With an amendment to Annex XVII of the REACH Regulation, a phased ban on PFAS substances in firefighting foam has come into effect. This ban applies to both the placing on the market and the use of PFAS-containing firefighting foam, ranging from portable fire extinguishers to large fixed fire extinguishing systems.
For HSE professionals, this means that existing fire extinguishing systems, stocks, and related procedures must be critically assessed and, where necessary, adjusted.
What are PFAS and why are they relevant?
PFAS (per- and polyfluoroalkyl substances) are chemical compounds that hardly break down in the environment. They accumulate in soil, water, and living organisms and are associated with health risks such as liver diseases, hormonal disruptions, and an increased risk of certain types of cancer.
In firefighting foam, PFAS are also highly mobile: when used, they can easily end up in groundwater and surface water. It is precisely this combination of environmental damage and health risks that has led to strict European regulations.
What is now prohibited?
PFOA
Since December 4, 2025, the use of firefighting foam containing the PFAS substance PFOA is prohibited.
Total PFAS concentration
In addition, a concentration limit of a maximum of 1 mg/l PFAS (sum of all PFAS) applies in firefighting foam and firefighting equipment. Firefighting foam that exceeds this limit may no longer be used or placed on the market. Organizations must therefore switch to PFAS-free alternatives.
The prohibitions are being phased in, depending on the application. The general main rule is that from October 23, 2030 no firefighting foam containing PFAS above the 1 mg/l limit may be placed on the market. For specific applications, different rules apply
Overview of main prohibitions (placing on the market)
|
Application |
Date |
|
Portable fire extinguishers |
6 April 2026 |
|
Portable extinguishers with alcohol-resistant foam |
23 April 2027 |
|
Supply to Seveso establishments, offshore oil and gas industry, military and civilian vessels |
23 October 2030 |
|
Exceptional applications (including existing installations) |
no later than 23 October 2035 |
Prohibitions on Use
In addition to the ban on marketing, prohibitions on use also apply, likewise phased in:
Application | Date |
Training and exercises (with the exception of functional tests with controlled discharge) | 23 April 2027 |
Portable fire extinguishers | 31 December 2030 |
Firefighting foam in existing Seveso installations, offshore oil and gas industry, military vessels and civilian ships (installed before 23-10-2025) | 23 October 2035 |
Additional obligations during the transition period
During the transition period (from 23 October 2026), additional requirements apply to organizations that still use PFAS-containing firefighting foam:
- Labelling
Equipment must be provided with the warning:
“WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration of 1 mg/l or more (sum of all PFAS).” - Use
PFAS-containing foam may only be used for fire class B and its use must be limited to the technically and practically achievable minimum. - Emission reduction
Emissions to the environment and exposure of humans and the environment must be reduced to the lowest achievable level. - Waste management
Unused firefighting foam, PFAS-containing waste, and wastewater must – as far as technically possible – be collected separately and processed in such a way that PFAS is destroyed or irreversibly transformed (for example, thermal treatment at approx. 1,100 °C).
For fixed installations, a management plan must also be drawn up. This plan should specify how PFAS-containing streams are managed, how maintenance and cleaning are carried out, how leaks and discharges are handled, and how the phase-out is to be achieved.
Who does this apply to?
These obligations apply to all organizations that use or store firefighting foam, regardless of company size or number of FTEs. This includes, among others:
- industrial companies with flammable liquids or chemicals;
- storage locations for hazardous substances;
- ports and logistics companies;
- organizations with fixed or mobile foam extinguishing systems;
- locations where firefighting foam is used during drills or emergencies.
In short: anyone who uses or manages firefighting foam falls under these rules.
What is still allowed – and what is not?
- Existing stocks
May still be used within the transition periods; Provided that emission restrictions, labeling, and management measures are complied with. - New products
May no longer be put into use if they exceed the PFAS threshold values. - Training and exercises
Are permitted to a limited extent and should preferably take place with PFAS-free alternatives.
The Human Environment and Transport Inspectorate (ILT) expects organizations to demonstrably work on phasing out and to have a clear schedule and documentation regarding this.
What is now concretely expected from organizations?
- Inventory
Map out all foam extinguishing products and installations, including PFAS content, location, and application. - Assessment and documentation
Determine which bans or transition periods apply and record what measures have been taken. - Replacement and disposal
Draw up a realistic transition plan for replacement with PFAS-free alternatives and ensure correct disposal. - Procedures and training
Update emergency plans, maintenance protocols, and instructions for staff. - Monitoring and supervision
Take ILT inspections into account and ensure that documentation is current and available.
Practical tips for HSE professionals
- Start with a risk and impact analysis per location and installation.
- Work with a phased transition plan towards completely PFAS-free.
- Document choices and measures carefully; this is essential for supervision and enforcement.
Conclusion
PFOA has been banned since December 2025. Portable extinguishers will follow no later than 2027 and for most other applications, all work must be completely PFAS-free by 2030 at the latest. The phase-out of PFAS-containing extinguishing foam is therefore not a future development, but a current obligation. Organizations that have not yet (fully) anticipated this are at risk in terms of compliance, environment, and supervision.
Lexerta supports organizations in providing insight into the current situation, interpreting the applicable obligations, and carefully securing and implementing the chosen approach.
