PFOS prohibited in fire-extinguishing media from 1 January 2026

On 1 January 2026 new amendments to SOLAS Chapter II-2 as well as the 1994 and 2000 High Speed Craft (HSC) Codes will enter in force prohibiting the use or storage of fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS). Read more about the ban of PFOS in this news.

Information for: Ship owners and managers as well as ship yards, suppliers and flag states.

The IMO has adopted amendments to SOLAS Chapter II-2 as well as the 1994 and 2000 High Speed Craft (HSC) Codes that prohibit the use or storage of fire-extinguishing media containing PFOS. The purpose of the amendments is to protect people on board against exposure to dangerous substances used in firefighting and to minimize the impact of fire-extinguishing media that are deemed detrimental to the environment.

The amendments will enter into force on 1 January 2026.

What is PFOS?

PFOS is part of a group of related chemicals that contain carbon, fluorine and other elements, known as perfluorinated and polyfluorinated alkyl substances (PFAS).

They are known as “forever chemicals” , as they are extremely persistent within the environment and human bodies, potentially leading to health problems.

PFOS has been used for a variety of products, including firefighting foams, due to its surface-active properties and surface resistance/repellency to oil, water and grease. PFOS is recognized as hazardous to humans, wildlife and the environment.

New fire-extinguishing media requirements

A prohibition against the use or storage of fire-extinguishing media containing PFOS has been introduced in SOLAS Regulation II-2/10.11 and the 1994/2000 HSC Code Ch.7.9. “Fire-extinguishing media” includes any firefighting foams on board the vessel. “Containing perfluorooctane sulfonic acid (PFOS)” means PFOS present in concentrations above 10 mg/kg (0.001% by weight).

The prohibition enters into force on 1 January 2026 and applies to fixed fire-extinguishing systems and portable firefighting equipment.

Verification that such extinguishing media are not used or stored on board the vessel will require DNV to review the manufacturer’s declaration or laboratory test reports. These shall be provided to DNV by either an owner, a ship/repair yard, or the foam-maker in each specific case.

The PFOS-free declaration issued by the foam manufacturer shall contain information about the firefighting foam, such as the foam type, production period, batch number and reference to the Type Approval (TA) / Marine Equipment Directive (MED) Certificate for the foam.

For extinguishing media installed before 1 January 2026 for which the manufacturer’s declaration or laboratory test report is not available, sampling and testing of the extinguishing media on board must be conducted in accordance with a recognized standard (e.g. NPR-CEN/TS 15968).

Application for newbuildings

Ships constructed (keel-laid) on or after 1 January 2026 and subject to compliance with SOLAS or the 1994/2000 HSC Code shall not be equipped with any firefighting foams containing PFOS in concentrations above 10 mg/kg (0.001% by weight) upon the ship’s delivery.

Application for vessels in operation

Ships constructed (keel-laid) before 1 January 2026 and subject to compliance with SOLAS or the 1994/2000 HSC Code shall comply with the new requirement no later than the first survey on or after 1 January 2026.

“First survey” is the first annual, periodical or renewal survey for the Cargo Ship Safety Equipment Certificate, Cargo Ship Safety Certificate, Passenger Ship Safety Certificate, or HighSpeed Craft Safety Certificate.

By the first survey on or after 1 January 2026, ship owners, managers and operators shall have evidence that the firefighting foams within the fixed fire-extinguishing systems and portable firefighting equipment on board are PFOS-free and shall have arranged for the safe disposal of any prohibited firefighting foams.

Please note that the flag administration may enforce these requirements for other vessel types.

Notes:

Under the EU Ship Recycling Regulation (EU SRR – Regulation (EU) No 1257/2013), the use of PFOS and its derivatives is already banned in new installations on EU-flagged ships. For existing ships, including non-EU-flagged vessels calling at EU ports, the presence of PFOS must be identified and recorded in the Inventory of Hazardous Materials (IHM). This requirement has been applied since 31 December 2020, with PFOS listed in Annex I of the EU SRR.

Guidance on foam replacement

Any fire-fighting foam containing PFOS in concentrations above 10 mg/kg (0.001% by weight) shall be disposed of using the appropriate shore-based reception facilities, as identified by the local authorities. The removal and subsequent delivery to an appropriate shore-based reception facility shall be duly recorded in the ship’s official logbook.

If the foam in a fixed fire-extinguishing system needs to be replaced, the following shall be ensured:

• The tank shall be emptied and cleaned properly before being refilled with the new foam.
• The new foam shall have the same mixing ratio (for instance 1%, 3% or 6%).
• The new foam shall have a similar viscosity to the previous foam (otherwise new foam pumps may be required and the foam mixing unit may need adjustment and verification).
• The new foam shall have equivalent approvals (approved as regular, alcohol-resistant or multi-purpose foam, as applicable).
• The new foam shall be type approved in accordance with the applicable IMO requirements: high-expansion foam in accordance with MSC/Circ.670 and low-expansion foam in accordance with MSC.1/Circ.1312 Corr.1.
• The TA/MED Certificate for the new foam shall clearly indicate the absence of PFOS.

Special requirements apply when replacing foam for an inside air foam system (IMO MSC.1/Circ.1271). This type of fireextinguishing system is approved for a particular pressure range, set of generators and for use with a specific type of foam. Information about acceptable foam, such as brand, type and mixing rate is listed in the TA/MED Certificate for the inside air foam system. Only the exact same type of foam as listed in the TA/MED Certificate can be used as replacement foam.

Future potential requirements

It should be noted that the newly introduced requirements of SOLAS Regulation II-2/10.11 and the 1994/2000 HSC Code Ch.7.9 do not prohibit the use or storage of all PFAS chemicals, only those products containing PFOS.

Regulatory bodies such as the EU and others are working towards further restrictions on the use of other chemicals in the PFAS group, such as perfluorooctanoic acid (PFOA). This may impact the delivery and availability of firefighting foams from EU ports to ships. A similar ban will be discussed in the IMO, with an estimated target date for any implementation in 2032 if agreed upon.

More information will follow once new requirements are adopted and implemented by EU ports, flag states and/or the IMO.

Recommendations

By the first survey on or after 1 January 2026, ship owners/ managers/operators shall have evidence that the firefighting foams within the fixed fire-extinguishing systems and portable firefighting equipment on board are PFOS-free and shall have arranged for the safe disposal of any prohibited firefighting foams.

By the first survey on or after 1 January 2026, ship owners/ managers/operators shall have evidence that the firefighting foams within the fixed fire-extinguishing systems and portable firefighting equipment on board are PFOS-free and shall have arranged for the safe disposal of any prohibited firefighting foams.

• MSC.532(107) – Amendments to SOLAS Chapter II-2
• MSC.536(107) – Amendments to 1994 HSC Code
• MSC.537(107) – Amendments to 2000 HSC Code
• IACS Unified Interpretation SC309 for SOLAS Regulation II-2/10.11
• IACS Unified Interpretation HSC11 for Regulation 7.9.4 of HSC Codes (1994 and 2000)
• MSC.1/Circ.1694 – Unified Interpretations of SOLAS Chapter II-2 and the HSC Codes (1994 and 2000)
• EU SRR – Regulation (EU) No 1257/2013