AFFF firefighting foam, PFAS rules, replacement and disposal

AFFF means aqueous film-forming foam, also written aqueous film forming foam. It is a fluorinated firefighting foam for Class B liquid-fuel fires, including oil and gasoline. There is no single worldwide ban on AFFF foam.

PFAS ingredients help form a film between the fuel and air, but controls differ by substance, country and use. Washington Ecology describes that film on liquid fuels. The US Fire Administration defines Class B as the liquid-fuel fire class.

For a site holding old foam, the first question is what it contains. Then separate the rules for buying new stock, using existing equipment, training and waste. A supply deadline does not always prohibit every existing use, and a use transition does not cancel waste duties.

AFFF, PFAS and PFOS mean different things

AFFF is one type of firefighting foam, not a label for every foam. PFAS is the chemical family that includes PFOS, PFOA and PFHxS, and each has its own legal controls. A PFOS-free statement does not show that the product is free of PFAS. Use the composition data for that product, not the marketing line. Japan's environment ministry explains the substances and their controls.

Class A and Class B describe fire types, not chemical families. Class A covers ordinary combustibles, including wood, paper and cloth. Class B covers flammable and combustible liquids. An AFFF fire extinguisher is a different question from Class A foam selection. The US Fire Administration sets out these fire classes.

The EU's adopted foam restriction cites PFAS persistence, releases to the environment and substitution. A PFOS-only check can miss those broader controls. Not every PFAS has the same hazard profile. Regulation (EU) 2025/1988 is the adopted text.

United States rules depend on the state

Don't infer a common civilian deadline from military policy. For airports, 14 CFR 139.317 specifies AFFF quantities. Paragraph (h) also permits other agents authorized by the FAA Administrator with equivalent firefighting capability. That section does not set a universal airport phase-out date. Airport operators should confirm current FAA authorization requirements before changing agents.

State restrictions need their own review. Washington restricts manufacture, sale and distribution of Class B foam with intentionally added PFAS. The general restriction began on 1 July 2020. The deferral for foam supplied to a person for use at a terminal, chemical plant or oil refinery operated by that person ran to 1 January 2024, subject to waivers. Federal-law exceptions remain. This is not a ban on every emergency use. Record the destination state and the installation type before you accept a supplier's compliance statement. Washington is an example, not a national checklist. See RCW 70A.400.020.

Japan controls substances and existing equipment

Japan controls PFOS, PFOA and PFHxS as Class I Specified Chemical Substances under the Chemical Substances Control Law. Manufacture and import are generally prohibited, with controls on use and specified product imports. The current Enforcement Order also lists PFOA-related and PFHxS-related substances. Its product lists include extinguishers, extinguishing agents and foam. Read the environment ministry's FAQ with Articles 1 and 7 of the Enforcement Order.

Assess existing equipment separately from new manufacture and import. The Order retains transitional handling for specified existing foam, and the ministry acknowledges existing equipment while replacement proceeds. A substance designation does not mean every installation immediately became illegal. The relevant transition appears in supplementary provision 4.

For foam within scope, Japan's binding technical standards cover sealed storage containers, indoor storage and protected floors, identification and controlled transfer. They also require collection of cleaning water and materials, inspections, spill precautions and inventory records. Foam discharged during training or inspection must be recovered and stored in sealed containers. Inspection records and inventory books have five-year retention duties. The current ordinance, amended with effect from 17 June 2026, covers the listed substances and related-substance groups.

Several EU deadlines already apply

The wider EU PFAS foam restriction is adopted law, not a proposal. From 23 October 2030 it generally prohibits placing on the market or using firefighting foam with at least 1 mg/L summed PFAS. Other transitions change that date for particular equipment and uses. The dates below come from REACH entry 82 in Regulation (EU) 2025/1988. PFOS, PFOA, PFHxS, the C9-C14 PFCAs restricted under entry 68, and PFHxA uses restricted under entry 79 sit outside paragraph 1. They still count in the 1 mg/L sum.

These rows are not blanket exemptions for industry or shipping. The April 2027 use limit also covers private fire services exercising the function of public fire services. It does not cover contained functional testing of firefighting systems where all releases are contained. That testing stays under the general 23 October 2030 use date unless a longer derogation applies. Intervention at industrial fires in Seveso establishments, where the foam and the equipment are kept for that purpose only, sits in the 2035 row rather than the April 2027 row. Civilian aviation, including civilian airports, is outside the Seveso derogation. The Seveso row means establishments covered by Directive 2012/18/EU.

The ordinary portable-extinguisher marketing date was 23 October 2026. It has passed.

Paragraph 7 conditions started on 23 October 2026, but only for use under the general rule and under the 2035 use derogation. They do not attach to every training discharge or every portable extinguisher. Where they apply, foam is limited to Class B fires, and emissions and exposure must be as low as technically and practically possible. Unused stocks and PFAS-containing waste, including wastewater, must be collected separately where that is technically and practically possible. The management plan is site-specific, reviewed every year and kept for 15 years. Paragraphs 7 to 10 of entry 82 set that scope.

Labeling also started on 23 October 2026. Foam placed on the market at or above 1 mg/L summed PFAS needs a PFAS warning, except portable fire extinguishers. Users label unused stocks and PFAS-containing waste, including wastewater, at that same concentration. Paragraph 10 requires this wording: "WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS".

Earlier substance-specific restrictions still apply. The POPs Regulation separately controls PFOS, PFOA and PFHxS. The PFOA installed-system use exemption ended on 3 December 2025 under Regulation (EU) 2025/1399. Separate trace provisions do not extend that intentional-use exemption.

PFHxA restrictions have applied since 10 April 2026 to specified training, testing and public-fire-service foams, at 25 ppb summed PFHxA and its salts or 1,000 ppb summed related substances, with exceptions. Civil-aviation provisions apply from 10 October 2029. REACH entry 79 is not postponed by the 2030 date.

Replacing AFFF with fluorine-free foam

Treat replacement as an equipment and compliance project. Before ordering fluorine-free foam:

• Inventory the actual concentrate and installed systems.
• Obtain product-specific composition evidence. Do not equate PFOS-free, PFOA-free, C6 and fluorine-free claims.
• Identify the fire-performance approvals needed for the installation.
• Check the equipment manufacturer's conversion and cleaning instructions.
• Plan collection and treatment of removed foam, cleaning water and contaminated materials.

Do not assume a replacement is a drop-in substitute. Cleaning is not proof that all PFAS has gone. The EU PFOA amendment recognizes residual contamination of fluorine-free replacement foam after equipment cleaning. Entry 82 also sets a residual ceiling: fluorine-free foam from equipment cleaned with best available techniques, other than portable extinguishers, must not exceed 50 mg/L summed PFAS. That ceiling derogates from the 1 mg/L rule. It is not a cleanliness certificate. The Commission is to review it by 23 October 2030. Within its scope, entry 82 still requires a plan for cleaning and substitution.

Handling old foam and disposal waste

Start with an inventory and containment plan. Keep product identity and quantity records, identify applicable storage duties, and consult the local regulator and a qualified waste contractor. Include rinse water and contaminated materials in the waste assessment. Don't drain old AFFF foam or rinse water to sewers.

In the US, use EPA's 2026 Interim Guidance, rather than the 2024 edition. It evaluates thermal treatment, landfills and underground injection, including for AFFF. It is non-binding, creates no disposal requirements and endorses no single technology.

The disposal route remains a site-specific problem. EPA recommends facility testing before accepting large quantities for thermal treatment and identifies continuing uncertainty. It also reports greater potential landfill releases than understood in 2024. Disposal or containment does not necessarily destroy PFAS. See EPA's 2026 fact sheet.

In the EU, where paragraph 7 applies, point (c) requires separate collection where technically and practically possible, and handling for treatment that destroys or irreversibly transforms the PFAS content. Agree the process with the contractor against the adopted text.

For Japanese stocks within scope, the binding handling ordinance also requires collection of cleaning water and materials. Include these wastes when arranging removal.

RegAffairs AI answers this AFFF question with links to its regulatory sources.