Forever, Unlimited

What are PFAS, and are they in India's water? Is there a limit? And who decided? These are the questions a reader asks on first hearing the phrase 'forever chemicals', and India's standards answer the second one plainly: there is no limit.

This paper makes three claims. First, India regulates PFAS in drinking water, bottled water and food not at all, and this is a verified absence, not an oversight of search. Second, the absence is a product of governance by list: India accepts additions to the Stockholm Convention's list of persistent pollutants one by one, and it has not accepted PFOS, PFOA or PFHxS. Third, no standard is not the same as no exposure. PFAS have been found in Indian rivers, groundwater, sediments and on food, and a country without a limit records no exceedance, so its silence is read as safety.

The paper opens in Bhopal. India's worst chemical disaster began at a pesticide plant, with a gas whose full composition was never known, a death toll the Supreme Court's own record gives three ways, and a law that came after the harm. PFAS are a slower, quieter case of the same pattern, and India still has the chance to write the limit before the count.

On the night of 2 to 3 December 1984, a runaway reaction in Tank 610 of the pesticide plant run by Union Carbide India Limited in Bhopal released nearly 40 tons of methyl isocyanate, a chemical used there to make the insecticide carbaryl, sold as Sevin, over a densely populated city. The Indian Council of Medical Research calls it the worst chemical disaster in the world (Indian Council of Medical Research 2010).

What people breathed that night has never been fully known. The Council's own toxicology report records that the tissues of the dead held, besides the products of methyl isocyanate, 'numerous unidentified organic chemicals', and, citing a 1987 editorial, that the composition of 'the poisonous cloud actually inhaled by the people of Bhopal' was not known. Some of its results were never published, the report adds, because of legal embargoes (Indian Council of Medical Research 2010).

Nor was the number of the dead ever settled. The Supreme Court's own record carries three figures side by side: 2,660 deaths, as the Union of India stated them to the High Court in 1988; about 3,000 fatal cases, on which the Court based the 1989 settlement of US$470 million; and 5,295 deaths, in the Union's 2010 petition to reopen that settlement, which also counted 527,894 cases of minor injury where the Court had assumed 50,000. The Court dismissed the petition on 14 March 2023 (Supreme Court of India 2023). A harm that is counted only after it happens is compensated by estimate.

India's law also came after the harm. The Bhopal Gas Leak Disaster (Processing of Claims) Act was enacted on 20 February 1985 (Supreme Court of India 2023), and the Environment (Protection) Act received assent on 23 May 1986, less than eighteen months after the leak. The second Act empowers the central government to lay down 'standards for the quality of environment in its various aspects' and standards for the emission or discharge of pollutants (Government of India 1986, section 3(2)(iii) and (iv)). That power has existed for forty years; in 2024 the Central Pollution Control Board told the National Green Tribunal that no standard is prescribed for PFAS in drinking water (section 5). The Act's preamble cites the 1972 United Nations conference at Stockholm. It is a later Stockholm agreement, the 2001 Convention on persistent pollutants, whose PFAS listings India has not accepted (section 6).

Bhopal did not end with the night. An earlier judgment of the Court, quoted in 2023, already contemplated claimants 'yet unborn' whose congenital defects might be traced to methyl isocyanate (Supreme Court of India 2023). The 337 tonnes of waste left at the factory were burned only in 2025, at Pithampur, and in December 2025 the disposal of the ash was still before the High Court (Press Trust of India 2025, reported).

PFAS are not a Bhopal. They come as no cloud and kill no one overnight; they cannot be seen in a glass of water, and finding them takes a laboratory that measures parts per trillion. The governance follows the same pattern, though: a chemical whose effects were not known in advance, a count made after the fact, a law written after the harm, and a burden that outlasts the event. Bhopal was a pesticide plant, and PFAS are now among the pesticides found on Indian food (section 3). The rest of this paper asks whether India needs to wait for a count before it writes a limit.

PFAS are a large family of synthetic chemicals. The United States Environmental Protection Agency lists where people meet them: non-stick cookware; stain- and water-repellent treatments on carpets, upholstery, clothing and other fabrics; grease-resistant paper, fast-food containers and wrappers, microwave popcorn bags, pizza boxes and candy wrappers; certain shampoos, dental floss and cosmetics; and the aqueous film-forming foams used to put out fuel fires. Many 'break down very slowly and can build up in people, animals, and the environment over time' (US EPA 2026c). In an Indian kitchen, that means the non-stick tawa and kadai; in an Indian street, the raincoat, the takeaway wrapper and the pizza box.

Some pesticides are PFAS too. A 2026 review counted 55 PFAS-based pesticides in residue monitoring of Indian grapes from 2014 to 2025, including fipronil and lambda-cyhalothrin, and found that a few exceeded safety thresholds in less than 0.1 percent of samples (Gunjal et al. 2026). The line between a pesticide paper and a PFAS paper is thinner than the regulations assume.

The record is short, recent and nearly all academic. Across seven major rivers of southern India, the mean sum of 16 PFAS was 96.9 ng/L along urban stretches, about seven times the 13.5 ng/L along suburban and rural stretches, and PFOS exceeded the European environmental quality standard for surface water (Pavithra et al. 2026). In groundwater, a vital source of drinking water in the Kamrup region of Assam, 12 PFAS were detected (Sharma et al. 2024). In sediments of the upper Ganges and the Ganges Canal, 16 PFAS were detected, and the extractable organic fluorine rose fivefold along the stretch studied, with the PFAS that laboratories target accounting for at most 1.3 percent of it (Müller et al. 2026). In Chennai, sediment cores from the Cooum River showed PFAS rising after the 2015 flood, which the authors read as evidence of 'ongoing production and use of PFAS in India' (Yamazaki et al. 2025).

The state's own submission to the National Green Tribunal cites drinking-water figures from South India: PFOA rising from below 0.005 ng/L in 2008 to 2 ng/L in 2015, and PFOS from below 0.033 to 1 ng/L, which it relates to a shift of industrial production toward countries such as China and India (Central Pollution Control Board 2024). Two nanograms per litre of PFOA is half the United States limit. The same submission reports a 2022 finding, prepared for the environment ministry, that PFAS concentrations in India are 'relatively lower than those in other countries'. Lower than elsewhere, measured where and how often, is the question this paper's companion on India's waters asks of pesticides (Ramprasad 2026).

The United States regulates PFOA and PFOS in drinking water at 4.0 ng/L each, three further PFAS at 10 ng/L, and a mixture of four through a hazard index; systems must test quarterly wherever a regulated PFAS exceeds a trigger level, and compliance with the limits is due by April 2029 (US EPA 2026a). In May 2026 the EPA proposed to keep the limits for PFOA and PFOS while letting systems apply for two more years, to 2031, and separately proposed to rescind the limits for PFHxS, PFNA, HFPO-DA and the mixture (US EPA 2026b). The European Union limits the sum of 20 PFAS to 0.10 µg/L, and all PFAS together to 0.50 µg/L once methods are agreed, from 12 January 2026 (European Union 2020). The World Health Organization's 2022 guidelines contain no PFAS guideline value (WHO 2022).

Four nanograms per litre is four parts per trillion, about four seconds in 7,900 years; one gram of PFOA would bring 250 million litres, about 100 Olympic swimming pools, to the United States limit.

We read each Indian instrument for a PFAS parameter. India's drinking-water standard, IS 10500:2012, has none (Bureau of Indian Standards 2012). The packaged-water regulation, which holds bottled water to 0.1 µg/L for each pesticide, has none; neither does the full regulation on contaminants, toxins and residues in food, in the compendium of 3 February 2026 (Food Safety and Standards Authority of India 2011; 2026). The Jal Jeevan Mission's testing framework, which lists every parameter its laboratories test, has none (Ministry of Jal Shakti n.d.).

The state has said so itself. Asked by the National Green Tribunal about PFAS in Chennai's lakes, the Central Pollution Control Board replied on 27 August 2024 that 'there is no standard prescribed for PFAS in drinking water by Bureau of Indian Standard in Indian standard (IS 10500:2012)'. It described a 'first step': the adoption of three ISO methods, a specification for laboratory water, guidance on designing sampling programmes and a statistical method for calibration, none of them specific to PFAS. A dedicated Indian method for PFOS and PFOA, IS 3025 Part 72, has been listed as a draft under development since 2020. The Board added that a national inventory of manufacturing and use, including PFAS, was under way (Central Pollution Control Board 2024).

Why does India have no limit? Part of the answer is a mechanism few people outside chemical diplomacy have heard of. The Stockholm Convention eliminates or restricts persistent organic pollutants by listing them in its annexes, and most parties are bound by new listings automatically unless they object. India is an opt-in party: a new listing binds it only once it accepts that listing. India became a party in 2006. Of the chemicals added since, it has accepted seven, all in force for India from 17 March 2021. It has not accepted PFOS (listed in 2009 and again in 2019), PFOA (2019) or PFHxS (2022), nor lindane, alpha- and beta-HCH, endosulfan or dicofol (Stockholm Convention Secretariat 2026).

Lists govern in strange ways. Kinniburgh and colleagues show that private agricultural standards copy the Rotterdam Convention's list into their own lists of banned substances, so that adding a chemical to the treaty triggers private bans as well; the effect is to make states more reluctant to list, a 'confounding interaction' in which stricter private rules impede the treaty (Kinniburgh et al. 2023). Donley shows how far national lists diverge: 72 pesticides approved for outdoor farm use in the United States are banned or being phased out in the European Union, and pesticides banned in the Union account for more than a quarter of American agricultural use (Donley 2019). Shattuck traces the industry behind the lists, now a generic trade largely produced in China and India, with commodity chains and environmental impacts that are 'less legible' (Shattuck 2021; Berndt et al. 2025). India's own lists show the same split: within a month of proposing to ban 27 insecticides in 2020, the government amended the draft to let firms keep making them for export (Ministry of Agriculture and Farmers Welfare 2020).

A list is a decision about whose water counts. A chemical off the list is a chemical no one is required to test, and a chemical no one tests produces no evidence that it should be listed.

The burden is unlikely to be even. The southern rivers study found PFAS about seven times higher along urban stretches than rural ones (Pavithra et al. 2026). Children carried the highest estimated hazard in Assam's groundwater (Sharma et al. 2024). The people likely to be most exposed are those who work with PFAS and live beside the places they are made, used or burned; India's national inventory of those places has been under way since at least 2024 and is not public (Central Pollution Control Board 2024). The households that cannot buy filtered or bottled water have no limit to appeal to, and the bottled water they cannot buy has none either.

The recommendation has five parts.

1. Set an interim limit now. Write a PFAS value into IS 10500 and the packaged-water regulation, using the European sum of 20 PFAS at 0.10 µg/L as a floor until India sets its own.
2. Finish the method. Complete IS 3025 Part 72, a draft since 2020, and equip state laboratories with the instruments to run it.
3. Test the tail first. Add PFAS to the Jal Jeevan Mission's state-laboratory panel, beginning with drinking-water sources near manufacturing, use and disposal sites, urban river stretches and groundwater-dependent households.
4. Accept the listings. Accept the Stockholm Convention's listings of PFOS, PFOA and PFHxS, so that India's obligations match the chemicals it already carries.
5. Publish the inventory. Release the national inventory of PFAS manufacture and use and the 2022 report prepared for the environment ministry, so that monitoring can follow the sources.

What would overturn this argument is stated in advance: an Indian standard or regulation, in force, that sets a PFAS limit for drinking water or food, or a systematic national survey, with published detection limits, that finds PFAS consistently below the United States limit.

Every claim of absence in this paper was checked in the primary document, and every number in the source that first reported it. Table 2 lists each check, the document read, and the result. A claim we could not read in the original is marked as such.

This paper uses published standards, regulations, treaty records and peer-reviewed studies. It names no household, worker or site.

We read the instruments in force on 17 October 2026 and may have missed a state-level rule, a sectoral effluent standard or an amendment not yet published online. The Indian measurements are few and use different compounds, matrices and methods, so they cannot be added together or compared directly with drinking-water limits. Several studies were read at the level of their abstracts. The Global Pesticide Use and Trade database (Shattuck et al. 2023), which reports that pesticide use trends in low-income countries are substantially underestimated, was available to us by title only.

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