Per- and polyfluoroalkyl substances (PFAS) are a family of substances that, according to the OECD’s definition, contain at least one perfluorinated methyl (CF3-) or methylene (-CF2-) carbon atom without an H, Cl, Br, or I atom bonded to it.[1] Since the carbon-fluorine bond is one of the most stable bonds in organic chemistry,[2] PFAS are used in a wide variety of applications due to their extreme chemical inertness. Because of their stability, they are also known as “forever chemicals.”[3] However, the widespread use of these substances, which are difficult to break down, is set to be severely restricted in the future.
To address the associated environmental and health risks, the European Union has now adopted Regulation (EU) 2025/1988 on fire extinguishing agents.[4] But what exactly does this entail, and what changes will businesses face?
Use in Fire Extinguishers to Date
Due to their outstanding properties—particularly their thermal and chemical stability, as well as their ability to form a continuous film of water over fire sources—PFAS were frequently used as fire extinguishing agents, such as aqueous film-forming foams (AFFF), to combat liquid fires.
Why are PFAS problematic?
When used as fire retardants, PFAS seep into the soil and thus reach the underlying groundwater. Due to their stability, they accumulate in various organisms and eventually enter the human body through drinking water and the food chain.[3] Precisely because PFAS are chemically extremely stable and therefore long-lasting, they can have far-reaching negative effects on metabolism and internal organs[5] and are, in some cases, suspected of being carcinogenic.[3] PFAS share this persistence with other groups of substances that are regulated under the criteria for persistent, mobile, and toxic substances (PMT/vPvM).
New Limits, Transition Periods, and Bans
Regulation (EU) 2025/1988 entered into force on October 23, 2025[4]. It expands Annex XVII of the REACH Regulation to include Entry 82, which strictly regulates the use of PFAS in firefighting foams. The best-known PFAS, such as perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), perfluorohexanesulfonic acid (PFHxS), and perfluorohexanoic acid (PFHxA)—including their salts and related compounds—are exempt from this new regulation. These substances are already regulated under other EU regulations, primarily in Annex I of Regulation (EU) 2019/1021 and in entries 68 and 79 of Annex XVII of the REACH Regulation.
As of October 23, 2030, firefighting foams with a total PFAS concentration of at least 1 mg/l may neither be placed on the market nor used anywhere in the EU. In addition, a labeling requirement will apply as of October 23, 2026 (excluding portable fire extinguishers). Furthermore, the following special provisions and different deadlines apply in certain cases:
- Fluorine-free foams from decontaminated equipment (excluding portable fire extinguishers): If the equipment has been decontaminated using best available technology (BAT), a maximum limit of 50 mg/l (total PFAS) applies.
- Portable fire extinguishers: They may remain on the market only until October 23, 2026 (until April 23, 2027, for alcohol-resistant foam types). The final date for use is December 31, 2030.
- Special Categories: For facilities subject to the Seveso III Directive (2012/18/EU), as well as for offshore platforms and the shipping industry, extended deadlines for placing on the market and use apply until October 23, 2035.
- Training, testing, and public fire departments: Use is permitted through April 23, 2027. However, for training and testing, this is permitted only on the strict condition that no substances are released into the environment.
Businesses that continue to use PFAS-containing foams with a concentration of at least 1 mg/l under one of these exemptions must comply with strict requirements starting October 23, 2026:
- Its use is permitted exclusively for fires involving flammable liquids (Fire Class B).
- Any release into the environment must be prevented. All wastewater and waste generated must be collected separately and treated properly.
- A detailed management plan must be developed and maintained.
Conclusion
Regulation (EU) 2025/1988 marks an important step toward protecting people and the environment from the long-term effects of PFAS emissions. The phased transition periods give companies the time they need to convert their fire protection systems to future-proof, PFAS-free alternatives (such as F3 foams)—a key component of sustainable hazardous substance management. The first fundamental step in this process is a detailed inventory of all fire-extinguishing foams currently in use at the facility, including a test of their PFAS content. Based on this, the proper substitution and disposal can be strategically planned.
To confidently navigate these complex regulatory requirements and keep track of deadlines, we recommend using professional hazardous substances management software. With Gesi³ GefStoff-Profi, you can manage your hazardous substance inventories in a legally compliant manner, easily document your inventory and the substitution process toward PFAS-free alternatives, and create the necessary risk assessments for new fire extinguishing agents directly in accordance with standards.
Sources
[1] OECD. Reconciling Terminology of the Universe of Per- and Polyfluoroalkyl Substances: Recommendations and Practical Guidance; 2021.
[2] O’Hagan. Understanding Organofluorine Chemistry: An Introduction to the C–F Bond . Chem. Soc. Rev. 2008, 37, 308–319.
[3] Federal Ministry for the Environment, Nature Conservation, Nuclear Safety, and Consumer Protection. FAQs on Per- and Polyfluorinated Chemicals (PFAS) (accessed March 16, 2026).
[4] European Union. Regulation (EU) 2025/1988.
[5] Federal Environment Agency. PFAS in Humans ( accessed March 16, 2026).
