| 1 | Column I point (v) | perfluorooctane sulfonic acid and its derivatives (PFOS), as listed in this Annex. | perfluorooctane sulfonic acid (PFOS), its salts and PFOS-related compounds as listed in this Annex |
| 2 | Column 4 point 3 | For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA-related compounds equal to or below 20 mg/kg (0,002 % by weight)… This exemption shall be reviewed and assessed by the Commission no later than 25 August 2023.
| For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA-related compounds equal to or below 20 mg/kg (0,002 % by weight)… |
| 3 | Column 4 point 4 | For the purposes of this entry, Article 4(1), point (b), shall apply to concentrations of PFOA and its salts equal to or below 1 mg/kg (0,0001 % by weight)… | For the purposes of this entry, Article 4(1), point (b), shall apply to concentrations of PFOA and its salts equal to or below 1 mg/kg (0,0001 % by weight)… 4a. For the purposes of this entry, Article 4(1), point (b), shall apply to concentrations of PFOA or any of its salts equal to or below 1 mg/kg (0,0001 % by weight) and to concentrations of any individual PFOA-related compound or combination of PFOA-related compounds equal to or below 10 mg/kg (0,001 % by weight) where they are present in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems. This limit value shall apply until 3 August 2028. 4b. For the purposes of this entry, Article 4(1), point (b), shall apply to the sum of the concentration of PFOA, its salts and PFOA-related compounds equal to or below 10 mg/kg (0,001 % by weight) where they are present in fluorine-free fire-fighting foam and originate from fire-fighting equipment which has undergone cleaning in accordance with the best available techniques. |
| 4 | Column 4 point 6 | By way of derogation, the use of PFOA, its salts and PFOA-related compounds shall be allowed in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, including both mobile and fixed systems, until 4 July 2025, … | By way of derogation, the use of PFOA, its salts and PFOA-related compounds shall be allowed in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, including both mobile and fixed systems, until 3 December 2025, … “firefighting foam” means any mixture to fight fires with foam and includes but is not limited to firefighting foam concentrates and firefighting foam solutions to produce the foam |
| 5 | Column 4 point 10 | For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA and its salts and/or PFOA-related compounds equal to or below 2 mg/kg (0,0002 % by weight)… This exemption shall be reviewed and assessed by the Commission no later than 22 February 2023
| For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA and its salts and/or PFOA-related compounds equal to or below 2 mg/kg (0,0002 % by weight)… |
On July 14, 2025, an amendment was announced modifying the requirements for PFOA listed in Annex I (Prohibited Substances) of the EU POPs Regulation. This measure appears to provide a transitional period and realistic thresholds for residual PFOA present in firefighting foams.
Regulation Overview
The EU POPs Regulation (Persistent Organic Pollutants, Regulation (EU) 2019/1021) is based on the Stockholm Convention and addresses the prohibition, restriction, release reduction, and waste management of persistent organic pollutants (POPs).
Persistent Organic Pollutants (POPs) are substances that, once released into the environment, accumulate and pose serious risks to both ecosystems and human health.
Examples of chemicals identified as POPs include:
Pesticides (e.g., DDT)
Industrial chemicals (e.g., PCBs – polychlorinated biphenyls)
Unintended by-products generated from manufacturing, combustion, or decomposition processes (e.g., dioxins and furans)
Key amendment details
Commission Delegated Regulation (EU) 2025/1399
Date of Publication: July 14, 2025
Entry into force: August 3, 2025
Changes Related to PFOS
Clarification of the definition and scope of “firefighting foam,” changes to the applicable requirements for firefighting foams, and allowance for continued use of articles already in use without additional restrictions even after the expiration of existing exemptions (see table below).
Column I point (v)
perfluorooctane sulfonic acid and its derivatives (PFOS), as listed in this Annex.
perfluorooctane sulfonic acid (PFOS), its salts and PFOS-related compounds as listed in this Annex
Column 4 point 3
For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA-related compounds equal to or below 20 mg/kg (0,002 % by weight)…
This exemption shall be reviewed and assessed by the Commission no later than 25 August 2023.For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA-related compounds equal to or below 20 mg/kg (0,002 % by weight)…
Column 4 point 4
For the purposes of this entry, Article 4(1), point (b), shall apply to concentrations of PFOA and its salts equal to or below 1 mg/kg (0,0001 % by weight)…
For the purposes of this entry, Article 4(1), point (b), shall apply to concentrations of PFOA and its salts equal to or below 1 mg/kg (0,0001 % by weight)…
4a. For the purposes of this entry, Article 4(1), point (b), shall apply to concentrations of PFOA or any of its salts equal to or below 1 mg/kg (0,0001 % by weight) and to concentrations of any individual PFOA-related compound or combination of PFOA-related compounds equal to or below 10 mg/kg (0,001 % by weight) where they are present in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems. This limit value shall apply until 3 August 2028.
4b. For the purposes of this entry, Article 4(1), point (b), shall apply to the sum of the concentration of PFOA, its salts and PFOA-related compounds equal to or below 10 mg/kg (0,001 % by weight) where they are present in fluorine-free fire-fighting foam and originate from fire-fighting equipment which has undergone cleaning in accordance with the best available techniques.
Column 4 point 6
By way of derogation, the use of PFOA, its salts and PFOA-related compounds shall be allowed in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, including both mobile and fixed systems, until 4 July 2025, …
By way of derogation, the use of PFOA, its salts and PFOA-related compounds shall be allowed in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, including both mobile and fixed systems, until 3 December 2025, …
“firefighting foam” means any mixture to fight fires with foam and includes but is not limited to firefighting foam concentrates and firefighting foam solutions to produce the foam
Column 4 point 10
For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA and its salts and/or PFOA-related compounds equal to or below 2 mg/kg (0,0002 % by weight)…
This exemption shall be reviewed and assessed by the Commission no later than 22 February 2023For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA and its salts and/or PFOA-related compounds equal to or below 2 mg/kg (0,0002 % by weight)…
Column 4 point 11
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Articles containing PFOA, its salts or PFOA-related compounds already in use in the Union before or on the date of expiry of the relevant exemption laid down in points 5(a) to (d) may continue to be used.