The IMO has developed amendments to SOLAS Chapter II-2 and the High Speed Craft (HSC) Codes (1994 and 2000) to prohibit the use or storage of fire-extinguishing media (including firefighting foams) containing perfluorooctane sulfonic acid (PFOS). The prohibition applies to both fixed and portable systems and equipment and enters into force on 1 January 2026.

These amendments were adopted after the following resolutions:

The following clarifications have also been published related to extinguishing media containing PFOS:

  • IACS Unified Interpretation SC309 for SOLAS Regulation II-2/10.11
  • IACS Unified Interpretation HSC11 for Regulation 7.9.4 of HSC Codes (1994 and 2000)
  • The IMO has also published the same content as IMO MSC.1/Circ.1694  – Unified interpretations of SOLAS Chapter II-2 and the HSC Codes (1994 and 2000).

New requirements

These new requirements apply as follows:

  • Ships constructed (keel laid) on or after 1 January 2026 and subject to SOLAS/HSC Codes must not use or store fire-extinguishing media (including firefighting foams) containing PFOS in concentrations above 10 mg/kg (0.001% by weight) upon the ship’s delivery.
  • Ships constructed (keel laid) before 1 January 2026 must comply with the above requirement no later than the date of the first survey* on or after 1 January 2026.
  • Disposal of the prohibited substances must be done using appropriate shore-based reception facilities.
  • Any declaration issued by the fire-extinguishing media manufacturer should contain information about the extinguishing media such as, but not limited to - type, production period, batch number and reference to Type Approval/MED Certificate. It must also be kept onboard and made available to attending surveyors for review and verification that the fire-extinguishing media does not contain PFOS in concentrations above 10 mg/kg (0.001% by weight).
  • For extinguishing media installed before 1 January 2026, where the maker’s declaration or laboratory test reports are not available, sampling and testing of the extinguishing media onboard should be required to be conducted in accordance with a recognised standard (e.g. NPR-CEN/TS 15968) in order to verify that the firefighting media does not contain PFOS in concentrations above 10 mg/kg (0.001% by weight).

What should shipowners and ship managers do now?

By the first survey* on or after 1 January 2026, shipowners, ship managers and ship operators must ensure:

  • They have evidence that fire-extinguishing media is PFOS-free or have arranged for the safe disposal of any prohibited fire-extinguishing media;
  • Any replacement fire-extinguishing media or equipment has been suitably type approved;
  • They update the vessel’s inventory of hazardous materials after removal of any PFOS-containing fire-extinguishing media, as applicable. 

*Definition of first survey

According to MSC.1/Circ. 1290, the “first survey” referenced in SOLAS regulations, unless indicated otherwise, is the first annual, periodical or renewal survey due after a specified date in the regulations, or any other survey deemed reasonable and practicable by the Administration (having taken into account the extent of repairs and alterations being undertaken).

For a ship under construction where the keel is laid before a regulation’s specified date, but the delivery is after that date, the initial survey is considered the “first survey”.

Future restrictions

In the future, the EU, IMO and other regulatory bodies may introduce further restrictions on the use of fire-extinguishing media containing other chemicals in the PFAS group, such as perfluorooctanoic acid (PFOA). 

For further information

If you would like more details or need support with these requirements, please contact statutorysupport@lr.org.