What’s changing exactly?
Two major pieces of legislation now affect vessels:
SOLAS ban on PFOS (effective 1st January 2026)
The IMO has confirmed that firefighting foam containing PFOS (perfluorooctane sulfonic acid) will be banned on vessels under SOLAS from 1 January 2026. The ban applies to both new builds and existing vessels, as part of a global effort to eliminate persistent pollutants from fire systems.
- New vessels (keel laid on or after 1 January 2026): must not carry or use PFOS-containing foam on delivery.
- Existing vessels: must remove and replace any PFOS-based foam by the first survey after 1 January 2026.
This applies to both fixed systems and portable equipment: use or storage of PFOS-containing firefighting media is prohibited.
EU Regulation 2025/1988 on all PFAS (published 3 October 2025)
This introduces a mandatory phase-out of ALL fluorinated firefighting foams and extinguishers containing PFAS – not just PFOS. This includes PFOS, PFOA, and PFHxA. Whilst this EU regulation isn’t specifically aimed at shipping, it has major implications for vessels operating in European waters and out of European ports.
The critical point: From 23 October 2025, you can no longer bring PFAS-containing foam aboard civil vessels in EU ports, even though existing foam already on board can continue to be used until 2035. This does not apply to UK ports until the HSE and UK REACH have completed their consultation process, ending in February 2026. An opinion by the HSE and UK REACH is due to be issued no later than August 2026. The date of 23rd October 2025 will apply to Northern Ireland under the terms of the ‘Windsor Agreement’.
Key deadlines at a glance
- 23 October 2025: Last date to bring PFAS foam aboard civil vessels in EU ports waters.
- 1 January 2026: SOLAS ban on PFOS foam comes into effect globally
- 23 October 2026: PFAS portable extinguishers can no longer be placed on market in EU
- 23 April 2027: Alcohol-resistant PFAS foams in portable extinguishers can no longer be placed on market in EU
- December 2030: Last date to use existing PFAS portable extinguishers
- 23 October 2030: PFAS foams (≥1 mg/l) can no longer be placed on market or used in EU fixed systems
- 23 October 2035: Last date to use PFAS foam in fixed systems on board civil vessels.
Extended exceptions until 2035
The following can continue using PFAS foam in fixed systems until 23 October 2035, provided foam was on board at EU ports before 23 October 2025:
- Companies covered by Directive 2012/18/EU (excluding civil aviation)
- Offshore oil and gas facilities
- Military vessels
- Civilian ships (if foam was on board at EU ports before 23 October 2025)
However, continued use requires strict management controls including limiting use to fire class B only, minimising environmental impact, maintaining separation of PFAS inventory and waste, and keeping detailed records for 15 years.
What about the UK?
The UK HSE is reviewing its position and will announce its opinion to UK REACH in April 2026. There’s a strong likelihood the UK will follow the EU’s approach. If you operate vessels calling at EU ports, you need to plan for the stricter EU regulations now. We will provide updates on the final ‘opinion’ of the HSE and UK REACH at the appropriate time.
