IMO 2026: Ban on PFOS in fire fighting media onboard ships

Starting from 01 January 2026, amendments to SOLAS Chapter II-2 and the High-Speed Craft Codes (HSC Code 1994 & 2000) will officially take effect, prohibiting the use or storage of Fire Fighting Media containing PFOS (Perfluorooctane Sulfonic Acid).

This regulation applies to both fixed fire extinguishing systems and portable fire extinguishers, directly impacting:

• Shipowners, managers, and operators
• Naval architects and shipyards
• Marine equipment manufacturers

According to IMO, “phasing out PFOS is essential to reduce persistent pollution in the marine environment and to protect human health from the serious risks of this chemical.”

Why is PFOS banned?

PFOS belongs to the PFAS group, often referred to as “forever chemicals” due to their extreme persistence in nature. Although once widely used in Class B foam Fire Fighting Media for their effectiveness in suppressing flammable liquid fires, they pose severe risks:

• PFOS accumulates long-term in the marine environment, water sources, and living organisms.
• Scientific studies link PFOS to endocrine disruption, liver damage, and increased cancer risk.

As a result, not only IMO but also the European Union (EU) and the United Nations Environment Programme (UNEP) are promoting the global elimination of PFOS/PFOA.

Related IMO Resolutions 2026

To implement the phase-out of PFOS in marine Fire Fighting Media, IMO has adopted several resolutions and technical guidelines as legal and operational references:

SOLAS Chapter II-2 – MSC.532(107): Amends Chapter II-2 of SOLAS on fire safety measures, prohibiting the use or storage of PFOS-containing Fire Fighting Media in both fixed and portable systems.

HSC Code 1994 – MSC.536(107): Applies to high-speed craft built under the 1994 Code, aligning PFOS restrictions with SOLAS to enhance fire safety.

HSC Code 2000 – MSC.537(107): Applies to vessels under the 2000 HSC Code, updating fire safety provisions to fully eliminate PFOS in Fire Fighting Media.

Unified Interpretations – IACS UI SC309 & HSC11: Issued by IACS to clarify IMO requirements. SC309 covers hazardous material and IHM lists, while HSC11 details verification procedures for high-speed craft.

IMO MSC.1/Circ.1694: Provides transition guidelines for shipowners, classification societies, and manufacturers on replacing foam, handling PFOS waste, and updating relevant certificates.

Implementation Roadmap for IMO 2026 Regulation

The new IMO regulation on eliminating PFOS in Fire Fighting Media will be rolled out under a clear roadmap, allowing shipowners and managers sufficient time to prepare.

1. For new ships (keel laid on or after 01 January 2026)

From the delivery stage, ships must not use or store any Fire Fighting Media containing PFOS above 10 mg/kg (0.001% by mass).

This means that from 2026, all fixed fire-fighting systems as well as portable equipment (such as portable fire extinguishers and foam sprayers) must be completely PFOS-free.

2. For existing ships (keel laid before 01 January 2026)

Ships already in service will be given a transition period. However, the final deadline is the first survey after 01 January 2026. At that time, all systems or equipment containing PFOS must be replaced or removed, and updated technical documentation must be provided to prove compliance.

3. Handling and disposal of PFOS-based Fire Fighting Media

Any PFOS-based agents or cylinders no longer permitted for use must be delivered to an approved onshore reception facility. This is a mandatory requirement to ensure hazardous waste does not pollute the marine or terrestrial environment.

4. Documentation and certification requirements

Shipowners must maintain full documentation proving that onboard Fire Fighting Media are PFOS-free. The minimum records include:

• Manufacturer’s declaration
• Batch details and production date
• Type Approval / MED Certificate

If such documentation is unavailable, samples must be taken and tested at an accredited laboratory to demonstrate compliance.

From 01 January 2026 onwards, all ships—newly built or already in operation—must demonstrate that their fire-fighting systems are free from PFOS. Failure to comply will be considered a violation and may result in Port State Control (PSC) detention.

This is a significant regulatory shift that requires shipowners and managers to proactively review their Fire Fighting Media and plan for replacement well in advance of the deadline.

What Should Shipowners and Managers Do?

To comply with the IMO 2026 regulation, shipowners and managers must start reviewing and preparing immediately.

By the first survey after 01 January 2026, all onboard fire-fighting systems must demonstrate that their Fire Fighting Media are PFOS-free, or that any PFOS-containing agents have been safely replaced and disposed of in accordance with the regulation.

Three Key Tasks:

Proof of PFOS-free Fire Fighting Media

All fire-fighting systems and equipment (both fixed and portable) must have documentation proving they do not contain PFOS. If PFOS was previously used, shipowners must provide evidence that it has been removed and disposed of at an approved facility.

Certification of Replacement Equipment

Any new fire-fighting equipment must be supplied with valid Type Approval / MED Certificates to ensure legal compliance and operational safety.

Update Technical Documentation

The Inventory of Hazardous Materials (IHM) must be updated to reflect the removal of PFOS-based Fire Fighting Media, ensuring transparency during inspections.

Clarification on “First Survey”

According to MSC.1/Circ.1290, the “first survey” refers to the first annual, periodical, or renewal survey conducted after 01 January 2026. For vessels under construction (keel laid before the deadline but delivered afterwards), the initial survey will be considered the “first survey.”

PFOS/PFOA-Free Foam Fire Fighting Media

In pursuit of safety and sustainability, MARICO provides next-generation foam Fire Fighting Media that are completely free from PFOS/PFOA, fully compliant with IMO, SOLAS, and other international certifications.

This is not only preparation for the 2026 deadline but also a long-term trend in the maritime industry, enabling shipowners and managers to stay ahead in meeting global regulations.

As a trusted supplier of marine firefighting equipment in Vietnam, MARICO is committed to delivering safe and compliant solutions that protect both people and the ocean.

Changing today means safer tomorrows – for a cleaner ocean and a sustainable maritime industry.