What is the SOLAS II-2 PFOS Amendment? — 1 January 2026 Firefighting Foam Prohibition

Definition: What is the SOLAS II-2 PFOS amendment?

The SOLAS Chapter II-2 PFOS amendment was adopted by IMO resolution MSC.532(107) in June 2023 and entered into force on 1 January 2026. It prohibits the use or storage of fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS) on board ships, and requires evidence of PFOS-free foam at the first statutory survey on or after the entry-into-force date.

PFOS is a persistent, bioaccumulative and toxic (PBT) substance historically used in Aqueous Film-Forming Foams (AFFF). The amendment aligns shipping with the broader global move away from forever chemicals, paralleled by the EU REACH restriction and ECHA’s proposed universal PFAS ban.

Who does MSC.532(107) apply to?

• New ships — keel laid on or after 1 January 2026: compliance is immediate at delivery.
• Existing ships — compliance by the first statutory survey on or after 1 January 2026. This is typically one of: the annual SOLAS safety construction survey, the renewal of the SECC, or the harmonised IOPP / MARPOL VI survey.
• All gross-tonnage categories above 500 GT on international voyages (other tonnages follow flag-state interpretation).

What evidence is required?

At the first survey on or after 1 January 2026, the ship must demonstrate three things:

1. No PFOS-containing foam on board — fixed deluge, portable extinguishers, foam cartridges, reserves in foam lockers.
2. Documentary evidence — typically a Safety Data Sheet (SDS) and a Supplier Declaration of Conformity (SDoC) for the replacement foam, confirming PFOS absence.
3. Safe-disposal record — waste transfer note from a licensed receiver for any pre-existing PFOS-containing foam.

IHM Part I annex update

Because PFOS has been listed in Annex I of the EU Ship Recycling Regulation (EUSRR) since 31 December 2020, the IHM Part I annex must reflect:

• Removal of PFOS-containing stock (location, approximate quantity, disposal route, date).
• New replacement foam with MD/SDoC attached.
• Designated Person’s sign-off entry in the IHM maintenance log.

Our VSIMS IHM Maintenance platform generates a one-click PFOS annex pack for Port State Control.

What about PFAS more broadly?

PFOS is a single member of the wider PFAS (per- and polyfluoroalkyl substances) family. Expect follow-on restrictions:

• EU Regulation 2025/1988 — added PFAS restrictions for firefighting foams under REACH Annex XVII Entry 82, with staggered deadlines running into 2027.
• ECHA universal PFAS restriction — under consideration; would extend the ban across product categories.
• National regulators — several flag states are moving ahead of IMO on PFAS transparency in IHM.

Practical timeline to compliance

1. Now — inventory every firefighting medium on board and identify any PFOS-containing stock.
2. Before first survey — replace with PFOS-free fluorine-free foam (F3) or PFAS-free F3, collect SDS + SDoC, record in IHM Part I annex.
3. At first survey — present the evidence to the RO surveyor, obtain endorsement of SEC / ICIHM as applicable.
4. Continuous — include PFOS-free confirmation in every new foam purchase via VSMPS.