Understanding shipboard foam regulations
When it comes to firefighting foams for shipboard use, many marine surveyors feel uncertain about new and upcoming regulation and how it affects their clients.
In addition to the new International Maritime Organisation’s regulations on PFOS in shipboard firefighting foams, there are also new EU regulations on PFAS, and the UK’s Health and Safety Executive is currently in a consultation period concerning its draft legislation on PFAS.
Many countries have also issued their own PFAS regulations or plan to do so, so the regulatory landscape is complex, contradictory and fragmented.
Contents:
- IMO PFOS Regulations
- IMO PFAS Regulations
- HSE draft regulations
- Potential issues with fluorine-free foams for marine vessels
- Safe disposal of PFOS and PFAS firefighting foams
- Recap
IMO PFOS Regulations
January 1st 2026 saw the introduction of the International Maritime Organisation’s global ban on shipboard firefighting foams which contain PFOS. In practice, this should be relatively straightforward to enforce, provided appropriate testing is undertaken where necessary.
PFOS is a degradation or end product of various C8-based fluorosurfactants and precursors which are used to manufacture firefighting foams based on an eight-atom long carbon chain structure. The manufacture of these AFFF-C8 foams has been prohibited under the Stockholm Convention since 2015. This is because PFOS is classified as a Persistent Organic Pollutant. If a vessel was built after 2015, in a country which signed up to the Convention, it should, therefore, not have an AFFF-C8 foam on board. That said, some counties which signed the Convention have not subsequently ratified it, so there is a chance that a vessel may still be carrying a C8 foam. Countries in this position include the USA, Israel, Brunei and Malaysia. The UK does not have a separate listing as it was an EU signatory to the Convention.
In the case of older, pre-2015, vessels, there are two possibilities for Marine Surveyors to consider. The first is that the vessel may be equipped with a C8 AFFF or AR-AFFF foam, which contains PFOS. Firefighting foams are generally expected to have a working lifespan of 10 years, but they can be used for longer provided they are regularly tested, and the foam remains viable, so some of these C8 foams may still be in use.
The second situation is slightly more complex in that the vessel may be using a newer C6 foam. These foams are based on a six-atom carbon chain and do not contain intentionally added PFOS. However, it is possible that when the vessel’s foam stocks were changed from a C8 foam to a C6 foam, that the tanks and pipework were not cleaned thoroughly, meaning that residual traces of PFOS are still present. The residual levels may mean that
even though the vessel carries a compliant AFFF-C6 foam, it still has unacceptable levels of PFOS present.
The IMO regulations state that for new ships, defined as where the keel is laid on or after 1st January 2026, compliance with the requirement to use a firefighting foam which does not contain PFOS is immediate upon delivery. This could be a C6 foam or a fluorine-free foam. For existing ships, where the keel was laid before 1st January 2026, compliance must be by the first survey on or after 1st January 2026. Testing for PFOS, either in the form of a C8 foam or as residues, should form part of the survey procedure.
The advice to Marine Surveyors who are faced with the possible presence of PFOS containing C8 foams or residues is to contact a certified foam testing laboratory, who can arrange testing and advise on further action. Test samples can be taken at sea and couriered from the port to the testing house. This allows adequate time for testing and, in the event that PFOS is detected, removal can be planned to minimise operational downtime.
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IMO PFAS Regulations
As the new IMO PFOS regulation applies globally, the situation is relatively straightforward for marine surveyors, vessel owners and operators. The situation with AFFF-C6 firefighting foams is rather more fragmented. New legislation is in place or planned in a host of different countries, states and jurisdictions. This, as we shall see, can represent a particular challenge for marine vessels which travel internationally, since they may be required to comply with several different sets of regulations that conflict with each other.
Let’s start with the new EU- PFAS in firefighting foam regulation, which were published in October 2025. This lays out a series of transition periods for the phasing out of PFAS containing firefighting foams across different industries and sectors. The length of the transition period directly correlates with the degree of difficulty in substituting a fluorine-free foam that offers equivalent extinguishment characteristics to a foam which contains PFAS. Broadly speaking, the greater the hazard presented by a sector, the longer the transition period. The sectors with the longest transition periods, set at 10 years, are SEVESO III/ COMAH sites, offshore oil installations and marine vessels.
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The HSE’s draft regulations
In August 2025, the UK’s health and safety authority published its draft regulation on the use of PFAS in firefighting foam. The document, entitled, ‘Annex 15 Restriction Report, Proposal for a restriction Per and polyfluoroalkyl substances (PFAS) in firefighting foams’, runs to over 400 pages.
The HSE is currently in a consultation period until February 18th 2026. This allows interested parties scope to respond to the proposed approach. Following the consultation period, they intend to publish their final regulation within 12 months, so UK legislation could be in place by early 2027.
While the HSE has taken a broadly similar approach to the EU, there is one significant different that affect the marine sector. Rather than the 10-year transition period for civil marine vessels laid down by the EU, the HSE proposes a 5-year transition period for civil shipping and a similar period for naval vessels. This may well give rise to operational difficulties, particularly where vessels travel internationally.
Globally, many countries are introducing their own regulations, much of which follows a similar approach to the EU legislation. Some countries have decided to implement much shorter transition periods, so marine surveyors will need to familiarise themselves with local regulations. Industry sources believe that the IMO will move to bring in global legislation on the use of PFAS in shipboard firefighting foam systems, which would significantly simplify matters. It is also expected that this may take some time.
Interestingly, the EU regulation originally proposed a five year transition period for marine vessels which have existing foam systems on board but considered this to be too short given the required modifications to the foam system which can only be carried out during drydock. Therefore, the European Commission favoured a ten year transition period. There is a compelling argument that the UK’s legislation should match this, given the relative scarcity of dry dock facilities.
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Potential issues with fluorine-free foams for marine vessels
There are a number of questions that marine surveyors are likely to be asked by their clients about their shipboard firefighting foams. The most pressing one is likely to centre around whether a vessel should adopt a fluorine-free foam at the first opportunity or hold off until nearer the end of the allowed transition period.
While there are fluorine-free foams available on the market, there are a number of safety, operational and commercial issues with their performance that have given rise to the EU implementing a 10-year transition period.
Firstly, a fluorine-free foam cannot simply be dropped in to replace an AFFF foam. Fluorine-free foams are sometimes more viscous than AFFF foams and can only be delivered in a gentle, rather than a forceful, manner. Additionally, it can take a greater volume of fluorine-free foam to extinguish a fire because it uses a different extinguishment mechanism. In essence, using a fluorine-free foam may mean that a fire takes longer to extinguish because of the gentle application method. Taken together, these factors may mean that there’s a requirement for up to twice as much foam to be stored on board to meet the SOLAS requirements of vessels carrying 20 minutes’ worth of foam where gas suppression systems are also in use and 30 minutes where no gas suppression system is present. In addition to larger or more numerous foam tanks, the existing delivery system such as pipework, nozzles and the proportioning system may need to be reengineered. This can mean that a move to fluorine-free foam can be expensive and involve a period of retrofitting and crew training because of the difference in application methods.
The majority of civil and naval vessels proportion their foam concentrate with sea water. This is a further reason behind the longtransition period. Currently fluorine-free foams to not offer the same level of performance when using seawater. Furthermore, they become more viscous at lower temperatures and may tend to be more difficult to direct in windy conditions. Therefore, the local climactic conditions would need to be fully considered before transitioning.
The HSE’s draft proposal also covers military vessels, proposing a five year transition period, again shortening the EU’s published10-year transition period. Again, this proposal is open for feedback until February 18th, 2026. In July 2024, the U.S. Government Accountability Office (GAO), published a report stating that while the Department of Defense has worked on a fluorine-free military specification foam, it had concluded that fluorine-free foams did not meet performance needs and that ocean-going vessels were exempt and would continue to use AFFF-C6 foams.
Vessels which use several ports, particularly when in the cases of cargo vessels, tankers, ferries and cruise ships might be best advised to make the most of the transition period. Not only may they find that while they are operating in compliance with PFAS regulations in one port, but they may be non-compliant in the next. As well as presenting operational issues, this may also impact on the validity of insurance, so transitioning towards a fluorine-free foam is a complex matter that requires considerable research before a decision is made.
A further complication stems from the incompatibility of fluorine-free foams. Unlike AFFF-C6 foams which are mostly compatible, many fluorine-free foams cannot be mixed. Should a foam be discharged, it may need to be topped up with the same foam from the same manufacturer. It will be necessary to ensure that the chosen fluorine-free foam is available in each port the vessel berths in.
Just as when changing from a C8 foam to a C6 foam, tanks, pipework and delivery systems should undergo a specialist cleaning regime that includes PFAS/TOP Assay testing before the tanks are restocked with a fluorine-free foam. This ensures that residual PFAS levels are below the legal limits.
All this is not to say that fluorine-free foams will not be suitable for some vessels. A vessel operating in a warm freshwater environment may well be able to transition to fluorine-free foam just now. Similarly, a vessel carrying portable foam fire extinguishers could replace their current extinguishers with fluorine-free versions as these are premixed with potable water and most likely to be used on small fires.
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Safe disposal of PFOS and PFAS firefighting foams
The final reason that may make retaining a PFAS foam more attractive is the requirement to dispose of any discarded foam according to local regulations. In the UK, this involves shipping foam containers via a licensed waste contractor to a high temperature incinerator site. Currently there are only two such sites in the UK which accept foam waste and the process is expensive.
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Recap
In conclusion, it’s clear that advising clients on transitioning to fluorine-free foam is not a simple matter. There are a great many factors, from primary concerns like safety to operational and commercial issues and potential conflicts between various regulatory jurisdictions that require careful consideration. New fluorine-free foams are in development, and the transition periods should allow the development of fluorine-free foams which match the performance of AFFF foams. The smart approach may be to wait and see.
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Where to find out more
Individual country legislation:
- Consult the governmental agency which deals with maritime safety and legislation.
Note that some counties legislate on a state by state or provincial level.
