Ban on the use of PFAS substances in firefighting foams

PFAS and REACH: discover Regulation (EU) 2025/1988, which restricts the use of PFAS. What is the deadline for firefighting foams (2030), and what are the critical exemptions you need to know about?

Geoffrey Ponthier
Consultant HSE
Publication : 
17.11.2025
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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With the goal of eliminating all non-essential uses of PFAS, Regulation (EU) 2025/1988 of October 2, 2025, amends Annex XVII of the REACH Regulation—which covers restrictions on the manufacture, placing on the market, and use of certain dangerous substances, mixtures, and articles—to include PFAS substances in their entirety.

In this context, these substances may not be placed on the market or used from October 23, 2030 in firefighting foams at a concentration equal to or greater than 1 mg/L for the sum of all PFAS. However, this date must be viewed in light of the introduced exemptions, for which the associated prohibition or market-entry dates may prove more restrictive or more flexible depending on the equipment involved or the context of its use.

What are we talking about?

Firefighting foam refers to any mixture intended for fire suppression, including, but not limited to, firefighting foam concentrates and firefighting foam solutions used to produce foam.

Which substances are affected?

Any substance containing at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom (without any H/Cl/Br/I atoms attached to it).

However, the prohibition as of October 23, 2030 does not apply to:

·       perfluorooctane sulfonic acid (PFOS), its salts, and PFOS-related compounds (C8F17SO3X);

·       perfluorooctanoic acid (PFOA), its salts, and PFOA-related compounds;

·       perfluorohexane sulfonic acid (PFHxS), its salts, and PFHxS-related compounds;

·       linear and branched perfluorocarboxylic acids with the formula CnF2n +1-C(= O)OH where n = 8, 9, 10, 11, 12, or 13 (C9-C14 PFCA), including their salts and combinations;

· to undecafluorohexanoic acid (PFHxA), its salts, and PFHxA-related substances.

Indeed, these substances are already subject to restrictions under Annex I of Regulation 2019/1021 (for PFOS, PFHxS, and PFOA) or Annex XVII of the REACH Regulation (for PFCAs and PFHxA).

Nevertheless, these substances are included when determining the total concentration of all PFAS.

Are there any exemptions to the usage ban?

PFAS may be used in firefighting foams at a concentration equal to or greater than 1 mg/L for the sum of all PFAS:

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Additional measures to be implemented

As of October 23, 2026, for the PFAS usage bans effective October 23, 2025, and October 23, 2035, the use of PFAS-containing firefighting foams (with the notable exception of those in portable fire extinguishers) at a concentration equal to or greater than 1 mg/L for the sum of all PFAS must comply with the following conditions:

  • the user must ensure that firefighting foams are used only for fires involving flammable liquids (Class B fires);
  • the user must reduce emissions into the environment and direct or indirect human exposure to firefighting foams to the lowest level technically and practically possible;
  • the user must ensure the separate collection of unused firefighting foam stocks and PFAS-containing waste, including wastewater resulting from the use of firefighting foams, whenever technically and practically possible, and ensure they are treated so that the PFAS content is destroyed or irreversibly transformed;
  • the user must establish a "PFAS-containing firefighting foam management plan" specific to the site where the PFAS-containing foams will be used. This management plan must be reviewed annually and kept for at least fifteen years for inspection by competent authorities upon request.

Furthermore, as of that same date, all users of PFAS-containing firefighting foam (including portable fire extinguishers) must ensure that unused firefighting foam stocks and PFAS-containing waste, including wastewater resulting from the use of firefighting foams, are labeled when the concentration of the sum of all PFAS is equal to or greater than 1 mg/L (label written in the official language(s) of the Member State(s) where the unused firefighting foam stocks and PFAS-containing waste are generated and will be treated).

This labeling must include the following statement:

"WARNING: Contains per- and polyfluoroalkyl substances (PFAS) at a concentration equal to or greater than 1 mg/L for the sum of all PFAS."

This information must be displayed in a visible, legible, and indelible manner.