PFAS ban on firefighting foam: which deadline applies to you
Public fire services stop using PFAS foam on 23 April 2027, Seveso sites on 23 October 2035. From 23 October 2026 a management plan and labels are required.
Regulation (EU) 2025/1988 bans firefighting foam that contains 1 mg/L of PFAS or more, and the end date depends on who uses the foam. Public fire services and all training and testing stop on 23 April 2027. Industrial sites outside the Seveso directive stop on 23 October 2030, Seveso establishments on 23 October 2035. A zone or site that still uses PFAS foam after 23 October 2026 needs a management plan, labelled stock and separate collection of its foam waste.
The deadlines in one table
The regulation entered into force on 23 October 2025 and added entry 82 to Annex XVII of REACH. The limit is 1 mg/L for the sum of all PFAS, in the concentrate as well as in the foam solution. The PFHxA limits of Regulation (EU) 2024/2462 stay in place alongside it.
| Date | What happens | Legal basis |
|---|---|---|
| 10 April 2026 (passed) | PFHxA (C6) limits apply to foam for training, testing and public fire services | Regulation 2024/2462, entry 79, paragraph 4 |
| 23 October 2026 | Further use only under conditions: class B fires, separate collection, management plan, labels. End of placing on the market in portable extinguishers | Entry 82, paragraphs 7 to 10 and 5(a) |
| 23 April 2027 | End of use for training, testing and public fire services | Entry 82, paragraph 6(a) |
| 23 October 2030 | General end of placing on the market and use, civil aviation included | Entry 82, paragraph 1 |
| 31 December 2030 | End of use in portable extinguishers | Entry 82, paragraph 6(b) |
| 23 October 2035 | End of the derogation for Seveso establishments, offshore oil and gas, military vessels and civilian ships with foam on board before 23 October 2025 | Entry 82, paragraphs 5(c) and 6(c) |
The table shows the rules as they stand on 2 October 2026 and is not legal advice. For your own case, read the text of Regulation (EU) 2025/1988 or ask the competent authority. The Belgian health ministry has a summary page on the ban (in Dutch and French) that links to the European technical guide.
Public fire services: 23 April 2027 at the latest
A fire zone may use PFAS foam until 23 April 2027. Paragraph 6(a) grants that period to "public fire services and private fire services exercising the function of public fire services, except where those services intervene at industrial fires at establishments covered by Directive 2012/18/EU and the use of the foams and the equipment for that purpose only". According to recital 34, public services should still be allowed to use PFAS foam for ten years at those fires in Seveso establishments. In practice the exception means a separate stock and separate equipment.
For a C6 foam the date has already passed. Regulation 2024/2462 limits PFHxA, the C6 chemistry, to 25 ppb for PFHxA and its salts and 1000 ppb for PFHxA-related substances. Since 10 April 2026 those limits apply to foam for training, testing and public fire services, with the same two exceptions. According to recital 9 of the 2025 regulation, industry stakeholders report that the PFAS in foams "mostly belong to the C6 chain length category". Entry 82 does not lift the older rule: see its paragraph 2(c).
In Belgium, the federal civil security directorate wrote to all zone commanders on 15 October 2025. Its letter (in Dutch) says that a zone still using PFAS foam during the transition period must draw up a yearly management plan from 23 October 2026.
Training and testing stop on the same date for everyone
Training and testing with PFAS foam end on 23 April 2027 for every user, Seveso sites included. With C6 foam they ended on 10 April 2026. The exception reads: "training and testing, except functional testing of the firefighting systems provided that all releases are contained". The paragraph gives no separate end date for that contained functional test, so ask the competent authority before you rely on it.
Our advice is to stop training with operational concentrate altogether. BIO T is a fluorine-free training concentrate with deliberately reduced extinguishing properties: the fuel re-ignites quickly and the crew can repeat the drill. It is not for real fires. Our training foam concentrate is fluorine-free and biodegradable and works at low, medium and high expansion.
Seveso establishments until 2035, other industry until 2030
An establishment covered by the Seveso directive (2012/18/EU) may buy and use PFAS foam until 23 October 2035. Belgium has 396 such establishments according to seveso.be. Recital 19 gives the reason for the long period: for these sites and for offshore installations, the availability of suitable alternatives "has not yet been fully demonstrated". The date does not cover training, and civil aviation is excluded. The conditions that start on 23 October 2026 apply in full.
A site that is not a Seveso establishment falls under the general date of 23 October 2030. The company fire team of a logistics site is an example. In both cases we would use the remaining years to test fluorine-free foam on the liquids actually stored on site, and not leave the changeover to the last year.
Portable extinguishers have their own dates
Foam extinguishers follow a separate calendar, and we do not sell them. PFAS foam may be placed on the market in portable extinguishers until 23 October 2026 (alcohol-resistant foam until 23 April 2027), and existing units may stay in use until 31 December 2030. The regulation counts hand-held units up to 20 kg and wheeled units up to 150 litres as portable. The 50 mg/L allowance for cleaned equipment, described below, does not apply to them. Your extinguisher maintenance company is the one to ask.
What changes on 23 October 2026
From 23 October 2026, paragraph 7 ties further use of PFAS foam under paragraph 1 and paragraph 6(c) to four conditions. The foam is for class B fires only, emissions and exposure are reduced "to as low a level as is technically and practically possible", and stock and waste are collected separately. The fourth condition is a "PFAS-containing firefighting foams management plan" for the place of use, which must contain:
- the conditions of use and the volumes of foam on site
- how stock and waste are collected and treated
- how the equipment is cleaned and maintained
- what is done in case of a leak or spill
- a strategy for replacing PFAS foam with fluorine-free foam
The plan is reviewed every year and kept available for inspection for at least 15 years.
Unused stock and PFAS waste, wastewater included, go to a treatment that destroys the PFAS or transforms it irreversibly. Recital 39 states that biological wastewater treatment and incineration below 1100 °C should be excluded. Old stock is therefore not something to pour away or to use up at a drill. Leaving the drums on the shelf is no way out either: recital 30 recalls that storage counts as "use" under REACH. Hand the stock to a waste company that documents the destruction, and file that document with the plan.
From the same date, stock and waste at or above 1 mg/L carry a label. The wording is fixed and must be visible, legible and indelible: "WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS". The label is written in the official language or languages of the Member State, unless that state decides otherwise.
Cleaning: the 50 mg/L limit and PFAS rebound
Fluorine-free foam from equipment that held PFAS foam before may contain up to 50 mg/L of PFAS, if the equipment was cleaned "in accordance with best available techniques" (paragraph 4). The Commission reviews this allowance by 23 October 2030.
The letter to the zone commanders explains why it exists. PFAS clings to the inner walls of tanks and pipes. Even after intensive cleaning, residues can stay behind, migrate into the new fluorine-free foam and over time push it over the legal limit. The letter calls this PFAS rebound and describes it as a gradual process, so one analysis right after refilling does not settle the matter. Have the foam analysed again later.
For the cleaning itself, BIOEX describes a protocol: drain the tank, flush tank and pipes with hot water, scrub where possible and have the rinse water analysed by a laboratory. That rinse water is PFAS waste. For a pick-up hose or a small mobile foam unit or inline inductor, replacement can be simpler than cleaning.
What to do now
- List every drum, IBC, vehicle tank, premix tank and mobile unit, with its concentrate, volume and year. The safety data sheet usually tells you whether it contains fluorosurfactants. Without a sheet, or when in doubt, have a sample analysed.
- Find your end date per use in the table. A zone with a Seveso site in its area can have two.
- If you keep PFAS foam after 23 October 2026, write the management plan and label the stock. Have the rest collected and keep the proof of treatment.
- Clean or replace the equipment and have the result analysed.
- Choose the fluorine-free concentrate for your risk. ECOPOL is a fluorine-free, alcohol-resistant concentrate for class A and class B fires. BIO FOR N is a class A concentrate for solid materials. BIOEX itself warns that changing to fluorine-free foam "is not a 'drop-in' replacement for AFFFs": check the performance on your own liquids and the fit with your proportioning and discharge equipment. The alternatives are compared in types of firefighting foam.
- Check the proportioning with the new concentrate. Set the inductor to the rate on the data sheet (ours are adjustable from 0 to 6 %) and pair it with a foam nozzle of the same flow: 200, 400 or 800 l/min. Our article on the inline foam inductor describes the set-up.
Send us the list from step 1 with the make of your inductors and foam nozzles, and we will propose a concentrate and the settings that go with it.
Frequently asked questions
How long may a fire brigade keep using PFAS foam?
Until 23 April 2027 under Regulation (EU) 2025/1988. For C6 foam, the PFHxA limits of Regulation (EU) 2024/2462 have applied to public fire services since 10 April 2026. The exception in both rules is an industrial fire at a Seveso establishment, with foam and equipment kept for that purpose only.
What must the PFAS foam management plan contain?
The conditions of use and the volumes of foam on site, the collection and treatment of stock and waste, the cleaning and maintenance of the equipment, the measures for a leak or spill, and the strategy for switching to fluorine-free foam. The plan is required from 23 October 2026, reviewed every year and kept for at least 15 years.
How do I dispose of old AFFF stock?
Collect it separately, label it from 23 October 2026 and hand it to a waste company for a treatment that destroys the PFAS or transforms it irreversibly. According to the recitals of Regulation (EU) 2025/1988, biological wastewater treatment and incineration below 1100 °C should be excluded. Do not pour it into the sewer and do not use it up in training.
Can I use fluorine-free foam in my existing equipment?
Yes, after cleaning. Residues on tank and pipe walls can migrate into the new foam (PFAS rebound), which is why the regulation allows up to 50 mg/L of PFAS in foam from cleaned equipment instead of 1 mg/L. BIOEX states that fluorine-free foam "is not a 'drop-in' replacement for AFFFs", so check the proportioning rate and the foam quality with the new concentrate.
