New EU Restriction on PFAS in Firefighting Foams

By Dr. Martina Schneider, Regulatory Affairs Manager, Supply Chain Team, UL Solutions

On Oct. 2, 2025, the European Union adopted a new restriction of PFAS in firefighting foams via COMMISSION REGULATION (EU) 2025/1988. The new REACH Annex XVII entry 82 covers Per- and polyfluoroalkyl substances (PFAS) defined as any substance that contains at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom (without any H/Cl/Br/I attached to it). The restriction will formally enter into force 20 days after publication in the Official Journal.

As of Oct. 23, 2030, PFAS shall not be placed on the market or used in firefighting foams in a concentration equal to or greater than 1 mg/L for the sum of all PFAS.

However, companies should be aware that earlier deadlines are required for certain uses and placing certain products on the market:

e.g. PFAS should not exceed 1 mg/L for the sum of all PFAS as of Oct. 23, 2026 in firefighting foams placed on the market in portable fire extinguishers and as of Apr. 23, 2027 in alcohol-resistant firefighting foams placed on the market in portable fire extinguishers.

Also, PFAS should not exceed 1 mg/L for the sum of all PFAS as of Apr. 23, 2027 for training and testing, except functional testing of the firefighting systems provided that all releases are contained.

As of Oct. 23 2026, firefighting foams in which the concentration is equal to or greater than 1 mg/L of the sum of all PFAS, that are placed on the market shall be labelled with the following statement: “WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS”. This also applies to existing stock of not-utilized firefighting foams.

The concentration of PFAS in fluorine-free firefighting foams originating from the equipment which has undergone cleaning in accordance with best available techniques, shall not exceed 50 mg/L for the sum of all PFAS.

Until now, certain PFAS have already been regulated under REACH Annex XVII and the POP regulation (Regulation (EU) 2019/1021). E.g. REACH Annex XVII entry 68 and 79 do cover certain subgroups of PFAS. The POPs regulation (Regulation (EU) 2019/1021) regulates perfluorooctane sulfonic acid (PFOS), its salts and related compounds, perfluorooctanoic acid (PFOA), its salts and related compounds and perfluorohexane sulfonic acid (PFHxS), its salts. So, the new REACH Annex XVII entry 82 does not apply in addition to the already regulated uses of these specific PFAS sub-groups of substances, since stricter regulation must already be adhered to.

Companies need to check what kind of PFAS is present in their firefighting foam and determine the applicable regulation and maximum allowable concentration. Action for transition should be taken as soon as possible.

Reference

Commission Regulation (EU) 2025/1988