What is AFFF and why is it being phased out?

AFFF stands for Aqueous Film Forming Foam. It is a Class B firefighting foam that floats a thin aqueous film across the surface of a burning flammable liquid, smothering the vapour and sealing off the fuel from oxygen. It has been the dominant foam for fuel fires on airports, in the oil and gas sector, on warships and in industrial Class B portable extinguishers since the 1960s.

AFFF gets its film-forming property from fluorinated surfactants. Those surfactants are members of the wider PFAS family. PFAS chemicals are very stable, do not break down in the environment, and accumulate in soil, water, wildlife and people. That stability is why they are sometimes called “forever chemicals”. A growing weight of evidence links several PFAS to liver damage, immune effects, raised cholesterol and certain cancers, which is why regulators in the UK, the EU and the US have moved to restrict them.

PFOA, PFOS, PFHxA — what is the difference?

• PFOS (perfluorooctane sulfonate): the original “long-chain” PFAS in AFFF. Banned globally under the Stockholm Convention. UK ban long pre-dates 2025.
• PFOA (perfluorooctanoic acid): also long-chain (C8). UK use exemption for firefighting foam expired on 4 July 2025.
• PFHxA (perfluorohexanoic acid): the short-chain (C6) replacement used in modern fluorotelomer AFFF. Restricted in the EU under Regulation (EU) 2024/2462. Not yet restricted in UK law — the HSE proposal is in the post-consultation stage.

Older fluorine-free Class B foams (often labelled F3) have improved enough that the Fire Industry Association and most major manufacturers now consider them viable for the majority of UK applications.

The PFOA AFFF ban: what changed on 4 July 2025

PFOA was added to Annex I of the assimilated EU POPs Regulation (2019/1021) in April 2020. From that point, PFOA could not be manufactured, sold or used, with one narrow exemption for existing firefighting foam stock. That exemption ran out on 4 July 2025.

From that date in Great Britain (and equivalent provisions in Northern Ireland):

• PFOA-containing AFFF cannot be used on a fire of any size.
• It cannot be used for training or testing.
• It cannot be moved, decanted, refilled or maintained.
• It must be removed, stored as hazardous waste and sent for high-temperature incineration.

Holding PFOA AFFF in a workplace after 4 July 2025 is a breach of POPs legislation. Enforcement sits with the Environment Agency in England, SEPA in Scotland and Natural Resources Wales.

In practice that means any Class B foam extinguisher manufactured before about 2011 — and many made after — should already have been audited and either confirmed PFOA-free or removed.

The proposed UK REACH restriction on PFAS in firefighting foams

The PFOA ban only deals with one PFAS. The newer C6 / PFHxA AFFF that replaced it is still a PFAS and still environmentally persistent, so the HSE has moved to restrict it under UK REACH.

HSE consultation, August 2025

On 18 August 2025, HSE published an Annex 15 restriction report on PFAS in firefighting foams and opened a six-month public consultation that closed on 18 February 2026.

The HSE definition of PFAS for the purposes of the proposal is broad. It covers any substance with at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom without any hydrogen, chlorine, bromine or iodine attached. That is wide enough to catch C6 fluorotelomer AFFF as well as the older C8 chemistry.

HSE will issue its technical opinion within 12 months of publication. Ministers then decide whether to make a statutory instrument. A formal UK restriction is unlikely to enter force before early 2027.

Proposed transition periods

The draft transition periods in HSE's report run from the date the restriction enters force. They are not yet law, and may move in response to consultation feedback, but they give the planning shape:

• Training and system testing: 18 months
• Municipal fire and rescue services: 18 months
• Portable extinguishers, marine, civil aviation, defence: 5 years
• SEVESO / COMAH upper-tier sites and offshore installations: 10 years

The five-year window for portable extinguishers is the one most UK duty-holders need to plan around. It is generous compared with the EU equivalent, but it is also conditional on the consultation outcome and Defra ministers signing off.

How the UK position differs from the EU

EU REACH adopted Regulation (EU) 2024/2462 on 19 September 2024, restricting PFHxA and related substances across many applications, including firefighting foam. The most immediate firefighting deadline is 10 April 2026, when PFHxA in training and testing foams becomes unlawful in the EU. The civil aviation deadline is 10 October 2029.

The UK has not adopted Regulation 2024/2462. Since Brexit the UK runs its own REACH process, which has moved more slowly. The FIA's December 2025 PFAS update confirms that “there is no legal restriction on the supply or refilling of current fluorotelomer based (C-6/PFHxA) AFFF” in the UK.

What duty-holders should do now

The HSE consultation outcome will not change the direction of travel, only the speed. The sensible position is to plan for a PFAS-free foam estate now, even though the UK law is not yet final.

1. Audit your foam stock

Pull the data sheets for every Class B foam extinguisher, sprinkler concentrate tank and bulk foam store on site. Confirm the chemistry of each unit. Anything containing PFOA must already be flagged for disposal as hazardous waste. Anything labelled “C6” or “fluorotelomer” is currently legal but will need to be replaced inside the proposed transition window.

A fire risk assessment is the natural place to document this. The Regulatory Reform (Fire Safety) Order 2005 requires the Responsible Person to keep the assessment up to date, and a change in the legal status of fire-fighting media is a material change. Our Fire Risk Assessment UK guide covers the duty-holder framework if you need a refresher.

2. Choose a fluorine-free alternative

For most workplace Class B risks, fluorine-free foam (often marked F3) is now a like-for-like swap. F3 concentrates have improved noticeably since 2020. For higher-risk fuels such as polar solvents (acetone, ethanol, methanol), specify an F3 product tested against the appropriate EN 1568 part 4 performance class.

Other options to consider on a case-by-case basis include water mist for kitchen and small-volume fuel risks, dry powder for outdoor flammable-liquid stores, and CO2 for electrical and confined risks. The right combination depends on the fuels involved and the Responsible Person's judgement.

3. Plan compliant disposal

PFAS foam is classed as hazardous waste. It must go to a permitted high-temperature incinerator running at or above approximately 1,100 °C. Only a handful of UK facilities can take it. Per-unit disposal costs have risen sharply: industry-reported pricing went from roughly £2 to £3 per portable extinguisher in early 2024 to around £8 to £9 by late 2024, as capacity tightened.

Book disposal slots early. Do not allow PFAS foam to enter the general waste, drainage or surface-water systems. Keep transfer notes for at least three years.

4. Train your team

People who use, test or maintain firefighting foam need to know what is in the canister and what the current rules are. Annual extinguisher training and Responsible Person updates should now include PFAS chemistry and the UK regulatory timeline. Our NEBOSH National Certificate in Fire Safety and Risk Management covers the underlying duties; for shorter, role-based training, our in-company fire safety courses can be tailored to site-specific foam.