EU Regulation 2025/1988

New PFAS Restrictions for Firefighting Foams

Comprehensive guide to compliance requirements and implications for global maritime fleets trading to European ports.

Overview

The European Union has formally adopted Regulation (EU) 2025/1988, introducing comprehensive restrictions on PFAS (including PFOS, PFOA, PFHxS) in firefighting foams used on vessels. This regulation represents one of the most significant compliance changes for the maritime sector in recent years.

Key Point: This regulation applies to all vessels calling EU ports, irrespective of flag, ownership, or trading pattern.

Key Regulatory Highlights

01

PFAS Concentration Limit – 1 mg/L

All firefighting foams must comply with a maximum limit of 1 mg/L (Total PFAS). Compliance will be determined through Total Fluorine (TF) analysis, now the preferred EU testing methodology.

02

Phase-Out & Transition Deadlines

PFOS Prohibition: January 2026
General PFAS Foam Ban: 23 October 2030
Portable Extinguishers (Standard): 23 October 2026
Portable Extinguishers (Alcohol-resistant): 23 April 2027
Extended Deadline (Military, Offshore, Existing): Until 2035

Operational & Compliance Expectations

Complete PFAS Inventory

Assessment of foam concentrates, fixed systems, and portable extinguishers on all vessels.

Laboratory Testing

Total Fluorine Analysis to verify PFAS levels meet the mandated threshold.

Management Plans

Implementation from October 2026 including documentation of handling, disposal, and substitution strategy.

Waste Handling

All PFAS-containing foam must undergo approved treatment; biological treatment is prohibited.

Transition Planning

Strategic planning to align with dry-dock schedules and operational constraints.

Regulatory Compliance

Verification by Port State Control, Classification Societies, and Flag Administrations.

Industry Impact

This regulation significantly elevates the environmental and technical compliance expectations for fleet operators. Regulatory authorities will increasingly verify:

PFAS Testing Certificates

Documentation of compliance testing results

Foam Origin & Batch Data

Traceability of all foam products onboard

Inventory & Disposal Records

Complete documentation of foam management

Management Plans & Timelines

System transition and compliance schedules

Warning: Proactive compliance is essential to avoid operational delays, detentions, or enforcement actions at EU ports.

How Varuna Sentinels BV Supports Global Fleets

PFAS Foam Inventory & Verification

Comprehensive assessment of all foam concentrates, fixed systems, and portable extinguishers across your fleet.

Total Fluorine Testing Coordination

Arrangement and coordination of laboratory testing using approved Total Fluorine analysis methodology.

Foam Replacement Advisory

Expert guidance on foam replacement and system compatibility with existing equipment.

PFAS Management Plans

Preparation of comprehensive management plans for compliance with regulatory requirements.

Documentation Support

Complete documentation support for Class, Flag Administration, and Port State Control compliance.

Strategic Planning

Fleet-wide compliance planning aligned with operational schedules and dry-dock windows.

Ready to Ensure Compliance?

If your vessels are trading to Europe, now is the right time to initiate PFAS compliance planning. For fleet-wide assessments or technical guidance, our IHM Division team is available to assist.