[Regulation]Regulation update: EU REACH XVII revision (Ban on PFAS in firefighting foams)
15 Oct 2025
On October 3, 2025, the European Commission (EC) published Commission Delegated Regulation (EU) 2025/1988, which restricts the use of PFAS substances in firefighting foams.
When a specific substance is considered harmful to human health or the environment, an EU Member State or the European Chemicals Agency (ECHA) may propose a restriction
Following consultations (public comment period) and opinion development by the relevant committees, ECHA submits its recommendation to the European Commission (EC)
Once the recommendation is adopted, it is published in the EU Official Journal (OJ) and thereby becomes legally binding
Despite previous restrictions on certain PFAS substances (such as PFCA and PFHxA), approximately 60% of the total firefighting foams currently produced still contain PFAS. With the adoption of this regulation, it is estimated that around 13,200 tonnes of PFAS emissions will be prevented over the next 30 years. Details of the amendment to the list of restricted substances are as follows:
EU REACH Annex XVII: Addition of Entry 82 (PFAS)
Scope of application: Firefighting foams
Key Definitions
PFAS: Any substance that contains at least one fully fluorinated methyl (–CF₃) or methylene (–CF₂–) carbon atom
Firefighting foam: Any mixture used to fight fires with foam, including but not limited to firefighting foam concentrates and firefighting foam solutions used to produce the foam
Date of application: 23 October 2030
Applies to cases where the sum of all PFAS concentrations is equal to or greater than 1 mg/L
Grace Period: To ensure a smooth transition, sector-specific grace periods are provided.
Details on grace periods, labeling, and management obligations can be found in Table 1 and Table 2 below.
For specific subjects and requirements, please refer to the original text of the regulation.
Para.
Sub-para.
Use & Target
Grace Period allowed
4
-
PFAS Residues (≤ 50 mg/L) from Equipment Cleaned with Fluorine-free Foams
No specific restrictions (Subject to review by 23 October 2030)
5
(a)
Portable fire extinguishers
Until 23 October 2026
(b)
Alcohol-resistant firefighting foams (for use in portable fire extinguishers)
Until 23 April 2027
(c)(i)
Sites Covered by the Seveso Directive (Directive 2012/18/EU) (e.g., industrial facilities)
Until 23 October 2035
(c)(ii)
Offshore Oil & Gas Installations
Until 23 October 2035
(c)(iii)
Military vessels
Until 23 October 2035
(c)(iv)
Civilian Vessels Equipped Before 23 October 2025
Until 23 October 2035
6
(a)(i)
Training and Testing Purposes (Excluding functional testing; all releases must be fully contained)
Until 23 April 2027
(a)(ii)
Public and Semi-public Firefighting Services
Until 23 April 2027
(b)
Use of PFAS in Portable Fire Extinguishers
Until 31 December 2030
(c)
Cases Falling Under Section (5)(c) (Industrial, Offshore, Military, Civilian Vessels)
Until 23 October 2035
7
-
When Use is Still Permitted After 23 October 2030 (under exemptions) → PFAS Management Obligations Apply
Effective from 23 October 2026
[Table 1. Grace Periods for PFAS-containing Firefighting Foams]
Para.
Use & Target
Grace Period allowed
7
Establishment of PFAS-containing Firefighting Foam Management Plans Including separate collection of waste, minimization of discharges, and substitution strategies
Effective from 23 October 2026
8
Firefighting Foams Placed on the Market (excluding portable extinguishers) Mandatory PFAS warning label required
Effective from 23 October 2026
9
Unused Foams and Wastewater/Waste Stored by Users Labels must also be affixed
Effective from 23 October 2026
10
Label Statement: Must be clearly and permanently displayed
WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS
-
[Table 2. PFAS Labeling and Management Obligations]
On October 3, 2025, the European Commission (EC) published Commission Delegated Regulation (EU) 2025/1988, which restricts the use of PFAS substances in firefighting foams.
Date of publication: October 3, 2025
Date of entry into force: October 23, 2025
Regulation Overview
The EU REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals, EC 1907/2006) is an integrated chemical management system that establishes procedures for the registration, evaluation, authorisation, and restriction of chemical substances.
The process for designating a substance as a restricted substance is as follows:
When a specific substance is considered harmful to human health or the environment, an EU Member State or the European Chemicals Agency (ECHA) may propose a restriction
Following consultations (public comment period) and opinion development by the relevant committees, ECHA submits its recommendation to the European Commission (EC)
Once the recommendation is adopted, it is published in the EU Official Journal (OJ) and thereby becomes legally binding
[출처: ECHA Restriction Process]
Key Changes
Despite previous restrictions on certain PFAS substances (such as PFCA and PFHxA), approximately 60% of the total firefighting foams currently produced still contain PFAS. With the adoption of this regulation, it is estimated that around 13,200 tonnes of PFAS emissions will be prevented over the next 30 years. Details of the amendment to the list of restricted substances are as follows:
EU REACH Annex XVII: Addition of Entry 82 (PFAS)
Scope of application: Firefighting foams
Key Definitions
PFAS: Any substance that contains at least one fully fluorinated methyl (–CF₃) or methylene (–CF₂–) carbon atom
Firefighting foam: Any mixture used to fight fires with foam, including but not limited to firefighting foam concentrates and firefighting foam solutions used to produce the foam
Date of application: 23 October 2030
Applies to cases where the sum of all PFAS concentrations is equal to or greater than 1 mg/L
Grace Period: To ensure a smooth transition, sector-specific grace periods are provided.
Details on grace periods, labeling, and management obligations can be found in Table 1 and Table 2 below.
For specific subjects and requirements, please refer to the original text of the regulation.
4
-
PFAS Residues (≤ 50 mg/L) from Equipment Cleaned with Fluorine-free Foams
No specific restrictions
(Subject to review by 23 October 2030)
5
(a)
Portable fire extinguishers
Until 23 October 2026
(b)
Alcohol-resistant firefighting foams
(for use in portable fire extinguishers)
Until 23 April 2027
(c)(i)
Sites Covered by the Seveso Directive (Directive 2012/18/EU)
(e.g., industrial facilities)
Until 23 October 2035
(c)(ii)
Offshore Oil & Gas Installations
Until 23 October 2035
(c)(iii)
Military vessels
Until 23 October 2035
(c)(iv)
Civilian Vessels Equipped Before 23 October 2025
Until 23 October 2035
6
(a)(i)
Training and Testing Purposes
(Excluding functional testing; all releases must be fully contained)
Until 23 April 2027
(a)(ii)
Public and Semi-public Firefighting Services
Until 23 April 2027
(b)
Use of PFAS in Portable Fire Extinguishers
Until 31 December 2030
(c)
Cases Falling Under Section (5)(c)
(Industrial, Offshore, Military, Civilian Vessels)
Until 23 October 2035
7
-
When Use is Still Permitted After 23 October 2030 (under exemptions)
→ PFAS Management Obligations Apply
Effective from 23 October 2026
[Table 1. Grace Periods for PFAS-containing Firefighting Foams]
7
Establishment of PFAS-containing Firefighting Foam Management Plans
Including separate collection of waste, minimization of discharges, and substitution strategies
Effective from 23 October 2026
8
Firefighting Foams Placed on the Market (excluding portable extinguishers)
Mandatory PFAS warning label required
Effective from 23 October 2026
9
Unused Foams and Wastewater/Waste Stored by Users
Labels must also be affixed
Effective from 23 October 2026
10
Label Statement: Must be clearly and permanently displayed
WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS
-
[Table 2. PFAS Labeling and Management Obligations]