Key takeaway
What This Development Means
HSE has proposed restricting PFAS in firefighting foam under UK REACH, citing persistent, mobile pollutants and GB emissions of about 48 tonnes per year. The plan sets concentration limits and sector-specific transition periods, pushing a shift to fluorine-free foams. Stakeholders should review inventories, assess alternatives and submit evidence to the consultation.
What counts as “PFAS in firefighting foam” under the proposal?
HSE applies the OECD structural definition, which means any substance with at least one perfluorinated methyl (–CF₃) or methylene (–CF₂–) group. This covers foam concentrates and ready-to-use products. The class-wide scope aims to prevent substitution with equally persistent PFAS.
What are the headline timelines and limits I should plan for?
Indicative measures include 1 mg/L total PFAS for placing products on the market, 50 mg/L for in-use systems after cleaning, 18 months for fire and rescue service use, five years for aviation and portable extinguishers, and ten years for COMAH and offshore. See tables (pp. 15–16) for sector specifics and prepare evidence on feasibility.
Source basis: https://consultations.hse.gov.uk/crd-reach/pfas-in-firefighting-foam-fff-restriction-proposal/
The UK Health and Safety Executive (HSE) has opened a UK REACH consultation proposing a restriction on PFAS in firefighting foam across Great Britain, with sector-specific transition periods and concentration limits to curb emissions that threaten water sources and public health (consultation opened 18 August 2025; closes 18 February 2026). The move would affect fire services, airports, petrochemical sites, defence and offshore operators, accelerating shifts to fluorine-free alternatives.
HSE’s Annex 15 dossier concludes that use of PFAS in firefighting foam leads to persistent, mobile degradation products that accumulate in the environment and people, contributing to long-term risks even at low emission levels. The agency estimates around 48 tonnes of PFAS are released annually in GB from foam use, supporting the case for restriction.
Key Measures And Timelines
HSE proposes a class-wide restriction using the OECD structural definition of PFAS, covering foam concentrates and ready-to-use products to avoid regrettable substitution. Suggested concentration limits are 1 mg/L total PFAS for placing on the market and 50 mg/L for in-use systems following decontamination, reflecting technical feasibility and enforcement needs.
Transition periods vary by sector to maintain fire safety while enabling change: 18 months for fire and rescue services (for live incidents), five years for civilian aviation and portable extinguishers, and ten years for COMAH and offshore installations. Defence generally has five years, with ten years for military vessels.
Implications Across The Value Chain
Manufacturers, distributors and end-users of PFAS-containing foams face substitution, decontamination and potential equipment changes. HSE’s analysis notes fluorine-free foams (F3) already meet established performance standards in controlled tests, and successful transitions have been recorded across sectors, though more evidence from real incidents is limited. The dossier also flags monitoring and analytical approaches (for example, total organofluorine and TOP assays) needed to verify compliance and manage legacy contamination.
Next Steps And How To Engage
Stakeholders including industry, airports, utilities, emergency services, ports and insurers are invited to submit evidence on feasibility, costs, decontamination methods and environmental impacts before 23:59 (London) on 18 February 2026 via HSE’s consultation portal. Submissions can include confidential and non-confidential versions.
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