Fidra welcome the UK Government’s new Environmental Improvement Plan (EIP) 2025 commitments to align with the EU on chemical regulation, review regulations on sewage sludge applied to farmland, and to develop plans to address harmful pollutants such as PFAS and POPs. But to truly protect people and the environment, government must go further. We need a clear PFAS plan that cuts PFAS emissions at source and a circular economy strategy that delivers full chemical transparency and puts safe, sustainable design into practice. We take a closer look at the commitments in the EIP and highlight the next steps and details that we need to protect our environment from pollution.
Why the 2025 EIP matters
The Environmental Improvement Plan 2025 sets out the goals and commitments the UK Government want to achieve to improve the environment in England. The Government has also published some delivery plans, monitoring plans and indicators to go alongside the EIP 2025. The Environment Improvement Plan (EIP) 2025 is the first EIP produced under the current Labour Government and outlines the government’s ambition and environmental priorities. The EIP 2025 will be monitored by environmental watchdog, the Office for Environmental Protection, which will provide an indication of progress towards the Environment Act statutory targets.
Sewage sludge applied to farmland
What the EIP says:
Commitment 38: Review the regulatory framework for sewage sludge spreading to agricultural land to ensure it effectively manages the risks to the environment and health.
What this means:
The Government could bring sludge-use-in-agriculture regulations into the Environmental Permitting Regulations and make the Safe Sludge Matrix mandatory, ensuring pathogen removal and restricting agricultural use to conventionally or enhanced-treated sludge. This will safeguard soils against pathogens alongside existing controls on heavy metals (lead, cadmium, zinc, copper, mercury, nickel). The reform follows Scotland’s move to regulate biosolids under the Environmental Authorisations (Scotland) Amendment Regulations 2025, but is unlikely to lead to significant change unless other harmful contaminants and chemical mixtures are also addressed.
There is an urgent need to expand the list of regulated contaminants in sludge to include microplastics, PFAS, pharmaceuticals, veterinary medicines, and other chemicals of concern in order to improve overall sludge quality. However, technologies capable of removing these substances are still emerging, are often costly, and are not yet scalable. As a result, the long-term viability of applying treated sewage sludge to farmland is increasingly uncertain. Should tighter contaminant limits be introduced, current nutrient recycling practices may no longer be feasible, coupled with the constraints on available landbank and growing public concern around the issue, policymakers need to be proactive and ambitious in developing solutions and protecting agricultural soils. Relying solely on Chemical Investigations Programme data to assess risk will lead to unacceptably slow action. Protecting agricultural soils is essential for food security, public health, and environmental sustainability. A precautionary policy approach, consistent with the Environmental Principles, would involve phasing out the application of sewage sludge to farmland until levels of microplastics, PFAS, and other contaminants are reduced and there is certainty that risks to human and environmental health are negligible. This would provide a more robust foundation for effective risk management.
Water and chemical pollution
What the EIP says:
Commitment 39: Better understand the health impacts associated with polluted waters
The Monitoring and reporting approach for Goal 4 states – Defra will continue to develop monitoring methods to allow water bodies to be scanned for a broad range of chemicals beyond those already monitored. This information, along with established targeted screening, will be fed into the prioritisation and early warning system programme to inform decision making and regulation.
What this means:
While the health focus in Commitment 39 is welcomed, it is noticeable that the actions to deliver it focus only on pathogens, not on risks from chemical pollutants. Similarly, the environmental impacts of chemical pollution and taking action on known pollutants has not been outlined in detail. In response to the latest scientific findings, the EU has updated its list of priority substances and watchlist chemicals in the Water Framework Directive to improve water monitoring, and this monitoring is then informing regulations on chemicals. The UK needs to update monitoring in line with the EU and ensure risks identified through monitoring result in regulatory action that addresses chemical pollution at source through UKREACH and as well as through environmental permitting regulations to address industrial emissions and sewage sludge application to land.
Protecting human health and the environment from chemicals
What the EIP says:
Goal 4: Chemicals and pesticides: We will minimise environmental risks from chemicals and pesticides
What this means:
The UK has made international commitments to reduce pollution to levels that are not harmful to biodiversity including; reducing the overall risk from pesticides and highly hazardous chemicals by at least half. To deliver Goal 4 will require further action and regulation to tackle pollution at source by ending the production and use of harmful chemicals such as PFAS, chemical flame retardants and endocrine disrupting chemicals like bisphenols.
What the EIP says:
Commitment 40: Reform UK Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) to enable protections that address chemical pollution to be applied more quickly, efficiently and in a way that is more aligned with our closest trading partners, especially the EU, by December 2028
What this means:
The EIP 2025 includes a commitment to align with the EU on chemical regulation which could mean we see more controls on harmful chemicals more quickly to better protect our health and environment in the UK. It is encouraging to see Actions to update the Candidate List of Substances of Very High Concern (SVHCs) and Authorisation List which seeks to eliminate the use of harmful chemicals, as these have not been updated since Brexit. However the wording still leaves the door open to align with other foreign jurisdictions too. There are also many other protections from chemicals that the UK is falling behind on such as regulations that decide which chemicals are harmful (Classification and Labelling and packaging (CLP) and regulations on chemicals which kill living organisms, known as biocides. These regulations also need to keep pace with the world leading chemical regulatory system operating in the EU. Since Brexit, the UK has been unable to respond to scientific and regulatory development on chemicals, bringing in just one new restriction since 2021. Aligning chemical regulation with the EU is the only way to get the UK back on track with protecting our health and environment from chemicals.
‘Forever chemicals’ PFAS
What the EIP says:
Commitment 41: Take action on PFAS through a new PFAS plan
What this means:
The EIP acknowledges the need to address ongoing and legacy PFAS pollution. It commits to publishing a PFAS plan in 2026, which will set out a range of interventions to “address releases of harmful PFAS”. The EIP also commits to providing support to manage existing PFAS contamination sites. Whilst we welcome these commitments to address ‘forever chemicals’, their effectiveness remains to be seen as we await further detail and clarity in the proposed 2026 PFAS Plan. Given the well documented concerns relating to PFAS, and widespread contamination, we hope the severity of this issue is reflected in the Government’s plans. To provide effective solutions, the Government must commit to meaningful reductions in PFAS emissions by restricting all non-essential uses and transitioning the UK towards sustainable alternatives.
Under Commitment 46, the EIP also reaffirms its targets set out under the Pesticides National Action Plan 2025, to reduce the environmental impact from pesticides by 10% by 2030 and support uptake of more sustainable practices, such as Integrated Pest Management (IPM). Pesticides are a direct source of PFAS into the environment. In 2022, the equivalent of 10.6 million hectares were sprayed with PFAS pesticides in the UK, in the arable sector alone. PFAS pesticides can also breakdown into smaller PFAS, such as Trifluoroacetic acid (TFA); an incredibly persistent and mobile PFAS that is suspected to be harmful to reproduction. Denmark has already withdrawn over 30 PFAS pesticides because of their links to TFA, and Sweden is reviewing a similar approach. We urge the Government to ensure PFAS pesticides are captured in the PFAS Plan 2026, including commitments to phase out this direct source of PFAS pollution and support adoption of more sustainable alternatives, such as IPM.
Circular Economy
What the EIP says:
Goal 5: We will minimise waste by designing it out of the system, reusing and recycling materials wherever possible
Commitment 43: Substantially increase the destruction of POPs found in waste by 2030
What this means:
POPS are Persistent Organic Pollutants, which are chemicals that don’t easily breakdown, many are banned due to the harm they cause to our health and environment. POPs, such as chemical flame retardants are often found in waste furniture and electricals. This commitment could result in increased incineration of waste found to contain POPs above certain concentration thresholds, especially if monitoring by regulators demonstrates that other waste streams (in addition to waste electrical and electronic equipment (WEEE) and waste upholstered domestic seating (WUDS)) contain high levels of POPs. It is also likely that there will be increased incineration of waste materials as more chemicals are classified as POPs. Increased incineration of waste isn’t consistent with the EIP measures to reduce greenhouse gas emissions to mitigate climate change. Preventative solutions such as a reduction in the use of persistent and harmful chemicals in products in the first place are not mentioned. Enforced product chemical transparency (labelling), ideally dynamic data including information about chemical contents in product materials and components, would enable waste processors and recyclers to avoid unnecessary incineration. The use of Extended Producer Responsibility (EPR) schemes would also be a mechanism to support local authorities struggling with the cost of POPs in waste management and incineration. Both labelling and EPR measures could force producers to use safer non-toxic alternatives (e.g. expandable graphite instead of brominated flame retardants) or innovative design solutions (e.g. furniture fire barrier materials). Alignment with EUREACH would certainly help restrict the use of certain chemicals (e.g. aromatic brominated flame retardants) in the first place, but long-lived items such as upholstered furniture, which contains banned POPs are likely to require incineration far into the future.
What the EIP says:
Commitment 51: Publish the circular economy growth plan in early 2026, followed by its implementation
What this means:
While the overall goal covers designing out waste, most of the commitments in the EIP are around waste management and recycling rather than design. There needs to be further measures in the circular economy growth plan to deliver safe and sustainable design principles. This must include measures to prevent the use of harmful chemicals in products so that they don’t contaminate secondary materials or prevent recycling. We also need chemical transparency so that we know what chemical are where in our products and supply chains, this will futureproof the circular economy and allow materials to be repurpose, reused and recycled.
Microplastics
What the EIP says:
No commitments or actions
Microplastic is mentioned in relation to wet wipes, and a source of microplastic pollution is mentioned brake and tyre wear.
What this means:
Plastic is a major threat to our ecosystems and the UK has made an international commitment on preventing, reducing, and working towards eliminating plastic pollution. Microplastic is mentioned briefly in the EIP 2025 in relation to wet wipes and wear from vehicle brakes and tyres, however microplastic comes from a variety of sources. Secondary microplastic comes from the breakdown of larger plastic and can be found in road run off and sewage sludge applied to land. Primary microplastic is designed to be small pieces of plastic to start with, such as nurdles which are small plastic pellets used to make nearly all plastic products, and plastic infill used in artificial sports pitches, these too end up in the environment harming UK wildlife. Microplastics are also a source of chemical pollution; they can leach chemicals used to make the product into the environment, as well as attracting chemicals already in the environment to their surfaces, creating contaminant hubs. The EIP 2025 talks about improving protected landscapes and reducing pressures on wildlife but Fidra has found 168 Sites of Special Scientific Interest (SSSIs) in the UK are polluted with nurdles. Plastic pollution risks undermining Government’s nature goals. In the EU, plastic infill on sports pitches is being phased out and new regulation on plastic pellets (nurdles) is making pellet loss prevention measures mandatory across the plastic industry supply chain to achieve ‘zero pellet loss’. In the UK, regulation is needed to stop microplastic pollution at source.
Where the government needs to go further
The Environmental Improvement Plan 2025 could be a step in the right direction, if the plans and commitments outlined lead to source control to prevent pollution. To truly protect people and the environment from chemical and microplastic pollution more action is needed to embed the UK’s agreed Environmental Principles. Fidra will be looking to the PFAS Plan, agricultural use of sewage sludge review and circular economy strategy to make sure harm is prevented and rectified at source. This will require strong, swift and effective regulation on pollutants such as PFAS and microplastics (including plastic pellets and infill) and agricultural use of sewage sludge. The UK must avoid lagging behind and get the foundations of environmental protection right by aligning UK and EU chemicals and product sustainability regulations. We want to see the new circular economy growth plan put safe and sustainable by design principles and chemical transparency into practice to build a safe circular economy. Overall, the government needs to take a precautionary approach in regulation to ensure source control with strong enforcement and extended producer responsibility schemes that ensure polluters pay for plastic and chemical pollution. These actions will help the government achieve its EIP goals and encourage the use of safer, non-toxic alternatives that will better protect our environment and our health.