What happens when chemicals are both persistent and mobile in the environment? The UK government has just outlined its strategy for managing these dual threats under a new policy framework. This interim statement from the Department for Environment, Food & Rural Affairs will be essential reading for manufacturers, importers, and chemical users operating in England, Scotland, and Wales. If your products contain PFAS or you’re involved in chemical risk assessments, understanding this new PMT approach could influence your regulatory strategy and restriction planning.
The PMT concept explained
The UK has adopted an interim approach to the persistent, mobile, toxic (PMT) concept, including very persistent, very mobile (vPvM) substances. This policy framework, agreed with Scottish and Welsh governments, specifically targets PFAS management under UK REACH regulation.
PMT substances present unique challenges because they combine environmental persistence with the ability to move through ecosystems. This mobility means they can spread far from their original source, making containment and cleanup extremely difficult. PFAS exemplify these concerns perfectly. Their carbon-fluorine bonds create exceptional persistence, allowing them to remain in the environment for decades. Combined with multiple emission sources – firefighting foams, industrial processing aids, textile coatings – this creates complex risk management challenges.
This statement builds on the 2023 Regulatory Management Options Analysis (RMOA), which examined PFAS and environmental hazards associated with persistence, bioaccumulation, mobility, and toxicity. The new PMT approach provides more focused tools for addressing the specific combination of persistence and mobility. The policy recognises that PFAS represent “extreme examples of persistent and mobile substances,” making them priority candidates for this management approach.
The PMT concept will support UK REACH risk management decisions, including proposed restrictions. This suggests upcoming regulatory actions could specifically target substances meeting PMT criteria. For manufacturers and importers, this means increased scrutiny of PFAS-containing products and processes. The framework provides regulators with clearer grounds for restriction proposals based on combined persistence and mobility concerns. The policy also establishes priorities for research addressing technical knowledge gaps, available data, and appropriate test methods. This suggests the framework will evolve as scientific understanding improves.
While this statement focuses on PFAS, it acknowledges that “a wider range of substances potentially have these properties of concern.” This broader scope suggests the PMT concept could expand beyond PFAS to other persistent, mobile chemicals. Companies should consider reviewing their chemical portfolios for substances that might meet PMT criteria. Early identification allows proactive substitution planning before restrictions emerge. The emphasis on mobility as a key concern also highlights the importance of environmental fate data in regulatory assessments. Substances that can travel long distances from emission sources face heightened regulatory attention.
Alignment with international trends
The PMT concept reflects growing international consensus on managing chemicals with combined persistence and mobility properties. Similar approaches are under discussion in EU chemicals regulation and other jurisdictions. This alignment suggests UK approaches to PMT substances will likely parallel international developments, creating consistent pressure across markets for substitution of problematic chemicals.
The statement identifies specific research priorities including addressing technical knowledge gaps, improving available data, and developing appropriate test methods. This suggests opportunities for collaboration between industry and regulators in developing better assessment tools. Companies with strong environmental fate data or innovative testing approaches may find opportunities to contribute to policy development while gaining competitive advantages.
Next steps for compliance
While this remains an interim statement, it signals clear regulatory direction. Companies should begin assessing their exposure to PMT concerns and developing substitution strategies where appropriate.
Review product portfolios for PFAS content and consider mobility characteristics of other persistent chemicals in your supply chain. Early action positions you ahead of potential restrictions.
Monitor upcoming UK REACH restriction proposals, as PMT concerns may feature prominently in regulatory justifications. Understanding this framework helps anticipate and respond to restriction consultations.
This policy statement reflects the UK’s post-Brexit approach to chemical regulation, maintaining alignment with international best practices while developing distinctive UK frameworks. The PMT concept represents one example of how UK REACH may evolve differently from EU REACH.
For multinational companies, this creates additional complexity in managing parallel regulatory requirements across jurisdictions. However, the focus on scientifically-based approaches suggests reasonable alignment with international trends.
Ready to assess your exposure to PMT concerns and develop strategic responses? Our team at Alura Group can help you navigate the evolving UK REACH landscape and prepare for potential PFAS restrictions. Contact us today to discuss how this new policy framework affects your business.
Source: https://www.gov.uk/