PFOS free foam: how to meet 2026 inspections
From 2026, shipowners and maritime operators will need to pay particular attention to the documentation of their fire protection systems. The ban on PFOS in foams used on board is entering a practical verification phase, requiring proof of compliance during regulatory inspections. In this context, demonstrating that each PFOS free foam has the required documentation will be essential to passing safety checks without incident.
PFOS document control enters a new phase
From the first safety equipment inspection carried out after January 1, 2026, inspectors must verify that all firefighting foam on board is PFOS-free. This requirement applies to both fixed firefighting systems and portable equipment used in daily operations.
The measure is part of international efforts to remove substances considered harmful to the environment and ensure that ships operate in accordance with current maritime safety requirements .
What documentation will be valid during an inspection?
To demonstrate that a free foam meets the established requirements, companies must have verifiable documentation that clearly identifies the product used on board.
There are three accepted alternatives to prove the absence of PFOS.
Manufacturer's statement
First, the manufacturer can provide a formal declaration confirming that the firefighting foam does not contain PFOS. This document must include sufficient information to link the certification to the product being transported or installed on the vessel.
Accredited laboratory report
Companies can also use an accredited laboratory to analyze samples of the foam. The report must demonstrate that the PFOS concentration remains below 10 mg/kg, equivalent to 0.001% by weight.
TA or MED certificates
Furthermore, some TA or MED type approval certificates already include explicit references to the absence of PFOS. When this information is included in the official documentation, it can be used as valid evidence during inspection.
Traceability will be a determining factor
In addition to presenting valid documents, operators must demonstrate that these correspond exactly to the foam used on board.
To this end, the documentation must contain information such as the manufacturer, foam type, batch number, production date, and references to TA and MED certificates. Similarly, the vessel's containers and records must facilitate product identification to ensure complete traceability.
This requirement seeks to avoid discrepancies between the documentation submitted and the fire extinguishing agents actually available on the vessel.
What will happen to foams that cannot be certified?
When a company cannot provide any of the accepted documentary evidence, the foam must be replaced with another that does have sufficient evidence of the absence of PFOS.
The replacement will affect both fixed systems and portable equipment. For this reason, shipping companies and fleet managers are reviewing inventories and records further in advance to avoid problems during regulatory checks.
Preparations to avoid incidents during inspections
With the new inspections approaching, organizations like DNV recommend starting the collection of documents and the review of the foam installed on each ship as soon as possible.
Early preparation will allow for the correction of any shortcomings before the inspection and will reduce the risk of partial inspections, regulatory observations, or restrictions related to the vessel's authorization conditions.
The maritime sector strengthens control over fire extinguishing agents
The implementation of these controls marks a further step in the shipbuilding industry's adaptation to stricter environmental requirements. The need to certify PFOS-free foam will drive greater levels of documentation control, traceability, and technical management of fire protection systems.For shipowners and operators, the review of documentation will no longer be a secondary administrative task, but an essential element to maintain regulatory compliance and ensure the operational continuity of their vessels.
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