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EU restriction on PFAS in fire-fighting foam

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Regulation (EU) 2025/1988, which entered into force on 23 October 2025, introduces comprehensive restrictions on PFAS in firefighting foams. In turn, the regulation will lead to inclusion of a new entry (no 82) in Annex XVII of REACH. The measure prohibits the placing on the market, use, and export of all PFAS-containing foams after defined transition periods. A maximum concentration limit of 1 mg/L (1 ppm) for PFAS, as defined by OECD, will apply, which is also the case for related waste and wastewaters. Systems cleaned and refilled with fluorine-free foam (F3) may, however, contain up to 50 mg/L. Transition periods range from 5 to 10 years, allowing users time to adapt to fluorine-free alternatives. At the same time, existing POP and REACH restrictions for specific PFAS groups, such as PFOS, PFOA, PFHxS, PFHxA, and C9–C14 PFCA, remain in force with even lower thresholds. However, no mandatory analytical method is specified in the regulation.

ECHA has issued a guideline to facilitate the transition from PFAS-containing firefighting foams to F3 alternatives in compliance with the EU foam restriction and POP and REACH regulations. Analytical verification is emphasized, with single substance (target) analysis via LC-MS/MS recommended for quantifying known PFAS compounds in foams and water. To detect precursor compounds, the Total Oxidisable Precursor (TOP) assay is advised, converting hidden species into measurable PFCA. Broader fluorine assessments using Total Organic Fluorine (TOF) and related techniques (AOF, EOF) are suggested for screening, though they lack structural specificity for compliance. Additionally, the guideline promotes surface sampling with adsorbent wipes to identify residual PFAS contamination on system components post-cleaning.

Eurofins has analyzed foams since 2017 using both standard target analysis and the TOP assay. We offer dedicated packages for this matrix and two target analysis packages are available: PFAS18, covering regulated PFAS (PFOS, PFHxS, PFOA, PFHxA etc.) and other common PFCA, PFSA, and FTS substances; and PFAS45, which includes 45 PFAS, including additional simple precursors, and AFFF constituents such as 6:2 FTAB and DPOSA. The TOP package contains the same 18 compounds as PFAS18 and includes C4–C9 PFCA typically formed during TOP oxidation. We strongly recommend combining target analysis with the TOP assay, so a PFAS18 combo pack is available as well. For concentrated or ready-to-use foam (e.g. 3% or 6% dilutions), use the codes in the table below and send 50 ml (min 20 ml) in one of our 100 ml plastic PFAS bottles.

Code Package
PLWBT PFAS 18 in fire fighting products
PLWBW PFAS 45 in fire fighting products
PLWBX PFAS (TOP) 18 in fire fighting products
PLWBY TOP PFAS18 combo (before/after TOP) in fire fighting products

Delivery time is 10 working days. For rinse water or firefighting water, use one of our unclean water packs such as PLWLY (PFAS21), PLW8K (PFAS24), or PLW9E (PFAS30) and send 2×100 ml in PFAS bottles. Bottles can be ordered free of charge on our website. Moreover, TOF can be determined, contact us for more information.

Eurofins also offers a “triple wipe” method for surface swabbing. A white paper has been published (Aug 2025) demonstrating its performance in recovering PFAS from firefighting foam on stainless steel surfaces. Further information on the report, ordering of wipes and analytical packages available can be found in the links below. Always state the matrix on the order and warn if high PFAS levels are expected. More details on foam packs and unclean water packages are available in our online catalogue and flyer.

For questions regarding PFAS, our analytical advisory service is available through customer support at 010-490 8110 or via email at sh-analys.miljo.se@etn.eurofins.com.

Links

EU regulation (PFAS in foam; (EU) 2025/1988)
ECHA guideline
White paper (PFAS wipes)
Eurofins product sheets (foam and wipes)
Eurofins search engine