From January 1, 2026, firefighting media containing more than 10 mg/kg of PFOS will be prohibited on ships worldwide under SOLAS amendments adopted by IMO’s Maritime Safety Committee. The ban affects both new and existing vessels — and for operators trading to Europe, it intersects directly with IHM obligations under the EU Ship Recycling Regulation. Compliance preparation must begin now.
Regulatory basis: Resolutions MSC.532(107), MSC.536(107), and MSC.537(107), adopted June 8, 2023 — amending SOLAS Chapter II-2 and the 1994 and 2000 HSC Codes.
Threshold: Firefighting media containing more than 10 mg/kg of PFOS (0.001% by weight) will be prohibited. This limit effectively defines “PFOS-free” under IMO unified interpretations.
New ships: Keel laid on or after January 1, 2026 must comply at delivery.
Existing ships: Must comply no later than their first survey — annual, intermediate, or renewal — after the January 1, 2026 effective date.
IHM connection: PFOS is listed in Annex I of the EU Ship Recycling Regulation, requiring documentation in IHM Part I for EU-flagged ships and non-EU ships calling at EU ports.
Cost exposure: Compliance costs — laboratory testing, foam replacement, system flushing, hazardous waste disposal, and documentation — can reach hundreds of thousands of dollars per vessel.
What PFOS Is and Why It Is Being Banned
Perfluorooctane Sulfonic Acid — PFOS — is a synthetic compound that has long been the active ingredient in aqueous film-forming foams, widely deployed across the maritime industry to combat hydrocarbon fires at sea. Its effectiveness in suppressing flammable liquid fires made it the foam of choice for tankers, offshore platforms, and vessel engine rooms for decades. But the same chemical properties that make PFOS effective as a fire suppressant also make it one of the most environmentally persistent substances known to science. PFOS does not degrade naturally and can remain in ecosystems for decades after release. It bioaccumulates in living organisms — including humans — and studies have linked chronic exposure to liver damage, immune suppression, thyroid disruption, and possible carcinogenic effects.
The Stockholm Convention on Persistent Organic Pollutants already restricts PFOS use across multiple applications. IMO’s action through the SOLAS amendments adopted in June 2023 eliminates its remaining role in maritime firefighting systems, effective January 1, 2026. For the shipping industry, this is not a distant regulatory development — it is a compliance deadline already within the survey cycle of vessels currently in service.
The PFOS ban represents more than a regulatory update — it is a major environmental and safety milestone for the maritime industry. Shipowners who delay identification and replacement of PFOS-containing foams risk steep compliance costs and operational disruption when surveyors demand proof of PFOS-free firefighting systems at the first survey after January 1, 2026.
The SOLAS Amendments and Their Scope
The regulatory basis for the ban is embedded in three resolutions adopted at IMO’s Maritime Safety Committee 107th session on June 8, 2023: MSC.532(107) amending SOLAS Chapter II-2, MSC.536(107) amending the 1994 HSC Code, and MSC.537(107) amending the 2000 HSC Code. From January 1, 2026, firefighting media containing more than 10 mg/kg of PFOS — 0.001% by weight — will be prohibited across all vessels subject to these instruments. New ships with keels laid on or after January 1, 2026 must comply at delivery. Existing ships must comply no later than their first survey after the effective date, whether that survey is annual, intermediate, or renewal in nature.
Survey compliance deadline: “First survey after January 1, 2026” means the ban is effectively already within reach for vessels whose annual surveys fall in early 2026. Operators who have not begun identification and testing of their foam inventories are already behind the compliance curve. Flag states and classification societies will expect documented evidence of PFOS-free status — not a promise to comply.
At-Risk Equipment: What Must Be Identified
The IHM Connection: EU Ship Recycling Regulation
For vessels trading to or within Europe, the PFOS ban is inseparable from the EU Ship Recycling Regulation. PFOS is listed in Annex I of the EU SRR, requiring its inclusion in IHM Part I — the inventory of hazardous materials present in the ship’s structure and equipment. EU-flagged ships and non-EU ships calling at EU ports must document the presence or absence of PFOS in their firefighting systems. While portable extinguishers are typically recorded under IHM Part III as stores, the ban extends compliance obligations to both fixed and portable systems. Operators must address PFOS risks in parallel with their IHM obligations, ensuring updated documentation and Class-approved Statements of Compliance are in place before the first post-2026 survey.
The Five-Step Compliance Process
As with ballast water treatment mandates and low-sulphur fuel requirements, preparation will determine whether the PFOS transition is smooth or financially painful. Operators who begin identification, testing, and replacement now will manage cost and disruption on their own schedule. Those who delay will face them on the surveyor’s.
The Cost of Compliance — and of Non-Compliance
For many vessels, existing PFOS-containing foams remain in storage tanks, drums, or portable units — often with incomplete or absent documentation of their chemical composition. The cost of bringing a single vessel into full compliance can include laboratory sampling and testing fees, replacement of entire foam inventories, cleaning and flushing of firefighting system pipework and storage tanks, licensed disposal of hazardous waste, and documentation updates including IHM revision and classification society review. Estimates suggest the total expense can reach hundreds of thousands of dollars per vessel — a figure that multiplies exponentially for fleet operators managing dozens of ships simultaneously.
Non-compliance carries its own costs. Vessels found to be carrying PFOS-containing firefighting media after January 1, 2026 face survey failure, flag state or port state control detention, and the reputational and commercial disruption that accompanies an unplanned compliance rectification at a surveyor’s demand. The message the regulation sends is unambiguous: early action is the only financially rational response.
Sources: IMO MSC Resolutions MSC.532(107), MSC.536(107), MSC.537(107) — adopted June 8, 2023 · SOLAS Chapter II-2 as amended · Stockholm Convention on Persistent Organic Pollutants (PFOS listing) · EU Ship Recycling Regulation (EU) No 1257/2013, Annex I · IMO unified interpretations on PFOS threshold
