PFAS also referred to as “forever chemicals” are chemicals commonly used in certain Aqueous film forming foam (AFFF), particularly ‘Class B’ foams which are used to combat flammable fuel fires.
Prohibitions/Restrictions have been brought in for three PFAS chemicals (PFOS, PFHxS and PFOA) that have been designated as Persistent Organic Pollutants at a global level under the UN Stockholm convention, and implemented at EU level through Regulation (EU) 2019/1021 on persistent organic pollutants.
The PFAS chemicals PFOS and PFHxS have been prohibited since 2009 and 2023 respectively. More recently the Commission has adopted the PFOS amendment which will reduce the maximum PFOS concentration allowed as unintentional trace contaminant (UTC) in substances, mixtures and articles and will remove the last specific exemption allowed in the EU.
The European Commission has proposed extending the deadline for the phase-out of PFOA in fire-fighting foam to 3rd December 2025. This proposal has been adopted, but the amendment has not yet been officially designated. Currently the deadline remains the 4th July 2025 until sometime as it's officially implemented by the Commission. For details and Commission updates on this initiative see Chemical pollutants – limits and exemptions for perfluorooctanoic acid (PFOA).
The Commission also propose new concentration limits as an unintentional trace contaminant. It plans to set a UTC limit for fire-fighting foams installed after cleaning to avoid a situation where the new foams need to be replaced because of previous PFOA contamination.
There is not a ban on the use of all AFFF in portable fire extinguishers or fire suppression systems. Some foams do not contain PFOA e.g. Fluorine Free foams, or some foams may contain it at very low levels which are below the concentrations specified in the EU regulations. Also, be aware that there are other proposed restrictions on the use of PFAS in these foams as covered below.
It is necessary to first check if your fire suppression system, including fire extinguishers, contain AFFF to determine the type of foam used and whether it contains the restricted chemical PFOA. If unsure contact your supplier to confirm that you have AFFF and request confirmation of any analysis conducted on the AFFF.
If you know the type of AFFF that you have on site, the EPA has also put together a list PFOA concentrations for a selection of fire-fighting foams that may be of assistance in determining whether the foam contains PFOA. Also, the following are examples of fluorine free foams.
If you have AFFF which contains PFOA or PFOA related compounds above the specified concentration this will need to be removed from use by the 4th July 2025. The following PFOA in Fire Fighting Foams guidance leaflet outlines the steps you must follow in relation to PFOA containing AFFF and stockpile notifications. This guidance leaflet is also available in Irish - PFOA i gCúir Chomhraicthe Dóiteáin.
If you have foams containing PFOA or related PFOA compounds over the allowed concentration and an aggregate volume of over 50kg at a given location, you are required to report annually to the EPA before the 4th July. The deadline for receipt of reports of stockpiles was extended to 30 November 2021. Any stockpiles that have not already been reported to the EPA, must be reported as a matter of priority. Reporting can be done through the Environmental Data Exchange Network (EDEN) portal. The following FAQ document gives more information on how to report stockpiles to the EPA.
Further information can also be found in the following leaflet for users of foam fire extinguishers.
All existing stocks of AFFF containing PFOA must be managed appropriately by a suitably authorised waste management contractor. Under the Waste Management Act 1996 the temporary storage of the PFOA containing fire-fighting foam waste should not exceed 6 months. The following contractors are licenced by the EPA to handle hazardous waste and may be able to offer physio-chemical treatment of POPs waste (this is not an exhaustive list, there may also be others):
• Indaver Ireland limited
• Enva Ireland Limited
• Veolia Environmental Services Technical Solutions limited
• Rilta Environmental Limited
Please note it is important that you get a copy of a waste disposal certificate for your records to show that you have disposed of the stockpile appropriately. Under EU regulations only the following disposal and recovery operations (shown on your disposal certificate) are permitted - D9, D10, R1 or R4.
The European Commission DG Environment and ECHA published a report on the use of PFAS and fluorine-free alternatives in fire-fighting foams in 2020. If you are replacing PFOA containing AFFF it is recommended to use PFAS free alternatives, known as “fluorine free” foams.
PFAS free foams are recommended due to other PFAS restrictions under REACH Regulation, and broader proposals currently at EU and ECHA level to place restrictions on all PFAS. Please refer to the section below on regulations/proposals affecting AFFF to learn more.
The EPA in consultation with the Fire Industry Association of Ireland (FIAI) have created the following information for suppliers of foam fire extinguishers. Please also refer to the next section to find more information on the regulations affecting AFFF.
As mentioned above there are three PFAS chemicals currently restricted/prohibited under the Stockholm convention (PFOS, PFHxS and PFOA). Potentially there will also be a restriction for LC-PFCAs (C9-C21 PFAS) which is currently a candidate POP for inclusion in Annex A to the Stockholm Convention. It will be considered further by the UN Conference of Parties in May 2025.
Another set of legislation that is relevant is the REACH regulations. Currently the use of the following types of PFAS chemicals in firefighting foam is restricted under the REACH Regulations:
REACH Proposals to further restrict PFAS in AFFF:
The European Chemicals Agency submitted a proposal to restrict the use of PFAS in fire-fighting foams in January 2022.
EU Member States and the European Commission will make the final decision shortly on the proposed REACH restrictions. Up to date information on the status of the proposal is available on ECHA’s website.
When released, these chemicals exist in the environment and in our bodies for long periods of time where they can increase in concentration. They have been found to have harmful effects on human and animal health.
Please refer to the 2024 state of the environment report for further summary information on the environmental impact of PFAS chemicals contained in firefighting foam. A dedicated section on chemicals can be found in Chapter 14 which discusses the environmental and health impacts of PFAS.
For more information on PFAS regulations and additional studies please refer to the EPAs PFAS page. This page also has signposts to information from the European Chemicals Agency, the UN Stockholm Convention and the European Environment Agency.