A straightforward guide to the new regulations
A summary of EU & IMO firefighting foam regulations for the offshore and marine sectors and SEVESO III/COMAH sites
Video summary
- Q1. Can I still use C6 AFFF firefighting foam?
- Q2. Can I still use C8 AFFF?
- Q3. What are the EU REACH and UK HSE regulations?
- Q4. My sector has a long transition period: should I transition to a fluorine free foam now?
- Q5. Are there sectors where fluorine free foams are the preferred option?
- Q6. What about offshore installations and shipping?
- Q7. What about SEVESO III and COMAH sites?
- Q8. What about IMO regulations?
- Q9. How can I ensure I am compliant and that my foam has not been unintentionally contaminated by C8 residues?
1. Can I still use C6 AFFF firefighting foam?
The short answer is yes. UK and EU regulations allow the continued use of C6 foams provided they:
- meet the current REACH and POPs regulations for unintentional trace contaminants (UTC) for PFOA, PFOS and PFHxS, and
- are within the sector specific transition periods set out by REACH and the UK HSE UK and EU regulations (see Q3 below)
UTC quantities can not exceed the figures below:
*ppm = parts per million; ppb = parts per billion
Oil Technics’ C6 foams have been tested and shown to comply with these regulations and fall well within the limits.
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2. Can I still use C8 AFFF?
No: legacy C8 foams are prohibited under the Stockholm Convention and ceased manufacture back in 2015. They may contain unintentional contamination or break down into substances such as PFOA and potentially PFOS, which are both POP listed.
If purchased before 2015, your foam may be prohibited C8 foam, but if purchased after that date there’s very little chance that it’s a C8 foam. There is, however, a possibility that your foam tanks still contain residues of C8 foam, which could contaminate your entire foam stock to above the permitted POPs levels.
If in doubt, submit a sample of your foam for PFAS TOP Assay testing: see Q9 below for more information.
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3. What are the EU REACH and UK HSE regulations?
EU REACH published their regulations on the 2nd October 2025, while the UK HSE completed a 6 month consultation period in February 2026 on their preferred approach to PFAS in firefighting foam - which aligns closely with the EU regulations.
In both cases, different sectors have different transition periods before they are required to move away from AFFFs to fluorine free foams (FFF). Where the risk to human life and assets is high, the transition period is considerably longer than lower risk environments. These transition periods are laid out below.
It is only at the date stated or conclusion of the transition period that a change to fluorine free from AFFFs becomes mandatory.
It should be noted that foam technology is advancing rapidly, so it may be advisable to wait for new generation foams to be in place before transitioning, especially given the safety, commercial and operational considerations involved.
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4. My sector has a long transition period: should I transition to a fluorine free foam now?
The short answer is no. Longer transition periods have been put in place because the current generation of fluorine free foams mostly have significant performance deficits compared to C6 foams.
The transition periods have been agreed to allow firefighting foam manufacturers time to develop new foams which offer the same level of effectiveness when it comes to extinguishing fires.
It should also be noted that the transition periods will be reviewed closer to their end date and may well be extended further if the quality of fluorine free foams has not improved sufficiently.
A straight substitution from C6 foam to fluorine free foam is not feasible. Beyond the typically reduced extinguishing performance — especially when used with seawater, non-aspirated delivery, or used in low temperature environments such as offshore platforms and marine settings — moving to fluorine free foam also introduces several commercial and operational challenges. These often include:
- Higher overall costs, both initial and ongoing.
- Increased storage requirements due to higher foam concentrate usage.
- Potential operational downtime resulting from necessary equipment changes.
- Proportioning challenges with existing systems.
- Complexity and added cost of system clean out to remove potential residue from previous products prior to changeover.
- Possible need to replace discharge devices which may be incompatible with fluorine free foams.
- Compatibility issues as, unlike most AFFFs, FFFs are generally incompatible with each other.
- Application specific concerns that may affect performance or compliance.
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5. Are there sectors where fluorine free foams are the preferred option?
There are some sectors where fluorine free foams are preferred and perfectly adequate in practice, as shown by the shorter transition periods given.
For example, fluorine free foams are suitable for most fire extinguishers and fire fighter training exercises, where the fire risk to be contained tends to be small and manageable.
If your sector has a transition period of greater than three years, it may be better to hold off until the regulations enforces you to do so and the technology behind fluorine free foams has developed further.
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6. What about offshore installations and shipping?
Currently, we are not aware of any fluorine free foam which performs adequately with forceful application, using seawater, in high winds and at low temperatures of -18ºC.
Some international standards specify testing with potable water, so it is important to check performance in the operational conditions and fuels in place, as using fluorine free foam may compromise safety. Some territories never experience such low temperatures and so this is not a concern - but fluorine free foams may still not perform adequately due to viscosity issues when used with forceful applications and seawater.
Oil Technics’ C6 AFFF-LF foams are formulated and well proven for use in extreme offshore conditions. They function effectively at -18ºC, in high winds and with seawater. We also offer IMO approved foams for shipping.
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7. What about SEVESO III and COMAH sites?
Given the complexities involved in any SEVESO III or COMAH site, a 10-year transition period has been confirmed within the EU (ending 23rd October 2035) with a similar 10-year transition period being proposed in the UK.
Individual risk and commercial assessments would be needed before any transition to a fluorine free foam, as the changeover is likely to involve additional foam storage and changes to the delivery system to allow for potentially slower extinguishment times, higher concentrations, viscosity issues and the necessity for gentle application.
With these issues to consider, it may be wiser to wait until nearer the end of the transition period before considering transitioning to an FFF.
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8. What about IMO regulations?
In regards to commercial vessels, IMO MSC 532(107) resolution clause 11.2.2 states that the ”use or storage of extinguishing media containing PFOS shall be prohibited” - this includes the prohibition of legacy C8 foams.
The IMO has since made a clarification that an allowable detection limit of < 10 ppm of PFOS, meaning high purity C6 AFFFs with PFOS levels below this limit can still be used on shipboard firefighting systems.
This resolution applies to new vessels from 1st January 2026. For existing vessels, C8 foams need to be replaced at their next survey.
The new EU REACH and UK HSE regulations also apply to both commercial and naval vessels.
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9. How can I ensure I am compliant and that my foam has not been unintentionally contaminated by C8?
It’s advisable to have a sample of your foam tested for PFAS content. Our independent Foam Testing Service can facilitate this: find out more here.
If your sample contains PFAS / C8 foam residues, we can suggest a tank cleaning protocol. This requires that you:
- dispose of the contaminated foam according to local regulations
- clean the tank with a specialised PFAS remover
- rinse thoroughly twice with hot water
- replace the foam with a compliant C6 AFFF foam or fluorine free foam as appropriate.
Using this protocol, we carried out a representative small scale tank cleaning exercise using Oil Technics’ micro-emulsion, aqueous cleaner PFAS Tank Cleaner.
After cleaning, the tank was filled with a fluorine free foam and a sample sent for TOP Assay testing. The results showed that, after one treatment with PFAS Tank Cleaner followed by two hot water flushes, total PFAS had been reduced to well below the allowable UTC level of <50 ppm.
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