Prohibition of the use or storage of extinguishing media containing perfluorooctane sulfonic acid (pfos) – entry into force 1 january 2026

SOLAS II-2/10.11 as amended by resolution MSC.532(107) - New Requirements for Firefighting System

The International Maritime Organization (IMO) has adopted new amendments to the International Convention for the Safety of Life at Sea (SOLAS) concerning the use of fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS). These forthcoming regulations, which come into force on 1 January 2026, are a key component of global efforts to enhance safety and protect the marine environment. This briefing addresses the most common questions regarding the new requirements.

REGULATORY FRAMEWORK & BACKGROUND

Q1: What is the regulatory basis for the PFOS ban, when does it enter into force, and why is it being implemented?
A1: The International Maritime Organization has implemented a comprehensive prohibition on perfluorooctane sulfonic acid in fire-extinguishing media through amendments to SOLAS Chapter II-2 and the High Speed Craft Codes. The regulatory framework consists of three key resolutions adopted by the IMO: MSC.532(107) amending SOLAS Chapter II-2, MSC.536(107) amending the 1994 HSC Code, and MSC.537(107) amending the 2000 HSC Code. These amendments enter into force on 1 January 2026 and apply to all ships subject to SOLAS Chapter II-2 and High Speed Craft Codes.

The prohibition addresses significant environmental and health concerns related to PFOS, which belongs to the PFAS family of chemicals often referred to as "forever chemicals" due to their persistence in the environment. While PFOS has been effective in firefighting foams, particularly aqueous film-forming foams (AFFF), it is a Persistent Organic Pollutant that poses significant risks to human health and marine ecosystems due to its toxicity and bioaccumulation. Global restriction is driven by international agreements like the Stockholm Convention and represents a direct result of global efforts to protect seafarers and the marine environment from exposure to dangerous chemicals that build up in the body and environment over time with significant negative health effects.

Q2: What constitutes prohibited PFOS-containing media?
A2: The prohibition applies to fire-extinguishing media, which includes firefighting foams* used in both fixed and portable firefighting systems and equipment. The threshold for what is considered containing PFOS is defined as concentrations above 10 mg/kg or 0.001% by weight*.

IMPLEMENTATION TIMELINE & COMPLIANCE REQUIREMENTS

Q3: What are the implementation requirements and timeline for new and existing ships?
A3: The implementation timeline differs significantly between new and existing ships.

For new ships constructed (i.e. keels laid) on or after 1 January 2026, compliance is immediate upon delivery, and they must not use or store PFOS-containing fire-extinguishing media from the outset.

For existing ships constructed before 1 January 2026, compliance is required no later than the date of the first survey on or after 1 January 2026.

“first survey” means the first annual, periodical, intermediate, or renewal survey (related to SOLAS Passenger Ship Safety Certificate, Cargo Ship Safety Equipment certificate or HSC Safety Certificate) due after 1 January 2026 , or any other survey deemed reasonable and practicable by the Administration. For ships under construction where the keel is laid before 1 January 2026, but delivery occurs after that date, the initial survey is the first survey (refer to MSC.1/Circ.1290).

Q4: How do I verify compliance and what documentation is required for surveys?
A4: Compliance verification requires comprehensive documentation and may include laboratory testing when maker’s declarations are unavailable. Maker’s declarations must contain detailed information about the foam including foam type, production period, batch number, and reference to Type Approval or Marine Equipment Directive Certificate. These declarations must confirm PFOS absence below threshold levels and be kept onboard and made available to attending surveyors for review and verification *.

For extinguishing media in systems installed before 1 January 2026 where maker's declarations or laboratory test reports are unavailable, sampling and testing of the extinguishing media onboard must be conducted in accordance with recognized standards*.

SURVEY REQUIREMENTS & ENFORCEMENT

Q5: What will be verified during surveys?
A5: BV surveyors will review maker’s declarations or laboratory test reports of the fire-extinguishing media and verify proper disposal documentation ensuring logbook entries are complete and accurate. Confirmation that replacement systems meet approval requirements with certificates indicating PFOS absence is essential.

DISPOSAL, REPLACEMENT & PRACTICAL IMPLEMENTATION

Q6: What are the comprehensive requirements for disposal, replacement, and system updates?
A6: The disposal requirements mandate that prohibited substances containing PFOS must be delivered to appropriate shore-based reception facilities when removed from the ship (SOLAS regulation II-2/10.11.2.1). The removal and subsequent delivery must be recorded in the ship's official logbook, ensuring proper documentation of environmental sound disposal through certified facilities.

Replacement requirements specify that new extinguishing media must be suitably type approved with certificates clearly indicating PFOS absence. Replacement extinguishing media should be approved and certificated in accordance with applicable IMO guidelines.

Q7: What specific actions must shipowners take before their first survey and how should they prepare?
A7: Shipowners must complete several actions by their first survey on or after 1 January 2026. They must conduct an inventory of all firefighting media onboard to determine PFOS content and provide evidence that fire-extinguishing media is PFOS-free or demonstrate safe disposal arrangements for prohibited media. Any replacement media must be suitably type approved. Tanks must be verified as cleaned with all PFOS residues removed, and all activities must be recorded in the ship's official logbook with proper documentation available for surveyor review.

Preparation should begin as soon as possible with reviewing maker's declarations or laboratory test reports for all current fire-extinguishing media. If documentation is unavailable, arrangements for sampling and testing from media onboard must be made. Planning replacement systems or fire extinguishing media require coordination with equipment suppliers, while arranging for safe removal and disposal through certified shore-based reception facilities is essential.

* This clarification is included in Unified Interpretations of SOLAS Chapter II-2 and the 1994 and 2000 HSC Codes approved by IMO (MSC.1/Circ.1694) and IACS UI on Fire-Extinguishing Media Restrictions (UISC309 /UI HSC11).