The UK Proposes Restriction for PFAS in Firefighting Foams

By Susana Planas MunGavin BSc., MSc, Senior Regulatory Specialist, Supply Chain Team, UL Solutions

On Aug. 18, 2025, the Health and Safety Executive (HSE), in their role as the UK REACH Agency, released the report on the restriction proposal relating to the use of Per- and Polyfluoroalkyl Substances (PFAS) in firefighting foams (FFF), referred to as Annex 15 report.

PFAS are being defined, for the UK restriction proposal, as any substance that contains at least one fully fluorinated methyl (-CF3) or methylene (-CF2-) carbon atom without any hydrogen, chlorine, bromine, or iodine atom attached to it, as per the OECD (2021) definition. The HSE considers that adopting a broad definition will minimise risks from potential non-substitution of the use of PFAS that are not currently known to be used in firefighting foams, but which have the same risks as those already identified.  Also, the agreed international common definition of PFAS, as they represent a global environmental and safety concern, is essential to reduce any further burden on industry and aid regulatory compliance and risk management actions.

Firefighting foams covered under this restriction proposal include those products produced by mixing liquid foam concentrate, water, and air at the point of use. Other forms of non-liquid-based fire suppression systems, such as gaseous suppression systems, are not within the scope of this proposal, even if they contain PFAS.

This restriction proposal has been released for public consultation, which will be open for comments over a period of six months until 23:59 London time on Feb. 18, 2026.

The Agency has published the Annex 15 restriction report, which is structured into 7 main sections, each addressing PFAS-related issues, as follows:

• Section 1 includes an introduction to the global issues of concern relating to PFAS.
• Section 2 includes PFAS hazard assessments evaluating both human health and environmental hazards, as well as exposure assessments. Projected quantities used in Great Britain vary by sector, mainly including those released from fire and rescue services, specific major petrochemical and chemical industries covered under the Control of Major Accident Hazards (COMA) Regulations 2015, offshore oil and gas platforms and pipelines, marine firefighting vessels and aircraft rescue and firefighting services, and ultimately, military and defence operations.
• Section 3 provides an overview of hazard exposure reports. Overall, up to 48 tonnes of PFAS-containing foams have been identified to be released into the environment during storage, incidents, training or maintenance, either directly, or after disposal into the sewer network.
• Section 4 includes risk characterization considerations, including Persistent, Mobile and Toxic (PMT) or very Persistent, very Mobile (vPvM) type concerns which could be considered equivalent to the other types of concerns included in Article 57(a) to (e) of UK REACH with regard to the identification of Substances of Very High Concern (SVHCs).
• Section 5 provides an analysis of alternatives that may be used, along with their human health and environmental hazards, including technically feasible fluorine-free mixtures. The Agency is proposing to restrict placing on the market and use of PFAS as a constituent in firefighting foam, adhering to sector and use-specific transition periods, in line with those derived from the EU restriction, to support an orderly transition and ensure that users can adapt to suitable alternatives without compromising safety.

Transition periods vary according to each sector. For example, ready-to-use hand-held and portable fire extinguishers (defined by BS EN3-7, BS EN 1866 and BS EN 1685 standards) would have a 6-month transition period before the entry into force of PFAS placing-on-the-market restrictions take effect, and a 5-year transition period for use restrictions. For chemical industries, a 5-year transition period is envisaged for placing-on-the-market restrictions, and a longer 10-year transition period for use restrictions at COMAH sites and offshore oil and gas installations. Other industries would have a 5-year transition period for use restrictions.

Section 6 includes socioeconomic analysis, and the final conclusions of the report are exposed in Section 7.

Manufacturers, downstream users (including chemical formulators), distributors (such as retailers), importers, and exporters of firefighting equipment containing PFAS, as the general public exposed or using such equipment placed on the market, are encouraged to be aware of potential hazards and restrictions on the use of PFAS.

The Agency concludes that a restriction under UK REACH is appropriate, and the proposal will be adopted following the public consultation of Annex 15 report.  The Agency is expected to formulate a technical opinion on the suggested restriction within 12 months of the publication of Annex 15 report.

Stakeholders interested in submitting comments may complete the online survey available from the HSE website:

PFAS in firefighting foam (FFF) restriction proposal - Page 1 of 4 - Health and Safety Executive - Citizen Space

References

PFAS restriction proposal public consultation of August 18, 2025

Annex 15 restriction report proposal for a restriction on PFAS in firefighting foams (FFF)

Annexes to Annex 15 report