How to document PFOS-free fire-extinguishing foam on board

At the first safety equipment survey* after 1 January 2026, all fire-extinguishing foams on board must be PFOS-free, and this must be verified by the attending surveyor. Compliance will prevent part-held surveys and/or Conditions of Authority. Here is a short summary of how to document compliance. This news is a follow up of our news from November 2025.

Information for: Owners/managers, shipyards, manufacturers, and flag states.

18 Statutory

NEED TO KNOW
  • All firefighting foams on board (fixed systems and portable equipment) must be documented as PFOS‑free, either by a manufacturer’s declaration, an accredited laboratory test or a TA/MED certificate stating PFOS‑free status. Foams without acceptable documentation must be replaced.
  • Documentation must be traceable to the actual foam on board.

The requirement to document PFOS-free fire-extinguishing foams applies to all types of foam on board, i.e. both fixed systems and portable equipment.

Briefly summarized, there are three ways to document PFOSfree foam:

  1. A PFOS-free declaration is provided by the manufacturer of the foam.
  2. The foam can be sampled and tested according to a recognized standard by an accredited laboratory and concluded to be PFOS-free through a laboratory test report confirming that the PFOS concentration in the foam is below 10 mg/kg (0.001% by weight).
  3. Although not required, the type approval (TA) or Marine Equipment Directive (MED) certificate for the foam may state that it is PFOS-free. If this is the case, it is considered equivalent to a PFOS-free declaration.

If none of the above can be provided successfully, the foam will need to be replaced with PFOS-free foam, with documentation according to 1), 2) or 3) above.

For the DNV surveyor to verify that the PFOS documentation corresponds to the actual foam on board, the documentation must contain sufficient information to trace it to the foam in use. Such information may include the manufacturer, foam type, production date / batch number and relevant TA/MED certificate references. Furthermore, the marking of and documentation for the foam(s) carried on board must include adequate information to demonstrate traceability back to the PFOS documentation.

DNV has prepared a template that can be used by manufacturers to prepare the PFOS-free declaration. The template is attached to this news. It is not mandatory to use this template – it simply aids you in ensuring the necessary information is provided.

For more information on the retroactive requirement, reference to relevant regulations, guidance for changing foam, etc., please read our previously issued news (see reference below).

Recommendations

To avoid follow-up actions, Conditions of Authority or part-held surveys, preparation should start early to ensure the necessary documentation for all foams on board is in place before the survey.

References

DNV Technical and Regulatory News No. 37, November 2025: PFOS prohibited in fire-extinguishing media from 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 High-Speed Craft Safety Certificate.