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Fire-fighting foams contain fluorinated surfactants commonly known as PFAS (per- and polyfluoroalkyl substances). They are classified as "eternal pollutants" or "persistent organic pollutants" because they are persistent in the environment and can accumulate in living organisms.
European regulations restrict the use of these substances, particularly in fire-fighting foams.
What are we talking about?
According to European regulations 2019/1021 of June 20, 2019 (POP regulation) and 1907/2006 of December 18, 2006 (REACH), a fire-fighting foam is a mixture intended for fire-fighting, which includes, but is not limited to, fire-fighting foam concentrates and fire-fighting foam solutions capable of producing foam.
Several PFAS that may be present in your fire-fighting equipment are currently regulated.
You will find them in the following texts:
Exemptions still allow operators to use fire-fighting foams containing these PFOAs when they are intended for suppressing liquid fuel vapors and fighting liquid fuel fires (Class B fires) and already contained in systems, whether mobile or fixed, subject to compliance with the following conditions:
- Until December 3, 2025, when :
o they are not used for training; they are not used for testing, unless all discharges are contained ;
o it is possible to contain all associated rejects;
o stocks of fire-fighting foams which contain or may contain PFOA are managed in accordance with the waste provisions of the POP regulation.
- PFOA is present as an unintentional trace contaminant, and concentrations of PFOA or any of its salts are less than or equal to 1 mg/kg (0.0001% by mass), or concentrations of any PFOA-related compound or combination of such compounds are less than or equal to 10 mg/kg (0.001% by mass). This limit value applies until August 3, 2028.
In addition, a derogation from the ban on the use of PFOA is also possible for PFOA present as an unintentional trace contaminant and if the sum of the concentrations of PFOA, PFOA salts and PFOA-related compounds is less than or equal to 10 mg/kg (0.001% by mass) in fluorine-free fire-fighting foams from fire-fighting equipment that has been cleaned according to best available techniques.
Exemptions still allow operators to use fire-fighting foams containing PFHxS when they are present as unintentional trace contaminants in concentrations equal to or less than 0.1 mg/kg (0.00001% by mass), and when they are present in concentrated mixtures that are intended for use or are used in the production of other fire-fighting foam mixtures.
This derogation will be reviewed and assessed by the European Commission no later than August 28, 2026.
It is still possible to use fire-fighting foams containing PFHxA. But from April 10, 2026, it will no longer be possible to buy or use PFHxA, its salts and related substances when they are present above a certain concentration (≥ 25 ppb for PFHxA and its salts or ≥ 1000 ppb for the sum of related substances) in :
- fire-fighting foams and foam concentrates for training and testing purposes, with the exception of functional testing of fire-fighting systems, provided that all emissions are contained ;
- fire-fighting foams and foam concentrates intended for use by public fire services, except when these services are responding to industrial fires in Seveso establishments and using the foams and equipment only for this purpose.
Since July 4, 2025, the use of PFCAs in fire-fighting foams has been prohibited if their concentration is greater than or equal to 25 ppb for the sum of C9-C14 PFCAs and their salts, or 260 ppb for the sum of substances related to C9-C14 PFCAs.
Focus on the management of fire-fighting foams covered by the POP regulation
Stockpiles of fire-fighting foams which contain or may contain PFOA and PFHxS, their salts and/or related compounds for which no use is authorized must be managed in accordance with Article 7 of the POP Regulation. In particular, they must :
- be separated from other waste to avoid contamination,
- be disposed of or recovered without undue delay in such a way that the POPs they contain are destroyed or irreversibly transformed so that the remaining wastes and releases no longer exhibit the characteristics of POPs.
The following disposal and recovery operations are authorized:
- D9 Physico-chemical treatment,
- D10 Incineration on land,
- R1 Primary use as a fuel or other means of generating energy,
- R4 Recycling or recovery of metals and metal compounds under certain conditions.
Exemptions are possible under certain conditions.
Additional impact for operators of ICPE installations subject to authorization
We won't go back over the obligation to identify PFAS and analyze releases introduced by the Order of June 20, 2023 for ICPEs subject to authorization (see article: Substances PFAS: zoom sur les obligations).
It should also be noted that law no. 2025-188 of February 27, 2025 has modified the basis of assessment for the non-domestic pollution fee for persons operating a facility subject to ICPE authorization. When the activities of this person result in the discharge of PFAS substances into water, either directly or via a collection network, the fee is based on the mass of PFAS substances discharged per year.
The fee is set at 100 euros per 100 grams rejected.