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On 4 June 2025, the UK Government published an interim position statement detailing how the concepts of persistent, mobile and toxic (PMT), and very persistent and very mobile (vPvM) substances will be used to support risk management under UK REACH. This new approach aims to enhance the regulatory control of per- and polyfluoroalkyl substances (PFAS), as these substances pose significant environmental challenges due to their extreme persistence and mobility in the environment.

The interim position statement was published by the Department for Environment, Food & Rural Affairs (Defra) and applies to England, Scotland and Wales.  It marks a significant step in aligning UK chemical policy with emerging international practices. Although PMT and vPvM are not yet recognised as formal hazard classes under UK REACH or UK CLP, the government intends to leverage these concepts to support restriction proposals and risk management measures, particularly with regard to PFAS.

PFAS as a Regulatory Priority

PFAS are often referred to as “forever chemicals” due to their resistance to environmental breakdown and capacity to spread widely through water systems. UK environmental monitoring data has revealed widespread PFAS contamination in rivers, groundwater, and organisms, including fish, suggesting that their mobility and persistence result in diffuse and long-term pollution.

Due to these characteristics, PFAS do not easily fit into traditional risk assessment models that rely on thresholds or predicted no-effect concentrations. The government is therefore adopting a precautionary approach based on the PMT/vPvM concept to guide early regulatory intervention and prevent irreversible environmental harm.

Key Features of the Interim Approach

• Non-threshold regulatory principle: Rather than identifying safe exposure levels, the UK approach focuses on minimising emissions of PMT/vPvM substances throughout their lifecycle.

• Basis for restriction proposals: The interim concept will support the development of restriction dossiers under UK REACH, including the anticipated restriction on PFAS, by identifying substances of concern based on their PMT/vPvM properties.

• Use of Article 57(f): Substances identified as PMT or vPvM may be considered substances of very high concern (SVHCs) under UK REACH, using the provision for substances with equivalent levels of concern.

Next Steps and Broader Implications

While the interim approach currently targets PFAS, the government notes that the methodology may later be expanded to cover other PMT/vPvM substances. The Environment Agency has been tasked with advancing the scientific and technical tools needed to support this strategy, including:

• Improved methods for identifying mobility beyond traditional partition coefficients (e.g. Kₒc),

• Enhanced tools for screening and prioritising PMT/vPvM substances, and

• National monitoring programmes to track their presence in the environment.

In parallel, the UK will continue to engage with international forums, such as the UN Globally Harmonized System (GHS), and monitor developments in the EU’s Classification, Labelling and Packaging (CLP) Regulation, which recently introduced PMT/vPvM as new hazard classes.

A Step Toward Future Integration

Although PMT and vPvM are not yet part of the UK’s formal hazard classification system, this interim position enables the government to address substances with properties that pose serious long-term environmental risks. By incorporating the PMT/vPvM concept into restriction proposals, the UK intends to prevent irreversible contamination and enhance chemical safety in a scientifically robust and precautionary manner.

The full text of the interim position statement can be found here.

The UK Health and Safety Executive (HSE) has published its 2022 report on the official monitoring of plant protection products (PPPs), revealing significant compliance issues in the food and agriculture sectors. Issued under Article 68 of the retained EU Regulation 1107/2009, the report provides insights into national control measures for placing PPPs on the market and monitoring their use.

Summary of Official Controls and Enforcement

• 1,631 inspections were carried out by the HSE across Great Britain in 2022, targeting storage sites, online sales, and agricultural use.

• 65 product samples were collected for laboratory testing. Of these, 28 failed to meet legal requirements due to the presence of unauthorised co-formulants, unapproved use conditions, and labelling deficiencies.

• Follow-up actions included improvement notices, voluntary withdrawals, product recalls. In a few cases, there were enforcement notices and prosecutions.

• The focus of several campaigns was on high-risk products, such as triazole fungicides and copper compounds, and increased scrutiny of online marketplaces.

Residue Monitoring and Food Chain Risk

In collaboration with the Food Standards Agency (FSA), Food Standards Scotland (FSS), and DAERA in Northern Ireland, the UK’s pesticide residue surveillance programme tested 3,304 food samples across a wide range of commodities. Overall compliance with maximum residue levels (MRLs) was over 98%, but 60 samples exceeded the legal thresholds.

One area of concern was the detection of tri-allate residues in kale and broccoli, likely due to volatilisation and drift after application. Risk management discussions have been initiated with authorisation holders.

Northern Ireland: Online Sales and Compliance

The Department of Agriculture, Environment and Rural Affairs (DAERA) investigated six cases of non-compliance relating to unauthorised online pesticide sales. All cases were voluntarily resolved, underscoring the growing attention that enforcement is paying to digital platforms.

Industry Implications

The 2022 findings underscore the importance of:

• Maintaining robust supply chain controls to prevent contamination.

• Verifying authorisations for products marketed online and in stores.

• Ensuring that correct labelling and formulation details are upheld throughout the manufacturing and distribution process.

Looking Ahead

The HSE has indicated that future monitoring will continue to target high-risk products, unapproved imports, and digital sales channels. Retailers, manufacturers, and users of PPPs are encouraged to carefully review their compliance obligations.

Access the full 2022 report here.