Sep. 25 2025 Firefighting System Home Class & statutory Prohibition of the use or storage of extinguishing media containing perfluorooctane sulfonic acid (pfos) – entry into force 1 january 2026 LinkedIn Twitter Facebook share Convention SOLAS CH II-2 Fire Flag ALL FLAGS Ship typeAll Sea going Ship types SOLAS II-2/10.11 as amended by resolution MSC.532(107) - New Requirements for Firefighting SystemThe International Maritime Organization (IMO) has adopted new amendments to the International Convention for the Safety of Life at Sea (SOLAS) concerning the use of fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS). These forthcoming regulations, which come into force on 1 January 2026, are a key component of global efforts to enhance safety and protect the marine environment. This briefing addresses the most common questions regarding the new requirements.REGULATORY FRAMEWORK & BACKGROUNDQ1: What is the regulatory basis for the PFOS ban, when does it enter into force, and why is it being implemented?A1: The International Maritime Organization has implemented a comprehensive prohibition on perfluorooctane sulfonic acid in fire-extinguishing media through amendments to SOLAS Chapter II-2 and the High Speed Craft Codes. The regulatory framework consists of three key resolutions adopted by the IMO: 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. These amendments enter into force on 1 January 2026 and apply to all ships subject to SOLAS Chapter II-2 and High Speed Craft Codes.The prohibition addresses significant environmental and health concerns related to PFOS, which belongs to the PFAS family of chemicals often referred to as "forever chemicals" due to their persistence in the environment. While PFOS has been effective in firefighting foams, particularly aqueous film-forming foams (AFFF), it is a Persistent Organic Pollutant that poses significant risks to human health and marine ecosystems due to its toxicity and bioaccumulation. Global restriction is driven by international agreements like the Stockholm Convention and represents a direct result of global efforts to protect seafarers and the marine environment from exposure to dangerous chemicals that build up in the body and environment over time with significant negative health effects.Q2: What constitutes prohibited PFOS-containing media?A2: The prohibition applies to fire-extinguishing media, which includes firefighting foams* used in both fixed and portable firefighting systems and equipment. The threshold for what is considered containing PFOS is defined as concentrations above 10 mg/kg or 0.001% by weight*.IMPLEMENTATION TIMELINE & COMPLIANCE REQUIREMENTSQ3: What are the implementation requirements and timeline for new and existing ships?A3: The implementation timeline differs significantly between new and existing ships.For new ships constructed (i.e. keels laid) on or after 1 January 2026, compliance is immediate upon delivery, and they must not use or store PFOS-containing fire-extinguishing media from the outset.For existing ships constructed before 1 January 2026, compliance is required no later than the date of the first survey on or after 1 January 2026.“first survey” means the first annual, periodical, intermediate, or renewal survey (related to SOLAS Passenger Ship Safety Certificate, Cargo Ship Safety Equipment certificate or HSC Safety Certificate) due after 1 January 2026