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News | REACH Annex XVII Adds New PFAS Restrictions, Effective October 23, 2025
Author.
LCS
Source:
Post time:
2025-11-06
On October 3, 2025, the European Union published the (EU) 2025/1988 Amendment Act in its official gazette. Annex XVII of REACH added Article 82 restrictions on perfluoroalkyl substances and polyfluoroalkyl substances (PFAS) in fire foam. This amendment will come into effect on October 23, 2025.
Perfluorinated and polyfluoroalkyl substances (PFAS) are defined as any substance containing at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom (which is not connected to any H/CI/Br/I atom).
The newly added terms are as follows:
1. From October 23, 2030, all fire foam with the total concentration of PFAS greater than or equal to 1mg/L shall not be put on the market and used.
The first paragraph does not apply to:
(a) Annex I of Regulation (EU) 2019/1021 covers perfluorooctane sulfonic acid (PFOS) and its salts and related substances, perfluorooctanoic acid (PFOA) and its salts and related substances, perfluorohexane sulfonic acid (PFHxS) and its salts and related substances;
(b) Item 68: C9-C14 PFCAs, their salts, and related substances;
(c) The 79th item pertains to the use of perfluorohexanoic acid (PFHxA), its salts, and related substances.
When determining the total concentration of all PFAS, the substances exempted in paragraph 2 should be included.
4. As an exemption from paragraph 1, the PFAS concentration in the fluorine free fire foam of the equipment (excluding portable fire extinguishers) that has been cleaned with the best available technology shall not exceed 50mg/L.
The committee should review this exemption before October 23, 2030.
As an exemption from the first paragraph, all PFAS with a total concentration greater than or equal to 1mg/L can be placed on the market under the following circumstances:
(a) Fire fighting foam in portable fire extinguishers before October 23, 2026;
(b) Alcohol resistant fire fighting foam in portable fire extinguishers before April 23, 2027;
(c) Before October 23, 2035, fire foam is used for:
(i) Institutions covered by Directive 2012/18/EU. Civil aviation (including civil airports) is not within the scope of this exemption;
(ii) Equipment belonging to the offshore oil and gas industry;
(iii) Military vessels;
(iv) Civil ships with fire foam on board before October 23, 2025.
6. As an exemption from paragraph 1, the sum of all PFAS ≥ 1mg/L can be used for the following fire foam:
(a) Before April 23, 2027:
(i) Training and testing, except for functional testing of fire protection systems, provided that all releases have been controlled;
(ii) Public fire services and private fire services performing the functions of public fire services, unless these services interfere with industrial fires in places covered by Directive 2012/18/EU and use foam and equipment only for this purpose;
(b) Portable fire extinguishers until December 31, 2030;
(c) For the situation mentioned in point (c) of paragraph 5, it is valid until October 23, 2035.
The committee should review the exemption under item (c) before the expiration of its validity period.
7. From October 23, 2026, according to point (c) of paragraph 1 and paragraph 6, the use of PFAS with a concentration greater than or equal to 1mg/L in fire foam shall comply with the conditions of this paragraph. Users should:
(a) Ensure that fire foam is only used for fires involving flammable liquids (Class B fires);
(b) Reduce the emissions of environmental compartments and the emissions of human direct and indirect contact with fire foam to the lowest level in technology and practice;
(c) Ensure that the unused fire foam and waste containing PFAS, including the waste water generated by the use of fire foam, are collected separately when technically and practically feasible, and ensure that they are treated to destroy or irreversibly convert PFAS components;
(d) For the use sites of fire foam containing PFAS, a special "Fire foam management plan containing PFAS" shall be formulated, which shall include:
(i) Details of the conditions of use and quantity of fire fighting foam on site, recording how the conditions specified in point (b) are met;
(ii) Information collected and appropriately processed based on point (c);
(iii) Provide a detailed description of the types and methods of equipment cleaning and maintenance;
(iv) Plan to be implemented in case of accidental leakage/overflow of fire foam, including relevant follow-up documents;
(v) A strategy of replacing PFAS containing fire fighting foam with fluoride free fire fighting foam.
The management plan should be reviewed annually and kept for at least 15 years at the request of the competent authority for inspection.
8. From October 23, 2026, all fire foam (excluding portable fire extinguishers) with the total concentration of PFAS ≥ 1mg/L put on the market shall be identified according to paragraph 10. Unless otherwise specified by the Member State concerned, the logo shall be written in the official language of the Member State where the fire foam is put on the market.
9. From October 23, 2026, fire foam users with PFAS shall ensure that unused fire foam and the inventory of waste containing PFAS (including wastewater) generated by the use of fire foam are labeled according to the provisions of paragraph 10, provided that the total concentration of all PFAS is greater than or equal to 1mg/L. Unless otherwise specified by the Member State concerned, the label shall be written in the official language of the Member State. The Member State shall produce the unused fire foam and waste containing PFAS (including waste water) produced by the use of fire foam, and shall dispose of them.
For paragraphs 8 and 9, the label should include the following wording: "Warning: Contains per - and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS”。 These pieces of information should be labeled in a visible, clear, and indelible manner.
For the purpose of this provision, the following definitions shall apply:
(a) Portable fire extinguisher "refers to a fire extinguisher designed for manual carrying and operation, with a working mass not exceeding 20 kilograms and complying with EN3-7 standards; Mobile fire extinguishers not exceeding 150 liters, in compliance with EN-1866 standard; Spray fire extinguisher meets EN-16856 standard;
(b) "Fire fighting foam" refers to any mixture of foam for extinguishing fire, including but not limited to fire fighting foam concentrate and fire fighting foam solution for producing foam;
(c) "Unused fire fighting foam inventory" refers to fire fighting foam that has not been used for fire fighting.
Original link: hppt://eur-lex.europa.eu/eli/reg/2025/1988/oj/eng
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