IMO amendments 2026: Eliminating PFOS from fire safety systems
IMO amendments to SOLAS Chapter II-2 and the 1994/2000 High-Speed Craft Codes introduce a ban on fire-fighting media, including foam concentrates, containing Perfluorooctane Sulfonic Acid (PFOS).
Scope of Application
The IMO ammendments applies to:
– Shipowners, ship managers, and operators
– Ship designers, shipyards, and marine equipment manufacturers
The ban covers both fixed fire-extinguishing installations and portable fire-fighting appliances, with the requirements entering into force on 1 January 2026.
What is PFOS?
PFOS (Perfluorooctane Sulfonic Acid) is a substance belonging to the group of PFAS (Per- and Polyfluoroalkyl Substances), often referred to as “forever chemicals” due to their extreme persistence in the environment.
For decades, PFOS-based foam concentrates have been widely used in fire-fighting applications, particularly against Class B fires, thanks to their ability to form a thin aqueous film that separates fuel surfaces from oxygen.
However, scientific studies have demonstrated that PFOS is highly toxic, bioaccumulative, and resistant to natural degradation. It contaminates marine environments, water sources, and living organisms, and has been linked to severe health risks such as liver dysfunction, endocrine disruption, and increased cancer risks.
In light of these concerns, international bodies including IMO, the European Union, and UNEP have progressively moved towards the elimination of PFOS-containing substances.
Related IMO instruments
The IMO amendments have been adopted through the following resolutions:
- SOLAS Chapter II-2 – MSC.532(107)
- HSC Code 1994 – MSC.536(107)
- HSC Code 2000 – MSC.537(107)
Furthermore, unified interpretations have been issued:
- IACS UI SC309 on SOLAS Regulation II-2/10.11
- IACS UI HSC11 on Regulation 7.9.4 of the HSC Codes (1994 and 2000)
IMO has also circulated related guidance through:
MSC.1/Circ.1694 – “Unified interpretations of SOLAS Chapter II-2 and the HSC Codes (1994 and 2000)”
Key point of the IMO amendments
The provisions shall apply as follows:
For new ships (keel laid on or after 1 January 2026): the use or carriage of fire-fighting media containing PFOS above 10 mg/kg (0.001% by weight) will be prohibited from the time of delivery.
For existing ships (keel laid before 1 January 2026): compliance must be achieved no later than the first survey conducted on or after 1 January 2026.
Handling and disposal: prohibited fire-fighting media must be removed and disposed of at approved shore reception facilities.
Manufacturer’s documentation: declarations must clearly indicate the type, date of manufacture, batch number, and Type Approval/MED Certificate reference. These documents are to be retained onboard and made available during inspections.
For fire-fighting media installed before 1 January 2026: where no manufacturer’s declaration or laboratory test result is available, sampling and testing must be carried out in accordance with a recognized standard (e.g. NPR-CEN/TS 15968) to verify compliance with the PFOS threshold.
What shipowners and operators must do regarding the IMO amendments
Prior to or at the first survey after 1 January 2026, shipowners and managers must ensure:
- Evidence is available confirming that fire-extinguishing systems are PFOS-free, or that prohibited substances have been safely removed.
- Any replacement medium or equipment carries a valid Type Approval/MED Certificate.
- The Inventory of Hazardous Materials (IHM) is updated following the removal of PFOS-containing fire-fighting agents, if applicable.
According to MSC.1/Circ.1290, the term first survey is understood to mean:
- The first annual, periodical, or renewal survey conducted after the regulatory date specified in SOLAS; or
- Another survey deemed appropriate by the flag Administration or recognized organization.
For ships with keels laid before the regulatory date but delivered afterwards, the initial survey is to be regarded as the first survey.
The IMO amendments eliminating PFOS from fire-fighting media represents a significant step towards marine environmental protection and enhanced fire safety at sea. However, this marks only the beginning.
In the near future, IMO, the European Union, and other international regulatory bodies may extend restrictions to additional PFAS substances, such as PFOA, which remain in use in certain foam concentrates.
This reflects a clear regulatory trend towards the adoption of safer, more environmentally friendly fire-fighting agents, requiring shipowners, operators, and equipment manufacturers to proactively update technology and implement timely replacements to remain ahead of compliance requirements.