
UK Launches Public Consultation on PFAS in Firefighting Foams
The incorporation of PFAS into firefighting foams has raised significant environmental and health concerns.

The UK government has announced a new strategic approach to the UK REACH candidate list of substances of very high concern, replacing interim principles that have applied since 2021. Published by the Department for Environment, Food and Rural Affairs on 24 February 2026, the policy confirms that future updates to the UK REACH candidate list will more closely align with EU decisions, with implications for manufacturers, importers and downstream users across Great Britain.
The move affects businesses responsible for managing chemicals under UK REACH, particularly those handling substances of very high concern. Inclusion on the UK REACH candidate list triggers legal communication and notification duties and signals potential progression to authorisation requirements.
Under UK REACH, substances of very high concern include those that are carcinogenic, mutagenic or toxic for reproduction, as well as substances that are persistent, bioaccumulative and toxic in the environment. The UK REACH candidate list identifies these substances and flags them for possible future regulatory control.
Suppliers of listed substances, whether on their own, in mixtures or in articles, must meet additional communication obligations along the supply chain. If a substance progresses to the authorisation list, it cannot be used after its specified sunset date unless a specific authorisation has been granted or an exemption applies.
The regulation places responsibility squarely on businesses to understand chemical risks, implement risk management measures and ensure information flows to customers. This extends beyond manufacturers to distributors, formulators, retailers and professional end users.
When UK REACH came into force following the UK's exit from the EU, all substances on the EU REACH candidate list were carried over. Since then, interim principles guided further additions.
As of 24 February 2026, those interim principles no longer apply. In line with Commitment 40 of Defra's 2025 Environmental Improvement Plan, the government will now draw more systematically on regulatory decisions made in other jurisdictions, particularly the EU.
Substances added to the EU REACH candidate list since 1 January 2021 will be reviewed and, where appropriate, added to the UK REACH candidate list. Future EU additions will also be considered under this approach. The stated aim is to reduce business complexity and trade friction while maintaining high levels of protection for human health and the environment.
The Health and Safety Executive, acting as the UK REACH agency, retains the power to propose additional substances of very high concern. Proposals will follow the Article 59 process, including preparation and consultation on an Annex 15 dossier presenting the scientific evidence.
Defra and the devolved governments of Scotland and Wales have also signalled a stronger focus on substitution, encouraging the replacement of hazardous substances where safer alternatives are technically and economically viable.
Companies should now review portfolios against recent and upcoming EU candidate list updates and assess potential UK alignment impacts. Early supply chain engagement and substitution planning will be critical to avoid disruption if substances move towards authorisation.
The UK REACH candidate list will now be updated using a strategic approach that closely aligns with EU decisions. For businesses across the chemicals value chain, this increases regulatory predictability but reinforces the need for proactive compliance, supply chain communication and substitution planning.




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