REACH Annex XVII on PFAS in Firefighting Foams Published

On October 23, 2025, the European Commission published a new amendment to Annex XVII of the REACH Regulation, adding Entry 82 to restrict the use of per- and polyfluoroalkyl substances (PFAS) in firefighting foams. This broad restriction covers the entire PFAS class to prevent "regrettable substitution" and address the persistence criteria outlined in Annex XIII.

Phase-Out timeline 
The regulation imposes a general ban on the use and placing on the market of firefighting foams containing a total PFAS concentration of 1 mg/L or greater, effective from October 23, 2030. However, to manage the transition, sector-specific deadlines have been established for placing restricted foams on the market:

• October 23, 2026: Ban applies to foams in portable fire extinguishers.
• April 23, 2027: Ban applies to alcohol-resistant foams in portable fire extinguishers.
• October 23, 2035: Ban applies to foams used in establishments covered by the Seveso III Directive (excluding aviation), offshore oil and gas installations, military vessels, and civilian ships with foam placed on board before October 23, 2025.

Existing restrictions on specific subgroups (e.g., PFOS, PFOA, PFHxA, C9-C14 PFCAs) remain in force, but these substances contribute to the cumulative concentration limit under this new entry.

Obligations for users
Even before the full ban, new obligations for the "use" of PFAS-containing foams (including storage) take effect starting October 23, 2026:

• Users must minimize emissions to the environment and human exposure.
• Unused foams and PFAS-containing waste (including wastewater) must be collected separately and treated to destroy or irreversibly transform the PFAS content.
• Users must establish and maintain a site-specific "PFAS-containing firefighting foams management plan," which must be kept available for inspection for 15 years.

Labeling requirements
From October 23, 2026, restricted foams (excluding portable extinguishers) placed on the market must carry a warning label in the official language of the Member State: "WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS." This requirement also extends to users labeling waste and unused stock.
Full details of the restriction can be found in the official text of Commission Regulation (EU) 2025/1988.