ENERGY & SUSTAINABILITY PREPARING FOR PFAS REGULATIONS


In this article Ian Anderson, Partner at Schofield Sweeney, offers insight into PFAS regulation and explains why, as it moves rapidly up the regulatory agenda, manufacturers can no longer afford to ignore it


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FAS aren’t a new problem, but they are becoming a much more pressing one for UK industry. Often referred to as ‘forever chemicals’ because of their persistence in the environment, PFAS have been used for decades in a huge range of products and applications, from coatings, adhesives and electronics to packaging, technical textiles and firefighting foams.


Their durability is part of what made PFAS so useful in the first place, but it is also at the heart of the problem. They do not naturally break down and can remain in the environment for decades, with some accumulating in living organisms over time. PFAS have now been detected in everything from rainwater and wastewater to soil and the wider natural and built environment. Not every PFAS presents the same level of risk. Some are considered essentially inert, while others have been associated with serious health concerns, including cancer, ulcerative colitis, developmental issues, reduced immunity and thyroid disease. Earlier this year, the UK


Government published its 2026 PFAS Plan, setting out its approach to understanding, managing and restricting the use of PFAS in the years ahead. As regulation develops, manufacturers that make, process or use PFAS – or supply products containing them – are likely to face increasing obligations. But this isn’t simply an issue of future regulatory compliance. PFAS could potentially expose businesses to contaminated land liabilities, product liability claims and, in some circumstances, claims relating to employee exposure. Contamination can also affect property transactions, insurance and environmental permitting. For manufacturers, PFAS therefore need to be considered as a wider operational and commercial risk. One of the biggest challenges is knowing whether they are present in the first place. There is still a perception that PFAS are primarily an issue for chemical manufacturers or highly specialised industries. In reality, they have been used in thousands of products and processes, so manufacturers could have PFAS within their operations without necessarily realising it. This is where process engineers have an important role to play. Rather than waiting for further restrictions to arrive, manufacturers should start building a clear picture of where PFAS could exist within their operations now. For process engineers, that means looking closely at the entire production cycle. Raw materials and ingredients are an obvious starting point, but the review needs to go further. Coatings and surface treatments, processing aids, production chemicals, filtration systems and membranes, lubricants and maintenance products,


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packaging, waste streams and emissions should all be considered.


The objective is not simply to establish whether


PFAS are deliberately used in a finished product. Businesses need to understand where they may enter the process, how they are used and, importantly, where they could leave it.


exposure, and consider what changes may be required before regulatory pressure increases


“ Could PFAS enter wastewater or other waste Understand


or products contain PFAS and, where they do, which substances are present. They should also establish whether alternatives are available and what suppliers themselves are doing to prepare for potential restrictions.


Many suppliers may not currently have all of those answers but starting the conversation now gives businesses time to identify gaps and investigate alternatives rather than being forced to react once restrictions are introduced or customers begin demanding answers. Historical operations shouldn’t be overlooked


streams? Could they be discharged into the atmosphere? Are existing waste management arrangements appropriate if PFAS are identified? Is there any potential for surrounding land or watercourses to be affected? Answering these questions now gives manufacturers an opportunity to understand their exposure and consider what changes may be required before regulatory pressure increases. The exercise shouldn’t stop with a manufacturer’s own operations. Supply chain visibility will be equally important. Businesses should start asking suppliers whether materials


” PROCESS & CONTROL ENGINEERING | SEPTEMBER 2026


either. At sites that have been used for manufacturing for many years, PFAS may have been used by the current business, previous operators or neighbouring sites. Their ability to migrate through groundwater and surface water also means contamination does not necessarily remain within the boundaries of the site where it originated. Understanding the history of a site can therefore be just as important as looking at what is happening there today. There is still uncertainty around exactly how


PFAS regulation will develop but waiting for every detail to be confirmed before taking action carries its own risk. The manufacturers best prepared for tighter PFAS regulation will be those that have already done the legwork. Mapping potential PFAS use across processes, products and supply chains now will make it easier to respond to future requirements, identify alternatives where necessary and manage potential legal, environmental and commercial risks before they become much harder to resolve.


Schofield Sweeney www.schofieldsweeney.co.uk


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