The PFAS Plan: the food manufacturing bits

Defra published the PFAS Plan on 3 February 2026. The document was updated again on 17 August 2026.

It is a plan, not a regulation. It introduces no new limits, no new testing requirements and nothing you can be audited against. What it does is set out around 50 indicative actions across three pillars, with delivery outlooks and named owners, covering everything from firefighting foam to school uniforms to sewage sludge.

Almost all of the coverage has come from environmental law firms writing for every sector at once. This is the food manufacturing extract.

First, a definitional change that widens everything else

The plan adopts the Organisation for Economic Cooperation and Development (OECD) definition of PFAS and uses it to guide every action in the document.

That definition is broad. Any chemical with at least one fully fluorinated methyl or methylene carbon group counts, with a few noted exceptions. That is a wider net than the narrower approach used previously, and it matters because every threshold, restriction and testing programme downstream inherits it.

If you have a PFAS position stated anywhere, in a supplier questionnaire, a specification or a customer declaration, check which definition it was written against. A statement that was accurate under a narrow definition may not survive a broader one.

What the Food Standards Agency is actually doing

Three of the plan's actions sit with the Food Standards Agency, working through the National Reference Laboratory.

On food. Tests have been developed and validated for some PFAS in fish, shellfish, beef, poultry, milk and eggs. Validation is still ongoing for other meats, fruit, vegetables and cereals, and for 26 additional PFAS across all food types.

On packaging. The National Reference Laboratory continues to assess whether PFAS are present in UK food packaging. This is the finding worth knowing: initial work sampled specific food contact materials such as takeaway boxes and found negligible PFAS presence.

That is a more reassuring result than the general coverage implies, and it is the sort of thing that never makes the headline. If a customer or a journalist asks you about PFAS in your packaging, that sentence is in a government policy paper and it is the current official position.

One caution before you lean on it. "Negligible" is not a number, and the packaging methodology works to a threshold of 25 parts per billion in food packaging, which is very low. Nothing published says whether the sampled materials cleared that figure. So the finding is useful for a general question about PFAS in UK food packaging, and it is not evidence that any particular format passes.

On bottled water. If you produce bottled water, which is legally a food, there is an action to explore collecting data on contamination risk through industry engagement, risk mapping and research.

All three carry the same caveat in the delivery column: the extent of the work depends on the outcome of the UK and EU sanitary and phytosanitary negotiations in 2026. So the pace of this is tied to a trade negotiation, not to a regulatory timetable.

The action with a date on it

Action 2.3 is the one to diarise, and it is the one that reaches beyond food safety into your packaging costs.

The plan commits to progressing the addition of more PFAS substances to the UK REACH candidate list of substances of very high concern. The delivery outlook is specific: a new strategic approach to the UK candidate list in early 2026, a Health and Safety Executive consultation on relevant PFAS in summer 2026, and additions to the list following the decision-making process within 45 days of that consultation closing, expected autumn 2026. Further additions may follow in each annual UK REACH work programme.

So autumn 2026 is the first of a cycle rather than a one-off, and the candidate list becomes something to check annually rather than something to check once.

Here is why that is a packaging problem and not just a chemicals one, and it starts with something already live rather than something coming.

Under the Recyclability Assessment Methodology, PFAS already carries its own automatic red rating. An item or component containing more than 1 part per million of total PFAS, individual or summed, is red. For food packaging the threshold is far lower: more than 25 parts per billion of any individual or total PFAS. A red rating carries a fee multiplier on the household waste disposal element of your packaging bill.

Twenty five parts per billion is a very low bar. If you use grease-resistant or fluorinated formats and have never had them tested, you do not currently know which side of it you are on.

Substances of very high concern are listed separately in the same automatic-red criteria. So the candidate list is a second route to the same outcome, and a broader one: it catches substances by name rather than by the PFAS thresholds, and a listing can change the rating of packaging you are already using without anything about that packaging changing.

Alignment with the EU restrictions

Action 2.2 restates the commitment to reform UK REACH by December 2028, so that chemical protections can be applied more quickly and in a way more aligned with the EU.

Attached to it is a list of the EU REACH restrictions the UK will consider in that context. One is directly ours: the restriction on perfluorohexanoic acid (PFHxA) and its sub-group, which in the EU covers consumer products including food packaging.

So the direction of travel on food packaging is visible even though nothing has been proposed in Great Britain yet. If your packaging supplier is already supplying into the EU, they have dealt with this. Ask them.

Northern Ireland sits differently, as usual. Under Annex 2 of the Windsor Framework, Northern Ireland continues to follow EU chemicals legislation and is subject to the EU's PFAS actions directly.

Two more, if they apply to you

Persistent organic pollutants. Action 2.4 covers implementation of the Stockholm Convention obligations. Long-chain perfluorocarboxylic acids were agreed for global elimination in May 2025, and the delivery outlook says the restriction is to be implemented by the end of 2026. That is another automatic-red trigger under the packaging methodology, so the same logic as the candidate list applies.

Environmental permits. If your site holds one, Actions 2.10 and 2.11 are yours. Cross-sector guidance is being developed for regulators, operators and permitted industry on reducing PFAS emissions and improving handling, monitoring and disposal, with engagement across the four nations during 2026. The plan is explicit that it will set a clear requirement for industry to be transparent with regulators about PFAS use and emissions, and that permit reviews could follow.

What this plan is not

It is worth being clear about the limits, because the gap between the coverage and the document is wide.

There are no new PFAS standards in here. There is no phase-out date for PFAS in food packaging. There is no testing requirement landing on your site. Most of the actions are research, monitoring, guidance development and consultation, and the plan says of itself that it is a first step and that the actions are an initial set of proposals rather than an exhaustive list.

What it gives you is visibility. You can now see which regulator owns which piece, roughly when each piece is expected, and which of them could turn into something you have to do.

Your Monday morning list

1. Check which definition your PFAS statements were written against. Supplier declarations, specifications, customer questionnaires. The OECD definition is broader than what many of them will assume.
2. Find out whether your grease-resistant formats clear 25ppb. This one is live now, not future. Above that figure in food packaging is an automatic red rating and the fee multiplier that comes with it. Your packaging supplier should be able to tell you, and if they cannot, that is itself the answer.
3. Put autumn 2026 in the diary for the candidate list. If additions land, your packaging ratings may change without your packaging changing. Then check it again each year.
4. Ask your packaging supplier about PFHxA. If they supply into the EU they have already dealt with the restriction there, and their answer tells you how exposed your formats are.
5. Keep the negligible-presence finding to hand. Initial food contact material sampling found negligible PFAS. That is the current government position and it is useful when someone asks.
6. If you hold an environmental permit, expect a transparency ask. Guidance is being developed through 2026 and permit reviews are explicitly on the table.
7. Do nothing else yet. Nothing in this plan requires action from a food site today. The value is in knowing what is coming and when, not in starting a project.

Information, not advice. Always check the PFAS Plan before making decisions that matter.