Prohibition of the use of perfluorooctane sulfonic acid (PFOS) in fire-extinguishing media
- Home
- Latest updates
- News
- Prohibition of the use of perfluorooctane sulfonic acid (PFOS) in fire-extinguishing media
From the 1 January 2026, the International Maritime Organization (IMO) amendments to SOLAS Chapter II-2 (Construction – fire protection, fire detection and fire extinction) and the High-Speed Craft (HSC) Code (1994 and 2000) will come into effect. These amendments introduce a ban on the use of perfluorooctane sulfonic acid (PFOS) in fire-extinguishing media, aiming to reduce environmental and health risks associated with persistent chemicals found in certain fire-fighting foams.
This ban covers all fixed and portable fire-extinguishing equipment, including stored fire-fighting foams, that contain PFOS above 10 mg/kg (0.001% by weight).
Applicability
These new requirements apply to all vessels that must comply with SOLAS Chapter II-2. Specifically, this applies to cargo vessels of 500 GT and above engaged on international voyages, and passenger vessels carrying more than 12 passengers. Additional requisites include:
- For new ships, where the keel is laid on or after 1 January 2026, PFOS-containing fire-extinguishing media must not be installed or carried on board.
- For existing ships, the ban is applicable from the date of their first Cargo Ship Safety Equipment Certificate (CSSEC) survey (annual, periodic or renewal) or Passenger Ship Safety Certificate (PSSC) survey after 1 January 2026.
Ships certified under the HSC Code will also be subject to the ban. For these vessels, the requirement takes effect from the date of their first HSC Safety Certificate survey (annual, periodical or renewal) carried out on or after 1 January 2026.
Requirements
By this date, applicable vessels must ensure that:
- They have evidence that all fire-extinguishing media on board are PFOS-free, or that arrangements have been made for the safe disposal of any prohibited media.
- Any replacement fire-extinguishing media or equipment is appropriately type-approved.
- The vessel’s Inventory of Hazardous Materials (IHM) is updated following the removal of any PFOS-containing media, as applicable.
Ongoing compliance
To demonstrate ongoing compliance, extinguishing media carried on board should be accompanied by a manufacturer’s declaration that includes details such as the media type, production period, batch number, and reference to Type Approval or Marine Equipment Directive (MED) Certificate. This declaration must be kept on board and made available to attending surveyors for verification that the fire-extinguishing media does not contain PFOS above 10 mg/kg (0.001% by weight).
For extinguishing media installed before 1 January 2026, where a manufacturer’s declaration or laboratory test report is unavailable, sampling and testing must be conducted in accordance with a recognised standard to verify compliance with the PFOS limit.
NON-SOLAS Vessels and European Union (EU) regulations
Although the IMO ban does not apply to non-SOLAS vessels, Members operating within the EU should be aware that separate regional legislation applies to the use and storage of PFAS-containing fire-fighting foams under the EU REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation (EU) 2025/1988 – PFOS in Firefighting Foams. The regulation addresses per- and polyfluoroalkyl substances (PFAS), which are a broad chemical family of synthetic compounds, of which PFOS is one specific substance.
Under the EU REACH, the restrictions are not vessel or size-specific and cover the manufacture, import, supply and use of PFAS-containing fire-fighting foams within EU territory, including on any vessel operating, berthing or being maintained in EU waters. In addition, this regulation prohibits foams containing more than 1 mg/L PFAS from 23 October 2030, with limited exemptions extending between 2026 and 2035. These exemptions include ships already carrying PFAS-containing foams on board prior to the regulation’s entry into force, which may permit continued use for a limited period before a complete phase-out.
Vessel operators trading to or within EU ports should therefore ensure that any fire-fighting media carried or used on board comply with both the IMO requirements and the broader obligations under the EU REACH. Members are advised to contact the Club’s local correspondent in the relevant region for confirmation of how these requirements apply to their vessels.
If Members have any questions on how to comply with these requirements, they can contact the Club’s Loss Prevention team at lossprevention@shipownersclub.com.