13, the UK water industry concurs with the growing international consensus that the only meaningful solution to the problem of PFAS contamination is to ban its use.[41] Without such a ban, reflecting the accumulative and persistent nature of the compounds, it will become increasingly more difficult for the water industry to treat and manage PFAS concentrations. In addition, three risks will begin to grow:

1.      It can be hard to completely remove all PFAS from water[42] - in practical terms, it is difficult to achieve a consistent, high level of removal across a broad range of PFAS compounds as part of large-volume treatment processes. Further increases in PFAS concentration over coming decades will make it harder to stay within required thresholds;

2.      The capital and operating cost of advanced water treatment technologies that deal with PFAS are very high (potentially running to tens of billions of pounds to completely remove PFOS and PFAS over coming decades)[43], which could significantly increase water bills as increasing levels of treatment become necessary;

3.      Treatment of sewage or drinking water typically collects rather than destroys PFAS, leaving open the question of what to do with it following extraction. Residual PFAS waste cannot be destroyed through conventional incineration or buried because it does not break down over time. The only proven technology that could be deployed at scale which destroys PFAS is very high-temperature incineration. Current capacity is limited and available in only a small number of sites in the UK.

The UK is already behind its counterparts in taking policy action. A universal ban of PFAS is under consideration at EU level by the European Chemicals Agency (ECHA).[44] with a ban on long chain perfluorocarboxylic acids (LC-PFCAs) from January 26 of this year through the Stockholm convention, as well[45].

• On 7th December 2022, the EU amended Regulation (EC) No 1881/2006 to introduce maximum levels of perfluoroalkyl substances in certain foodstuffs[46].
• France has introduced new legislation to ban certain PFAS in cosmetics and ski wax by January 2026 and in some types of textiles by 2030 (cookware was included in the initial proposal but ultimately dropped from the scope following strong opposition by cookware producers)[47].
• New Zealand has banned the use of PFAS in cosmetic products from December 2026.
• In the United States, there are extensive restrictions being imposed on the use of PFAS by certain sectors[48] with the setup a funding pot to help implement PFAS treatment measures to support implementation[49].

In addition, the new EU Urban Wastewater Treatment Directive[50] states that Member States must implement the polluter pays principle by 31st December 2028, with the pharmaceutical and cosmetics industries obliged to contribute at least 80% of the costs of monitoring and cleaning harmful substances they discharge into urban wastewater. The Commission is understood to be considering extending this principle to PFAS manufacturers.[51]

Other governments are also undertaking legal action against manufacturers and polluters. For example, Sweden's Land and Environment Court of Appeal instructed the Swedish Armed Forces to pay damages of €3.5 million, consisting of both compensation for the costs of PFAS treatment and legal costs, after ruling that they were responsible for PFAS pollution in a water source.[52]

We therefore hope the UK Government will introduce the restrictions detailed at the beginning of this document.

May 2025

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