Cunliffe’s Water Commission highlights need for regulation to tackle chemical and plastic pollution


Water has dominated UK headlines in recent months, and while many of the headlines may focus on governance reform and industry performance, a closer look reveals a strong, overdue focus on one critical and under-recognised threat: micropollutants, aka chemical and microplastic pollution.

person touching water on kayak

The Water Review

On the 21st of July 2025, the Independent Water Commission, chaired by Sir Jon Cunliffe, published a review of the water sector in England and Wales1. Dubbed the Cunliffe Review, this report offers one of the most detailed evaluations of the UK’s water system in decades. The Review’s conclusions are clear: the current system is fragmented, under-regulated, and not fit for addressing the environmental and public health risks we now face.

The review outlines 88 recommendations to address structural, regulatory, and environment failures. Five of these have already been accepted by the UK Government including abolishing Ofwat to create a new integrated water regulator, the adoption of a catchment-based model for planning and investment, the establishment of a Water Ombudsman to better protect customers and the introduction of open-access monitoring, where pollution data should be publicly available in real time.

What’s in our water

Chemical pollutants can enter the water system from a wide range of sources, from household products to industrial discharges and agricultural runoff, and many are not removed effectively by conventional wastewater treatment. This means they build up in rivers, soil, and even drinking water, threatening environmental and human health. These contaminants include (but are not limited to):

list of chemical contaminants

Shockingly, many of these pollutants are not currently regulated or monitored under UK law. They can flow through wastewater treatment plants, accumulate in the sewage treatment by-product sewage sludge (which is spread on farmland as fertiliser), and end up in our food chain and wider environment. It has been estimated that 99% of microplastics present in sewage sludge applied to land are eventually exported to aquatic environments2.

Chemical and plastic pollutant recommendations from the review

Regulating sewage sludge and other polluting products

  • Update sewage sludge regulations: The current Sludge (Use in Agriculture) Regulations 1989 are outdated and don’t reflect what we now know about contaminants like PFAS and microplastics. The Review calls for modernisation to protect soils, crops, and water from toxic build-up and aligns with Fidra’s work to clean up sewage sludge.
  • Review of the Urban Wastewater Treatment Regulations (1994): These ageing rules need updating to reflect current scientific knowledge, with a focus on minimising chemical and microplastic pollution. This should also include consideration of an Extended Producer Responsibility (EPR) scheme, making polluters pay for clean-up, which is already in place in the EU for producers of cosmetics and pharmaceuticals3 , and could incentivise a move away from polluting products.
  • Ban wet wipes containing plastic: As an example of upstream, or “pre-pipe,” regulation, the Review urges government to consider legislative bans on products that clog pipes and pollute rivers. Source control, including restrictions on chemicals and bans on plastic products, ensure that pollutants do not enter the water system to begin with.

Improve standards and monitoring

  • Reform the Water Framework Directive: The Review warns that progress under this core environmental law has stalled. It recommends new classification systems, clearer targets, and more frequent assessments to ensure the UK meets its water quality goals and incorporates public health. Fidra urges that any new classification systems should embed the precautionary principle and recognise plastic and chemical threats to ecosystems. Since exiting the EU, there has not been a ‘replacement mechanism’ to monitor emerging threats to water bodies, whereas the EU Watch List published in March this year contains 12 priority micropollutants4 . The review recommends that the UK’s mechanism should be better aligned with EU REACH as a result.
  • Routine testing for priority pollutants: Wastewater treatment plants should be required to regularly test and publicly report levels of PFAS, microplastics, pharmaceuticals, and other micropollutants. Currently, most of these are not monitored at all.
  • Updates to drinking water standards: with more power for the Drinking Water Inspectorate to enforce limits, for example on PFAS.

Why this matters

The Cunliffe Review provides a roadmap to improve UK water quality, and it will take political will and public pressure to make these reforms reality.

In particular, the reviews focus on chemical and microplastic pollutants and modernising sewage sludge regulation is a major step forward. For too long, our laws have ignored the invisible but dangerous chemicals making their way through our pipes and into our environment.

Fidra supports many of these recommendations whilst recognising the need to go further and faster to get chemical pollution under control. Source control is essential in reducing pollution across our water systems. This involves restricting harmful chemicals or adding them to the UK’s candidate or ‘authorisation list’ which are chemicals that can only be used in specific circumstances5; classifying chemicals as hazardous where needed; and robust product controls and regulations that support a reduction in harmful chemical use.  Better controls on chemicals will prevent the use of harmful substances in products in the first place so they can no longer escape industrial sites or end up in sewage when we use a product.

Restricting harmful chemicals, such as PFAS, which are extremely persistent and difficult to remove, will cut pollution at its origin, reducing both environmental exposure and costly downstream clean-up. This approach directly aligns with the goals of the Cunliffe Review and would help limit the circulation of toxic substances currently polluting our waterways.

What’s Next?

The government will publish a response to the Review later this year, and a Water Reform Bill is now in development to enshrine some of these recommendations into law. Fidra are continuing to advocate for a universal PFAS restriction, a reduction in the use of chemical flame-retardants, and an end to the use of sewage sludge as fertiliser until it is a clean and safe resource. Only through better controls on chemicals and plastic will we protect our water for people and wildlife.

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References

  1. Independent Water Commission (2025) Independent Water Commission: Final Report Retrieved online July 25, 2025 from: https://assets.publishing.service.gov.uk/media/687dfcc4312ee8a5f0806be6/Independent_Water_Commission_-_Final_Report_-_21_July.pdf.
  2. Crossman J, Hurley RR, Futter M, & Nizzetto L (2020) Transfer and transport of microplastics from biosolids to agricultural soils and the wider environment Science of The Total Environment 724 138334, https://doi.org/10.1016/j.scitotenv.2020.138334.
  3. European Commission (2024) Directive (EU) 2024/3019 of the European Parliament and of the Council of 27 November 2024 concerning urban wastewater treatment (recast) (Text with EEA relevance) European Commission, Brussels.
  4. European Commission (2025) New substances added to the EU’s surface water watchlist Retrieved online August 4, 2025 from: https://environment.ec.europa.eu/news/new-substances-added-eu-surface-water-watchlist-2025-03-03_en.
  5. HSE (2025) UK REACH Candidate List of substances of very high concern (SVHCs) for authorisation Retrieved online August 4, 2025 from: https://www.hse.gov.uk/reach/candidate-list.htm.