From 1 January 2026, strict regulations will come into force under amendments to SOLAS Chapter II-2 and the High-Speed Craft Codes (1994 and 2000). These amendments prohibit the use or storage of fire extinguishing media containing Perfluorooctane sulfonic acid (PFOS) on ships. The move aims to protect both the marine environment and human health by phasing out this hazardous substance.
Application of the Amendments
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New ships: Any ship constructed on or after 1 January 2026 must not use or store PFOS-containing firefighting media if the concentration exceeds 10 mg/kg.
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Existing ships: Vessels built before this date must comply by their first scheduled survey (annual, periodical, or renewal) after 1 January 2026.
Proof of compliance will be required in the form of a declaration from the manufacturer and/or laboratory test results. To avoid ambiguity, the IMO’s Unified Interpretations (MSC.1/Circ.1694) provide detailed guidance.
Disposal and Record-Keeping Requirements
Any PFOS-based substances already onboard must be safely removed and disposed of at approved shore-based reception facilities. The IMO has announced that its GISIS module will eventually include a database of recognized facilities. Additionally, PFOS should be listed in a ship’s Inventory of Hazardous Materials (IHM) Part 1, in compliance with the EU Ship Recycling Regulation. When disposal is carried out, the IHM must also be updated accordingly.
The upcoming prohibition of PFOS in firefighting media represents a major step towards a cleaner and safer maritime sector. With clear compliance requirements for both new and existing ships, the IMO ensures that PFOS is effectively phased out and properly disposed of, reducing environmental risks. Shipowners and operators must prepare in advance by securing compliance certificates, arranging disposal through authorized facilities, and updating relevant inventories.
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Source: BRITANNIA P&I CLUB
