UK REACH Consultation Proposes Sweeping Restriction on PFAS in Firefighting Foam

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.