UK Proposes Comprehensive Ban on PFAS in Firefighting Foams

On July 21, 2026, the UK Health and Safety Executive (HSE) published its agency opinion on the restriction proposal for per- and polyfluoroalkyl substances (PFAS) in firefighting foams, formally launching a 60-day public consultation. The consultation will close on September 7, 2026.

Key Conclusion

In its opinion, HSE explicitly states that the use of PFAS in firefighting foams poses risks to the environment and human health (via environmental pathways), and that existing regulatory measures are insufficient to adequately control this risk. The agency recommends implementing a restriction under UK REACH regulations in Great Britain (GB).

Three Restriction Options

HSE has proposed three restriction options, with the core differences lying in the treatment of unused stockpiles and waste:

Option	Core Measures	30-Year Emission Reduction	Estimated Cost
RO1	Ban on placing on the market and use of PFAS firefighting foams ≥1 mg/L, with transition periods and management plans	529 tonnes (35%)	£613 million
RO2a	RO1 + mandatory collection and high-temperature incineration of unused stockpiles	1,368 tonnes (91%)	£696 million
RO2b	RO2a + extension to PFAS-containing waste and wastewater from use	1,422 tonnes (94%)	£704 million

HSE favors recommending Option RO2a, believing it strikes the optimal balance between cost-effectiveness and emission reduction outcomes.

Sector-Specific Transition Periods

To ensure fire safety is not compromised during the transition, HSE has established differentiated transition periods for various sectors:

Portable fire extinguishers: 6 months for placing on the market / 5 years for use
Fire and rescue services: 18 months (extendable to 10 years for COMAH sites)
Civil aviation: 5 years
Defence (land-based): 5 years
Petrochemical/chemical COMAH facilities: 10 years (most complex retrofitting requirements)
Offshore oil and gas installations: 10 years (challenges include space constraints and seawater compatibility)
Civilian/military vessels: 10 years (to align with dry-dock maintenance cycles)

Public Consultation

This consultation seeks input solely on socioeconomic factors. HSE particularly welcomes information and evidence regarding:

Specific data on transition costs
Technical feasibility and availability of alternative foams
High-temperature incineration (HTI) disposal capacity and costs
Practical challenges of transition across various sectors

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

Our Services

Downstream User Import Notification/Full Registration (DUIN)
Only Representation for non-GB based companies
Communication within Substance Group
Review/Prepare Substance Identity Report
Prepare & Submit Inquiry Dossier to the HSE
Classification, Authoring/Review SDS & Labels for UK CLP
PFAS-free Assessment Services
PFAS Substance Analysis and Identification Service

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further information

HSE

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