PFAS in fire-fighting foams: what changes for manufacturers and industry

Key data

If your company manufactures, distributes or uses fire-fighting foams containing perfluoroalkyl or polyfluoroalkyl substances (PFAS), this regulatory correction directly affects you. Regulation (EU) 2025/1988, published on 3 October 2025 in the EU Official Journal, amended Annex XVII of Regulation REACH (EC) No. 1907/2006 to restrict the use of PFAS in fire-fighting foams. Now, a corrigendum published on 8 September 2026 adjusts technical or textual aspects of that original regulation. Any compliance protocol developed on the basis of the initial text must be reviewed in light of the corrected text.

What does this regulation establish?

PFAS (perfluoroalkyl and polyfluoroalkyl substances) are synthetic chemical compounds that are extremely persistent in the environment and in the human body. Their use in fire-fighting foams — especially aqueous film-forming foams (AFFF) — has been one of the main sources of soil and groundwater contamination in Europe.

Regulation (EU) 2025/1988 introduced specific restrictions on these substances under the REACH Regulation, amending its Annex XVII, which is the catalogue of restrictions on the manufacture, marketing and use of hazardous substances in the EU.

The corrigendum now published (OJ:L_202690757) adjusts technical or textual aspects of the original regulation. Although the text of the corrigendum does not publicly detail which specific errors have been corrected beyond what is indicated in the official summary, its publication means that the text with legal validity is the corrected one, not the original from October 2025.

Economic and operational impact

A corrigendum does not introduce new obligations from scratch, but it has real operational consequences for affected companies:

• Review of internal documentation: Any procedure, technical sheet, compliance protocol or contract drawn up with reference to Regulation (EU) 2025/1988 in its original version must be checked against the corrected text. If there are discrepancies, the documentation must be updated.
• REACH compliance risk: Non-compliance with the restrictions in Annex XVII of the REACH Regulation may result in significant administrative penalties, as established by the regulatory framework itself. Penalties are determined at national level, so they vary by Member State.
• Product adaptation cost: Companies that were already in the process of reformulating foams to eliminate PFAS must verify that the timelines and technical conditions they are working with correspond to the corrected text and not the original.
• Supply chain impact: Distributors and end users of fire-fighting foams must request confirmation from their suppliers that products comply with the current corrected text.

Who does it affect?

• Manufacturers of fire-fighting foams that use or have used PFAS in their formulations.
• Distributors and marketers of fire-fighting foams in the European market.
• Managers of industrial facilities that have fixed foam-based fire suppression systems (chemical plants, refineries, airports, logistics warehouses).
• Fire safety maintenance and service companies that supply or refill equipment with PFAS foams.
• Compliance and HSE managers in industrial and safety sector companies.
• Legal advisors and chemical substance consultants who manage REACH files for their clients.

Practical example

A regional airport management company has a fire suppression system based on AFFF foams with PFAS content. Following the publication of Regulation (EU) 2025/1988 in October 2025, its HSE department drew up a plan for the gradual replacement of foams, setting timelines and technical specifications based on the original text of the regulation.

With the publication of this corrigendum on 8 September 2026, the compliance manager must:

1. Download the corrected text from the EU Official Journal.
2. Compare the corrected technical sections with those that formed the basis of the replacement plan.
3. If there are differences, update the plan and communicate it to suppliers and contractors.

Failure to do so means operating with a compliance plan based on a legally invalid text, which exposes the company to penalties in case of inspection.

What should companies do now?

1. Download the corrected text: Access the EU Official Journal (reference OJ:L_202690757) and obtain the corrected version of Regulation (EU) 2025/1988. It is the only text with legal validity since its publication.
2. Review existing compliance documentation: Check all procedures, product sheets and replacement plans drawn up since October 2025 against the corrected text. Identify if any technical or textual section has changed.
3. Update internal protocols if there are discrepancies: If the corrigendum affects timelines, definitions or technical conditions that you were already applying, update internal documents and communicate the changes to operations, procurement and HSE teams.
4. Inform suppliers and customers: If you supply or receive fire-fighting foams, confirm with your supply chain that everyone is operating on the corrected text.
5. Consult a REACH specialist if in doubt: The restrictions in Annex XVII of the REACH Regulation have complex technical and legal implications. If you have any uncertainty about the scope of the corrigendum, consult a chemical substance specialist before making operational decisions.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690757