By Chloie Brandrick There’s a lot of discussion around the phase-out of PFOS and other PFAS firefighting foams at the moment – and plenty of confusion about what needs to change and when.
Different rules apply depending on where your vessels operate, which foam you’ve got on board, and how close you are to your next survey.
If you’re responsible for onboard FFE, here’s what you need to know
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) is prohibited 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: As 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
Confirmed (EU Regulation 2025/1988):
- 23 October 2025: last date to bring PFAS foam aboard civil vessels in EU ports
- 1 January 2026: SOLAS ban on PFOS foam comes into effect globally
- 23 October 2026: PFAS portable extinguishers can no longer be placed on the market in the EU
- 23 April 2027: alcohol-resistant PFAS foams in portable extinguishers can no longer be placed on the market in the EU
- December 2030: last date to use existing PFAS portable extinguishers in the EU
- 23 October 2030: PFAS foams (≥1 mg/l) can no longer be placed on the market or used in EU fixed systems, for uses without a longer exemption
- 23 October 2035: last date to use PFAS foam in fixed systems on board civil vessels in the EU, where foam was already aboard before 23 October 2025
Proposed (UK REACH, subject to consultation, not yet final):
- Portable extinguishers: 6 months before new PFAS-containing units can be placed on the market, 5 years before existing ones can no longer be used
- Onboard fixed systems (foam already aboard before the restriction takes effect): 10 years for both placing on the market and use, matching the EU approach
- Offshore oil and gas installations: 10 years
- All other uses not covered above: 5 years
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 HSE, acting as the Agency for UK REACH, published its opinion in July 2026, and it’s more concrete than we expected.
HSE is proposing a 10-year transition period (running from whenever the restriction actually takes effect) for foam already installed in fixed firefighting systems on civil vessels, primarily chemical tankers where deck foam systems are mandated. That matches the 10-year window the EU already granted under Regulation (EU) 2025/1988, for foam that was aboard at an EU port before 23 October 2025.
Portable fire extinguishers get a separate, shorter timeline (also counted from whenever the restriction takes effect): 6 months before PFAS-containing units can no longer be placed on the market, then 5 years before they can no longer be used. That’s a different clock to the one governing fixed onboard systems.
This is still a proposal, not law. It’s out for public consultation, and the transition periods above could shift before anything is finalised. If you operate vessels calling at EU ports, the EU dates already apply and aren’t affected by this UK consultation either way.
We’ll update this article again once the consultation closes and HSE confirms its final position.
What do you need to do?
Check your current foam stock
Review documentation or certificates of analysis for any foam onboard. PFOS content above 10mg/kg (0.001%) is not compliant under SOLAS regulations. Be aware that all other PFAS compounds are also now restricted under EU regulations.
Can’t find paperwork?
You may need to send a sample for LC-MS/MS PFOS testing. Foams supplied before 2010 are particularly likely to contain PFOS. Consider a TOP (Total Oxidisable Precursor) assay to identify other PFAS compounds that may be restricted under the broader EU regulations.
Plan for replacement
If your foam contains PFOS, it must be removed by the first survey after 1 January 2026 in accordance with SOLAS regulations; it must be safely removed and replaced with approved alternatives.
Important: Even if you’re technically allowed to use existing PFAS foam until 2035, you cannot replenish it after 23 October 2025 if operating in and out of EU ports. For most vessel operators, transitioning to fluorine-free alternatives now is a practical way to plan for compliance and minimise disruption.
Update records
Once replaced, update your Inventory of Hazardous Materials (IHM) and keep records for class/flag inspections.
How Star can help
We only supply fluorine-free firefighting foam (also known as FFF or F3),helping customers move toward compliant alternatives where fluorine-free foam is suitable for the specific vessel and system.
We’re happy to:
- Test your foam – lab analysis to confirm if PFOS or other PFAS compounds are present. A TOP assay can also highlight other PFAS precursors that may be in the mix.
- Supply replacement foam suitable for the applicable regulations and the specific vessel/system requirements.
- Support removal, disposal and paperwork to keep you audit-ready.
- Advise on transition planning to ensure minimal disruption to your vessel’s schedule.
PFAS foam ban: FAQs
From 1 January 2026, SOLAS will prohibit PFOS (perfluorooctane sulfonic acid) in shipboard firefighting foams. New vessels (keel laid on/after that date) must be PFOS‑free on delivery.
Existing vessels must remove and replace any PFOS foam by the first survey after 1 January 2026.
However, the EU’s broader regulation means that as from 23 October 2025, ALL PFAS-containing foams can no longer be brought aboard civil vessels in EU ports. This is the most restrictive deadline for most operators.
Lab testing: LC-MS/MS to detect and quantify PFOS, and a TOP assay can show hidden PFAS precursors.
Given the broader EU restrictions, it’s worth testing for all PFAS compounds, not just PFOS.
The foam must be removed, replaced with a compliant alternative, and your IHM (Inventory of Hazardous Materials) updated.
Remember: even if you can technically use existing PFAS foam until 2035, as of 23rd October 2025, you cannot bring new PFAS foam aboard in EU ports.
Most existing deck-foam systems on civilian vessels are built for Newtonian (low-viscosity) foam concentrate. Most fluorine-free foams that meet IMO/MED standards are non-Newtonian. Moving from one to the other is a real change to how your onboard fire protection system handles the foam, not just a case of adjusting proportioner settings.
Check compatibility properly: proportioning ratios, pick-up tubes, pump and concentrate compatibility, and whether your existing proportioning equipment can handle the different flow behaviour. A commissioning check (proportioning check, backpressure test) before changeover is good practice, same as before, but budget for the possibility that proportioning equipment itself needs modifying, not just recalibrating.
If possible, check with the manufacturer or supplier in the first case. Otherwise, yes.
Given the EU’s broader PFAS restrictions, a TOP (Total Oxidisable Precursor) assay is now highly recommended, not just optional. This identifies oxidisable PFAS precursors (chemical ‘building blocks’ that can break down into PFAS like PFOS or PFOA). This helps with future‑proofing and disposal planning.
If the CoA is recent and credible, you may not need additional testing for SOLAS compliance.
However, for the broader EU regulations, you need to confirm the foam is free of all PFAS compounds, not just PFOS. For older foams (especially pre‑2010) or where documentation is incomplete, a verification test covering all PFAS is essential.
Keep a simple pack: any correspondence with the foam manufacturer or supplier; recent PFAS test results or CoA (covering all PFOS, not just PFOS); replacement product documentation; disposal consignment notes; any flushing/cleaning records; and an updated IHM.
Make sure your planned maintenance system reflects the change.
Yes – and we recommend it. Many vessels are moving to fluorine‑free foams ahead of deadlines to simplify compliance and reduce environmental exposure. Given that you can no longer bring PFAS foam aboard in EU ports, switching to fluorine-free foams now simplifies compliance and eliminates environmental concerns.
We’ll advise on selection and changeover so performance and compatibility are maintained.
We can supply fluorine-free firefighting foam concentrate in 200- or 20-litre drums at 3% or 6% mixing rates matched to your system and approvals. Please contact us with details of your requirements.
At an EU port: you can’t legally bring PFAS-containing foam aboard. If you need to top up or replace foam while in an EU port, it has to be fluorine-free. That’s been the case since 23 October 2025 and hasn’t changed.
At a UK port: nothing has changed yet. The HSE published its opinion on a UK REACH restriction in July 2026, proposing a 10-year transition period for foam already on board vessels before any restriction takes effect (matching the EU’s approach). But that’s a proposal, not law. It’s out for public consultation, and until a restriction is actually made under UK REACH, current rules for bringing foam aboard at UK ports stand as they are.
If you operate in and out of both UK and EU ports, plan around the EU rules now. They’re confirmed and they’re the tighter constraint.
Need advice or a quote?
Contact Star today. We’ll help you make a smooth, compliant switch.
Last updated: July 2026. Regulations continue to evolve. We recommend checking for updates regularly or contacting our team for the latest guidance.
