PFAS Compliance Checklist for Fleets

A Simple & Practical Guide by Varuna Sentinels

For Vessels Above 400 GT & 5,000 GT. Stay compliant with Regulation (EU) 2025/1988 and ensure your fleet is inspection-ready.

Introduction

PFAS and PFOS compliance has become an important topic for shipowners, especially for vessels trading to the European Union. On 2 October 2025, the European Commission adopted Regulation (EU) 2025/1988, restricting the use of per- and polyfluoroalkyl substances (PFAS) in firefighting foams. This regulation applies to commercial vessels above 400 GT and tankers above 5,000 GT operating in or trading to the EU.

Note: PFAS are persistent chemicals used in Class B foams that harm the environment. The EU now applies a class-based restriction covering all PFAS.

What Shipowners Are Required to Do

01

Identify Firefighting Foams Onboard

Deadline: 23 October 2025

Shipowners must identify all firefighting foams available onboard and confirm whether PFAS are present. This includes:

  • Fixed firefighting foam systems
  • Portable firefighting foam units
  • Training and reserve foams
02

Check PFAS / PFOS Compliance Status

Verify whether identified foams comply with regulatory limits. Varuna Sentinels follows a practical method:

  • Review manufacturer’s declaration for the foam.
  • If declaration confirms compliance, no further action is required.
  • If unavailable or non-compliant, we guide on testing or replacement.
03

PFAS Firefighting Foam Management Plan

Deadline: 23 October 2026

If PFAS-containing foams are used during the transition period, a Management Plan is mandatory, covering:

  • Storage locations and quantities.
  • Usage restrictions (Class B fires only).
  • Spill and emission control measures.
  • Equipment cleaning procedures.
  • Transition timeline to fluorine-free foams.

The plan must be reviewed annually and kept for 15 years.

04

Transition to Fluorine-Free Foams

Final Deadline: 23 October 2035

A planned transition is mandatory. Key requirements during replacement:

  • Proper cleaning of fixed systems.
  • Temporary residual PFAS limit of 50 mg/L allowed after cleaning.
  • Portable extinguishers must be PFAS-free.
05

Safe Disposal of PFAS Waste

Ongoing Requirement

PFAS-containing foams and waste must be collected separately and disposed of through approved shore facilities. Biological treatment is prohibited.

06

Records, Labelling, and Crew Awareness

By 23 October 2026
  • Proper labelling of PFAS foams and waste.
  • Crew awareness of risks and safe handling.
  • All records maintained for 15 years.

How Varuna Sentinels Helps Shipowners

PFAS compliance does not need to be complicated. We support you by:

  • Reviewing firefighting foams onboard.
  • Checking manufacturer declarations.
  • Advising testing or replacement only when required.
  • Preparing PFAS Management Plans.
  • Supporting documentation and audit readiness.
  • Guiding vessels through a smooth transition to fluorine-free foams.

Key Takeaway: PFAS compliance is about taking the right steps at the right time. Stay compliant and inspection-ready with Varuna Sentinels.

Need help with your PFAS Compliance Checklist?

Reach out to Varuna Sentinels BV at contact@varuna-sentinels.com or visit our website www.varuna-sentinels.com