Phase-out of PFAS-containing firefighting foams: deadlines, transition, and waste management

MSDS-Europe – Compass to chemical safety – Phase-out of PFAS-containing firefighting foam

In autumn 2025, the EU adopted restrictions on the use of per- and polyfluoroalkyl substances (PFAS) in firefighting foam. Depending on the application, the transitional periods may range from 1 to 10 years.

For companies, the key priorities are rapid inventory, selection of a fluorine-free alternative, system cleaning, and compliant management of rinse water and legacy foam to prevent environmental release.

Key takeaways

The EU introduced a phased restriction on PFAS-containing firefighting foam, with transition periods between 1 and 10 years depending on use.
Replacing legacy firefighting foam is not just a procurement task; cleaning, flushing and verification are also required.
Waste management is one of the main project risks, especially where large volumes of rinse water are generated.
Companies should start with inventory, risk assessment and documentation to make the transition traceable and auditable.

What is PFAS, and why is firefighting foam under regulatory pressure?

PFAS (per- and polyfluoroalkyl substances) are a large group of man-made compounds known for their exceptional stability and persistence.

According to international policy summaries, PFAS are receiving global regulatory attention due to their high persistence and their potential to accumulate in the body.

They became widely used in firefighting foam because their film-forming properties help separate oxygen from the fire, while their heat resistance also supports extinguishing performance. At the same time, PFAS-containing firefighting foam can release persistent substances into the environment, where they may remain for a long time and enter the food chain.

Why is this topic urgent now? According to the European Commission, firefighting foam is a significant source of PFAS emissions, and without restrictions several hundred tonnes per year could enter the environment.

What does the EU restriction mean in practice?

In early October 2025, the European Commission adopted the REACH measure concerning PFAS in firefighting foam.

The regulation does not impose an immediate total ban. Instead, it introduces a phased phase-out with different transitional periods depending on the application. According to the Commission’s summary, the transition may range from 12 months up to 10 years.

Key deadlines and transition periods

The Danish environmental authority (Miljøstyrelsen) provides a plain-language breakdown of the main phase-out milestones:

23.10.2025: entry into force of the regulation; transitional periods are calculated from this date.
23.10.2026: ban on placing on the market portable fire extinguishers containing PFAS firefighting foam.
23.04.2027: stricter rules for training and testing, with a limited exception where all emissions can be contained.
23.10.2030: end of the general transitional period where no specific derogation applies.
23.10.2035: end of the longer transition for certain critical, high-risk uses, such as Seveso establishments, offshore oil and gas, and naval vessels.

Key message for companies: even during the transitional period, emissions to the environment are expected to be minimised.

What does “PFAS-free” mean in practice?

The regulatory logic can also be approached through concentration thresholds. For example, the Danish authority highlights threshold values that may differ depending on system type, such as new versus existing systems.

How can PFAS-free status be substantiated?

The “PFAS-free” claim should be verifiable through the Safety Data Sheet (SDS), manufacturer statements and, where necessary, analytical testing.
Compliance is not just about the composition of the new foam, but about the outcome of the entire transition process, including draining, cleaning, rinse water treatment and documentation.

Why is the transition not a simple foam replacement?

Replacing PFAS-containing firefighting foam is typically a project, not a simple procurement task.

Cleaning and cross-contamination risks

If a system such as a tank, piping network or proportioner previously contained PFAS firefighting foam, residual contamination may transfer into the new fluorine-free extinguishing agent. For this reason, planned cleaning and flushing is usually required after draining, with controlled containment of rinse water.

The German Umweltbundesamt guidance updated in February 2026 provides a practical framework for questions companies commonly face, including identifying involvement, available time, analytics, cleaning and disposal.

Equipment and system compatibility

Fluorine-free firefighting foam, often referred to as fluorine-free foam or F3, may behave differently from legacy AFFF. In practice, companies should review, at minimum:

proportioner settings,
nozzles and foam generation,
pumps and filters,
commissioning tests and training requirements.

Temporary continued use during the transition period

Authority summaries indicate that continued use of PFAS-containing firefighting foam during the transitional period may trigger additional requirements, such as a management plan. The practical priority is technical control of emissions through containment and closed handling, so routine operation does not become a pollution event.

Company action plan for a compliant transition

The following sequence supports low operational risk and strong traceability.

1. Rapid inventory and audit

Identify where foam concentrate is stored and where fixed foam fire suppression systems are installed.
Review which products are present based on SDSs, supplier or manufacturer statements, and historical procurement records.
Check whether foam drills or tests have been carried out in recent years and where firefighting water or rinse water was discharged.

2. Risk assessment: where is the transition critical?

Flammable liquids, tank farms and dangerous goods warehouses generally represent higher-risk transition environments.
In office-building-type environments, the transition may often be simpler and faster.

3. Selecting an alternative

According to the Commission’s position, PFAS-free alternatives are available, but a safe transition requires time and technical review. As a minimum, procurement should include:

performance evidence and intended use,
a compatibility statement for the existing system,
operational and maintenance conditions.

4. Implementation and verification

Recommended transition logic:

Draining and containment to avoid discharge to sewer or soil.
Cleaning and flushing according to a planned protocol.
Rinse water treatment, including temporary storage, transport and certificates.
Verification by measurement or other predefined acceptance criteria.
Refilling, followed by commissioning tests and staff training.

5. Waste management and documentation

From a compliance perspective, the goal is to ensure that PFAS does not simply migrate into another environmental compartment. According to the UK Environment Agency summary, landfilling and wastewater treatment do not destroy PFAS, meaning the compounds may persist and later re-enter the environment.

Points to agree in advance with the waste contractor:

packaging and transport conditions,
acceptance documents,
certificate of treatment or disposal,
relevant waste coding, including EWC classification.

Waste-management challenges companies should prepare for

Waste is not an administrative detail. In PFAS transition projects, it is often one of the main technical, financial and compliance risks.

Typical waste streams

legacy foam concentrate and mixtures,
rinse water, often representing the highest volume,
contaminated filters, seals and absorbents,
potentially contaminated soil or debris from previous incidents.

Disposal options and limitations

The Austrian Umweltbundesamt highlights that PFAS-containing, or suspected PFAS-containing, firefighting foam stocks must be managed under the appropriate regulatory framework, for example via specialised hazardous waste incineration.

According to the UK Environment Agency, high-temperature incineration (HTI) is the only option capable of destroying PFAS at scale, and even then only under strict operating conditions.

What does this mean for companies?

Waste treatment capacity should be checked early in the project.
Scheduling with service providers is advisable due to capacity and compliance constraints.
Documentation of quantities, routes and certificates is critical from both reputational and authority perspectives.

Legacy contamination risks

If foam training was regularly carried out on-site in the past, or firefighting water routing was not controlled, companies should at least:

collect historical information on when, where and how much foam was used,
prepare a sampling plan for soil, groundwater and surface water where relevant,
implement immediate risk-reduction measures such as drain closure and containment.

Official communications also emphasise that, during the transitional period, emissions should be minimised and expired or waste foam should be disposed of appropriately.

FAQ – PFAS firefighting foam transition

How can I identify whether the firefighting foam contains PFAS?

The first step is to review the Safety Data Sheet (SDS) and the manufacturer’s statement. If the documentation is incomplete, outdated, or the system has been refilled multiple times, targeted analytical testing may be justified. In practice, uncertainty about the product is often one of the greatest project risks.

Is it enough to simply replace the foam concentrate?

Usually not. Residual contamination in piping, tanks and system components may cause cross-contamination and compromise the fluorine-free status of the new foam. A compliant transition usually requires draining, cleaning, flushing and verification.

What is the earliest deadline that can affect companies?

The phase-out affects different applications at different times. For example, the ban on placing on the market portable fire extinguishers containing PFAS firefighting foam applies from 23.10.2026, while stricter training and testing requirements appear from 2027.

What should be done with rinse water and firefighting water?

The objective is to prevent uncontrolled discharge to sewer, soil or surface water. The Environment Agency highlights that wastewater treatment does not destroy PFAS, so the correct route typically involves containment, temporary storage and organised transport for treatment or disposal.

How should legacy PFAS-containing foam be disposed of?

Authority summaries typically point to specialised hazardous waste incineration under appropriate technological control as the main route. Landfill or wastewater-type routes do not destroy PFAS and may simply move the problem further downstream.

Why is waste management one of the biggest transition challenges?

PFAS transition projects often generate both foam waste and large volumes of rinse water. Since PFAS destruction is technically complex and effective at scale only under strict conditions, waste management should be costed, planned and scheduled already at the project-design stage.

Summary: what is the safest company strategy?

Inventory and involvement assessment across products, systems and historical use.
Selection of a fluorine-free alternative that meets fire-protection and system-compatibility requirements.
Professional cleaning and rinse water management with proper containment.
Securing the waste route through contracts, certificates and traceability.
Documentation and training so the entire transition remains auditable.

If the company has multiple sites, different system types and legacy stocks, the transition should be managed as a dedicated project with clear responsibilities.

Need support with PFAS-related compliance tasks?

Our team can help you review documentation, support transition-related compliance tasks, and improve traceability across chemical safety processes.

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