It sounds dramatic, but in practice this is manageable – if you start planning now. From January 1, 2026, it will be prohibited to use or store fire-extinguishing media containing PFOS above 10 mg/kg (0.001% weight). This applies to both fixed systems and portable equipment, and "fire-extinguishing media" includes foam.

⚠️ IMPORTANT TO KNOW

  • Applies to: SOLAS vessels, HSC Code craft, fixed systems and portable equipment
  • Deadline: First survey (annual/periodical/renewal) on or after January 1, 2026
  • Documentation: PFOS-free declaration from manufacturer or laboratory test must be ready

What is PFOS, and why is it being banned now?

PFOS is part of the PFAS group – the so-called "forever chemicals". They don't break down in nature and accumulate in water, soil, and living organisms. The problem isn't just environmental: PFOS is also linked to health risks in humans.

Therefore, IMO is now prohibiting PFOS in fire foam above a threshold of 10 mg/kg (0.001% weight). In short: old AFFF foam from before 2010 almost always contains PFOS and must be replaced. IMO has adopted amendments to SOLAS II-2/10.11 and the HSC Code introducing the ban from 2026.

Who is affected – and when does the deadline apply?

The ban applies to vessels and equipment covered by SOLAS and the HSC Code.

The timeline is simple, but the consequence is important:

  • New builds (keel laid on/after January 1, 2026): Must be PFOS-compliant at delivery
  • Existing vessels (keel laid before January 1, 2026): Must be compliant by first survey on/after January 1, 2026

This means that if your next survey is in March 2026, everything must be in order by then. The vessel will not pass survey without documentation that all foam is PFOS-free.

Why you can't just buy "a fluorine-free foam"

Many make a classic mistake here: they assume that "fluorine-free foam is fluorine-free foam". When foam is to be replaced in a fixed system, you must ensure that the new foam meets several requirements:

Mixing ratio

1%, 3%, or 6% – depending on what the system is designed for. Wrong mixing ratio = ineffective extinguishing.

Viscosity

Typically 3-7 cSt at 20°C. Too thick foam → pumps work too hard. Too thin foam → inaccurate dosing.

Approvals

Regular foam, alcohol-resistant, or multi-purpose – must match the application.

Preparation

Tanks and lines must be emptied and cleaned thoroughly before filling with new foam.

This is why we always start with a survey before recommending specific foam. We use BIOEX fluorine-free foam tailored to each specific need – depending on risk, system, and approval requirements.

What surveyors will require (and what happens if documentation is missing)

At the first survey on or after January 1, 2026, surveyors will require documentation that all fire foam – in both fixed systems and portable equipment – contains PFOS below 10 mg/kg.

✓ What is accepted:

  • Manufacturer's declaration from foam supplier
  • Laboratory analysis according to recognized standard
  • Technical data sheet showing PFOS-free product

✗ If documentation is missing:

  • Survey will not be approved
  • Certificate may be suspended
  • Vessel may be forced to dock

In other words, there is no "trial period" or "temporary exemption". Either you have control, or you won't pass survey.

What to do with the old foam

PFOS-containing foam should not just be emptied into sewers or sea. It must be treated as hazardous waste.

How to do it correctly:

  • Empty foam tanks properly at approved facility or via waste reception
  • Rinse tanks and lines thoroughly to remove residues
  • Deliver foam to approved hazardous waste reception
  • Document what has been delivered and keep receipts

Remember that the vessel's Inventory of Hazardous Materials (IHM) must be updated. PFOS-containing foam shall be listed as long as it exists onboard, and removed from the list when documented disposed of. EU's ship recycling regulation (EU SRR 1257/2013) also requires IHM to be updated before change of owner or scrapping.

Survey checklist: 5 steps to PFOS control before survey

These steps help you map and document PFOS status. For implementation of the actual replacement, see our 5-step foam replacement service.

1

Map systems

Fixed systems and portable equipment. Document with photos and locations.

2

Gather documentation

PFOS-free declarations, data sheets, and approvals for each product.

3

Test where missing

Take samples and send to accredited lab. Above threshold? Plan replacement.

4

Plan replacement

Select correct fluorine-free foam and plan emptying, cleaning, and filling.

5

Handle waste correctly

Deliver to approved reception, get receipt, and update IHM.

Need help with implementation? Moray handles the entire process from survey to fully documented replacement. See our complete service →

What happens next: PFOA and other PFAS

It's important to be precise: the SOLAS amendment from January 1, 2026 applies to PFOS, not "all PFAS". At the same time, regulations are tightening in several areas:

  • PFOA in fire foam was banned in Norway from July 5, 2025 (with further specifications in regulations from the Norwegian Environment Agency)
  • Other PFAS substances will likely follow – EU and IMO are working on extended bans that may come into force around 2032

In short: the trend is clear. Fluorine-free alternatives are becoming the standard, and those who wait to plan will face increasingly strict deadlines.

How Moray can help you now

We can take you from "uncertainty" to clear documentation and completed replacement:

  • Survey of existing foam and systems (incl. fixed systems and portable equipment)
  • Recommendation of correct fluorine-free foam, for example BIOEX or other solutions based on application and approvals
  • Check of technical compatibility (mixing ratio, viscosity, system requirements)
  • Practical support during replacement (emptying, cleaning, filling)
  • Disposal via approved reception + documentation ready for survey

Need help with PFOS survey and replacement?

We help maritime customers become PFOS-compliant before first survey in 2026.

Sources and references