PFOS foam ban on ships: what to do before your next survey

What changed on 1 January 2026

The amendments in Resolution MSC.532(107) added two things to SOLAS chapter II-2. Regulation 10.11 bans the use and storage of fire-extinguishing media that contain PFOS. Regulation 1.2.10 sets the deadline for ships that already existed. The HSC Codes received the same requirement in their regulation 7.9.4, through MSC.536(107) and MSC.537(107).

The dates depend on when the keel was laid:

Ship	What applies
Keel laid on or after 1 January 2026	No PFOS-containing media on board from delivery
Keel laid before 1 January 2026	Clear of PFOS by the first survey on or after 1 January 2026, with removed media landed at a shore reception facility

“First survey” means the first annual, periodical or renewal survey after that date, which in practice is the safety equipment or safety certificate survey. For many ships that survey is already behind them or is coming up within months.

What counts as “containing PFOS”

The unified interpretation in MSC.1/Circ.1694, which repeats IACS UI SC309, settles two questions:

• Foam concentrates are fire-extinguishing media in the sense of the regulation.
• “Containing PFOS” means more than 10 mg/kg (0.001 % by weight).

The ban names PFOS only. Other fluorinated foams are still legal under SOLAS, so PFOS-free is not the same as PFAS-free. That matters for ships trading in the EU, where Regulation (EU) 2025/1988 phases out PFAS in fire-fighting foams: most uses end on 23 October 2030, and foam already on board before 23 October 2025 has a transition period until 23 October 2035. Whether and how the EU rules bind ships under other flags is still being clarified, so if the foam has to be replaced anyway, a fluorine-free product is worth considering.

Class societies apply the ban to fixed foam systems and to portable equipment such as foam applicators and foam extinguishers.

How the flag or class checks it

The flag or recognised organisation reviews one of two things:

1. A maker’s declaration that the foam is PFOS-free. To be useful it names the foam type, the production period or batch, and the type approval or MED certificate reference.
2. A laboratory report. Foam supplied before 2026 that has no papers is sampled on board and tested to a recognised standard.

Keep these documents on board. Lloyd’s Register points out that the PFOS-free statement in the Inventory of Hazardous Materials paperwork is not enough on its own.

Replacing the foam: the order that works

1. List every foam on board: the fixed tank or tanks, portable applicator cans, foam extinguishers and spare containers.
2. Ask the maker for a batch-specific declaration for each product. Where there is none, have a sample tested.
3. Plan the removal if a product is above the limit. The foam is landed at a shore reception facility. DNV requires a logbook entry for the removal (ABS recommends one). Keep the receipt and update the Inventory of Hazardous Materials, because PFOS is listed in Annex I of the EU Ship Recycling Regulation.
4. Empty and clean the tank and lines. Topping up is not an option: mixing leaves PFOS in the system, and foams are often not compatible with each other.
5. Choose a replacement that fits the system. DNV expects the same mixing ratio, a similar viscosity (otherwise the proportioner has to be adjusted and verified) and an equivalent approval class. Low-expansion foam must be type-approved to MSC.1/Circ.1312, high-expansion foam to MSC/Circ.670. Inside-air high-expansion systems may only take the foam named on the system certificate. ABS wants changes of foam type or mixing ratio sent for engineering review, and refilling a foam extinguisher needs the extinguisher maker’s agreement.
6. Verify the proportioner after the refill.
7. File the new paperwork and restart the test clock for the new concentrate.

Test intervals after the change

Item	Interval	Basis
Low-expansion foam concentrate	First test within 3 years of supply to the ship, then every year	MSC.1/Circ.1312
Alcohol-resistant protein foam	Stability (acetone) test before delivery, then every year	MSC.1/Circ.1312
High-expansion foam concentrate	First test after 3 years, then every year	MSC/Circ.670
Proportioners	Every 5 years, within +30 % / −10 % of the approved ratio	MSC.1/Circ.1432
Sealed portable foam containers	Non-protein foam under 10 years old: normally not tested. Protein foam over 5 years old: test or renew	MSC.1/Circ.1432

The periodic test covers sedimentation, pH, expansion, drainage and density. PFOS content is not part of it, so a PFOS analysis has to be ordered separately.

Where the guidance differs

• An early ABS regulatory note (May 2025) advised replacing PFOS foam before 1 January 2026. SOLAS and ABS’s later guidance use the first survey on or after that date.
• MSC.1/Circ.1432 and MSC.1/Circ.1312 word the first-test rule slightly differently for alcohol-resistant foams. Follow your flag’s notice where it gives one.
• We found no port state control guidance on PFOS so far, and no IMO procedure for cleaning a system. Follow the foam and system makers’ instructions.

How we help

We check the documents first, take and ship samples to an accredited laboratory where needed, remove and dispose of old concentrate, clean the system and refill it with a foam that suits it. You get the declaration, test reports and disposal record for the surveyor. See Foam analysis and PFOS-free conversion.