Technical Circular No: 025/2025
1. The IMO vide Resolutions, MSC. 532 (107), MSC. 536 (107) & MSC. 537 (107) adopted amendments to SOLAS Chapter II-2 and the High-Speed Craft (HSC) Codes (1994 and 2000) prohibiting the use or storage of fire-extinguishing media (including fire-fighting foams) containing perfluorooctane sulfonic acid (PFOS).
2. The prohibition enters into force on 1 January 2026 and applies as follows:
a. Ships constructed on or after 1 January 2026 shall not use or store fire-extinguishing media (including firefighting foams) containing perfluorooctane sulfonic acid (PFOS) in concentrations above 10 mg/kg (0.001% by weight) upon the ship’s delivery.
b. Ships constructed before 1 January 2026 shall comply with requirements not later than the date of the first scheduled Annual/Periodical/Intermediate/Renewal survey on or after 1 January 2026.
3. The amendment further requires that prohibited substances containing PFOS, when removed from the ship, must be delivered to appropriate shore-based reception facilities.
4. The maker’s declaration or laboratory test reports will be used for verification of the presence of PFOS in fire-extinguishing media.
5. The declaration issued by the foam maker should contain information about the foam such as, but not limited to:
- foam type,
- production period,
- batch Number,
- to type approval / MED Certificate for the foam.
6. 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 fire-extinguishing media on board will be required to be conducted in accordance with a recognized 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).
7. Ship Owners/ managers and Masters are advised to take note of above and accordingly ensure that by the first scheduled Annual/Periodical/Intermediate/Renewal survey on or after 1 January 2026:
a. Appropriate evidence is available on board providing that fire-extinguishing media does not contain PFOS in concentrations above 10 mg/kg (0.001% by weight) or towards safe disposal of any prohibited fire-extinguishing media.
b. When removed from a ship, ensure PFOS are delivered to appropriate shore-based reception facilities. The removal and subsequent delivery to an appropriate shore-based reception facility are duly recorded in the ship’s official logbook.
c. Ensure the tanks are cleaned and all residues of PFOS are removed
d. Replacement extinguishing media is approved and certificated in accordance with the applicable IMO guidelines. The extinguishing media approval certificate clearly indicates the absence of PFOS in the media.
Enclosure:
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.