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This blog was written by Natasha Jackson
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Goal 4 of the Environmental Improvement Plan 2025 (“EIP 2025”) is concerned with chemicals and pesticides. The Government’s ambition is framed with notable care: “We will reduce the risks from chemicals and pesticides to people and the environment.”
That phrasing matters. Unlike Goals dealing with air, water or waste, Goal 4 does not promise cleaner outcomes or restored ecosystems. It speaks instead in the language of risk-reduction rather than elimination; management rather than prevention. This reflects an underlying reality: chemical pollution is among the most technically complex, scientifically uncertain and legally fragmented areas of environmental regulation.
Reducing risks from chemicals and pesticides
Goal 4 is structured around a small number of high-level commitments rather than a dense matrix of numerical targets. That in itself is revealing.
At its core, Goal 4 commits the Government to reducing risks arising from the manufacture, use and disposal of chemicals and pesticides, while continuing to support innovation and economic activity. The delivery mechanisms are largely indirect, relying on existing regulatory frameworks rather than new primary legislation.
Chemical and pesticide regulations exist as a complex and relatively fragmented web, including but not limited to the following regimes:
Chemical regulation does not stop at national borders and Goal 4 must be read against a dense web of international obligations. The UK remains party to various instruments, most notably the Stockholm Convention on Persistent Organic Pollutants, under which certain PFAS are already restricted.
Notably absent from Goal 4 is any pledge to consolidate or simplify the domestic architecture. There is no introduction of a new overarching chemicals regulator, nor a unified statutory framework. Instead, it signals incremental reform layered onto an already complex system.
At the same time, post-Brexit divergence from EU law looms large. The EU is progressing towards a group-based restriction on PFAS under EU REACH, reflecting growing acceptance that regulating these substances individually is scientifically and legally inadequate. The UK’s more incremental approach risks misalignment, with consequences for environmental protection, product standards and international trade. It also sharpens the role of domestic accountability mechanisms, particularly the Office for Environmental Protection, in scrutinising whether Government action under Goal 4 is compatible with environmental law principles.
PFAS: a regulatory conundrum
Goal 4 sets out the Government’s intentions concerning per- and polyfluoroalkyl substances (“PFAS”); the so-called “forever chemicals”.
PFAS are a vast class of synthetic substances defined by carbon–fluorine bonds of exceptional stability. That stability makes them exceptionally useful: the first PFAS were invented by Teflon in 1938 for use in non-stick cookware, and they have been put to work on everything from skin cream to yoga pants since. It also makes them exceptionally harmful: they are highly persistent, mobile in water systems, and bioaccumulative in humans and wildlife. For this reason, they were branded as “forever chemicals” by an article in the Washington Post in 2018.
PFAS are now detected in soil, rivers, drinking water and blood serum across the globe. They are linked to serious public health concerns, including a range of cancers, endocrine disorders and reproductive health concerns. The risks posed by PFAS formed the subject of a recent Panorama programme (aired 1 Dec 2025) and there is an ongoing parliamentary inquiry by the Environmental Audit Committee.
From a regulatory perspective, PFAS expose various fault-lines in traditional chemical control. For example: (i) substance-by-substance regulation struggles to cope with large chemical families; (ii) assumptions of localised harm fall down when the contamination is often historic, diffuse and transboundary; and (iii) control at source are complicated when the source may no longer exist or may lie overseas.
Goal 4 responds by committing to a PFAS Action Plan in 2026, followed by a decision in 2027 on whether to restrict PFAS in firefighting foams under UK REACH. These are important signals, but they lack the concrete and detailed commitments that are a feature of other Goals.
All told, what Goal 4 presents on PFAS is primarily a ‘plan to make a plan’. While it offers positive noises in the right direction, but it doesn’t run to catch the UK up with the more advanced regulatory position in the USA and EU on this front. The reliance on future plans rather than immediate controls raises familiar questions. Is the complexity of the problem causing the regulatory can to be kicked down the road? And how does a risk-based, forward-looking approach sit with the precautionary principle, particularly where widespread exposure is already established?
Pesticides, targets and accountability
Goal 4 also encompasses pesticide risk reduction, including commitments to reduce the Pesticides Load Indicator by 2030.
This sits within a long-running legal debate about pesticide authorisation, post-approval controls and the application of precaution where scientific evidence is contested. For example, Alex Shattock advised the NGO ClientEarth on their OEP complaint regarding the emergency authorisation of bee-killing neonicotinoids, which resulted in a refusal to authorise the pesticide by the UK Government in January this year (see here and here). However, the ban is still not outright and there is a further request in the pipeline for sugar beets to be treated with it next year. There is also litigation in the pipeline regarding growing concerns about the pesticide Glysophate, which faces similar complexities in proving harm to a legal standard.
Under EU law, such disputes frequently played out before the Court of Justice (and continue to do so, see: https://www.pan-europe.info/pr...). Post-Brexit, they now fall primarily to domestic judicial review, informed by retained EU principles and the Environment Act’s environmental principles duty, and nuisance / negligence claims.
What remains unclear is how far the EIP’s pesticide commitments will translate into legally enforceable constraints, as opposed to policy aspirations mediated through guidance, voluntary uptake and funding incentives.
Litigation, liability and future trajectories
Those who have read or seen ‘Dark Waters’, a legal thriller based on Robert Bilott’s claim against DuPont (a Teflon manufacturer) for poisoning the local community with the PFAS ‘PFOA’, will be aware that PFAS contamination has already generated extensive litigation in the United States, including class actions and product liability claims resulting in settlements running into the billions.
The UK litigation landscape is different and PFAS claims are only just starting to come through. A pre-action settlement has been achieved in September 2025 involving alleged PFAS pollution in North Yorkshire in relation to the Angus International Safety Group factory in Bentham (see here and here) and it claims are being investigated linked to AGC Chemicals’ Lancashire facility where high levels of PFAS were detected in discharges into the River Wyre by the Environment Agency) (see news coverage here: https://www.bbc.co.uk/news/articles/cly85p0jndko).
I expect the coming years will see a growing trend in claims for:
The ingredients for future claims are increasingly present: scientific knowledge of harm, diffuse contamination, historic use and regulatory inertia. But this area of litigation raises interesting questions about causation and attribution: perhaps not dissimilar to asbestos, we know these chemicals are harmful, but don’t have an exact understanding of their toxicological or epidemiological issues to necessarily pin down fault on the balance of probabilities. It will be interesting to see if the Courts show willing to respond innovatively to PFAS litigation, as they did in the seminal mesothelioma case of Fairchild v Glenhaven Funeral Services Ltd [2003] 1 AC 32. But this will be tricky in a context where all of us are being unavoidably being exposed to many different PFAS on a regular basis, and there is no disease that has (thus far) been solely linked to these chemicals.
Where scrutiny will matter
As with other Goals, the success of Goal 4 will turn less on aspiration than on implementation. Several fault-lines stand out:
Overall thoughts
Goal 4 is less about dramatic ambition and more about structural adequacy. The promised PFAS Action Plan and future UK REACH decisions will be pivotal: not merely as policy documents, but as tests of whether Government is willing to recalibrate chemical regulation towards precaution, group-based controls and long-term environmental protection.
In that sense, Goal 4 functions as a stress test: of regulatory courage, of legal coherence, and of environmental law’s capacity to grapple with risks already embedded in the fabric of modern life.
