The PFOS Ban Is in Force. The Survey Clock Is Already Running.

PFOS firefighting foam ships are now subject to a mandatory ban under SOLAS Regulation II-2/10.11, in force since 1 January 2026.

The amendment came into force on 1 January 2026. For ships constructed before that date, the compliance deadline is not a fixed calendar date — it is the first SEQ survey on or after 1 January 2026. That means the deadline is different for every ship in your fleet, and for some it has already passed.

What SOLAS Regulation II-2/10.11, as amended by MSC.532(107), prohibits is the use or storage of fire-extinguishing media containing perfluorooctane sulfonic acid — PFOS — above a threshold of 10mg/kg (0.001% by weight). The prohibition applies to all ships. There is no flag carve-out, no trade-specific exemption, and no grace period beyond the survey trigger.

This article sets out what the regulation requires, what the evidence file needs to contain, and where the compliance gap most commonly sits.

What Changed, and When

PFOS has been a restricted substance under international environmental conventions for some years. What MSC.532(107) does is bring the prohibition into SOLAS Chapter II-2 as a mandatory safety requirement, enforceable through the statutory survey cycle.

For new ships — those constructed on or after 1 January 2026 — PFOS firefighting foam on ships must not be used or stored aboard on delivery.

For existing ships — those constructed before 1 January 2026 — the compliance deadline is the first Annual, Periodical, or Renewal survey on or after 1 January 2026. The specific survey type does not matter. The first SEQ survey that falls after the in-force date is the trigger, and compliance must be demonstrated at that survey.

Ships that have already passed that survey without addressing PFOS are non-compliant. Ships approaching their next survey without a complete evidence file are running out of time.

The PFOS Firefighting Foam Ships Compliance Framework

The regulation does not simply require removal of non-compliant media. It requires documented verification that the media aboard either meets the threshold or has been replaced with approved, certificated alternatives. The verification pathway depends on what documentation exists for the foam currently installed.

There are three pathways, and each has its own evidence requirement.

Pathway 1 — Maker’s Declaration

Where the foam manufacturer can provide a declaration confirming PFOS absence, that declaration must contain the following: foam type, production period, batch number, reference to the type approval or MED certificate, and an explicit statement confirming that the product does not contain PFOS above the 10mg/kg threshold. A generic product data sheet does not satisfy this requirement. The declaration must be specific to the batch supplied to the vessel.

Pathway 2 — Laboratory Test Report

Where a maker’s declaration is not available or is insufficient, a laboratory test report confirming PFOS content below the threshold is required. This applies particularly to foam installed several survey cycles ago where the original manufacturer may no longer hold records for that production batch.

Pathway 3 — Sampling and Testing per NPR-CEN/TS 15968

Where neither a declaration nor a laboratory report is available for media installed before 1 January 2026, sampling and testing must be carried out in accordance with NPR-CEN/TS 15968. This is the standard governing the analytical method for PFOS determination in firefighting foam concentrates. It is not a self-certification pathway — it requires accredited laboratory analysis of a sample taken from the foam aboard.

Replacement Media — What the Certificate Must Show

Where existing media is found to contain PFOS above the threshold, or where the verification pathway cannot be completed, the foam must be replaced. Replacement media must be approved and certificated. The certificate must explicitly confirm the absence of PFOS — a general product approval or MED certificate that does not address PFOS content does not satisfy the requirement.

This is a point where compliance gaps appear. Procurement teams ordering replacement foam may source an approved product without checking whether the certificate specifically addresses PFOS. The certificate needs to be reviewed before the media is accepted aboard, not at the survey.

Removal, Disposal, and the Logbook Record

Removal of non-compliant foam is not simply a disposal task. The regulation specifies that removed media must be delivered to shore-based reception facilities. The removal and delivery must both be recorded in the ship’s official logbook. The tanks must be cleaned and all residues removed before replacement media is loaded.

Each of these steps generates a record, and each record is part of the evidence file that the surveyor will review. A tank that has been emptied and refilled without a logbook entry for removal and delivery does not satisfy the requirement, regardless of what is now in the tank.

Where the Compliance Gap Sits

In practice, the failure points for PFOS firefighting foam ships cluster around three areas.

First, older foam with no maker’s declaration on file. Foam installed two or three survey cycles ago, from a supplier who may have since changed ownership or product lines, often has no retrievable batch-specific documentation. The assumption that existing foam is compliant, without verification, is not a defensible position at survey.

Second, replacement foam purchased without a PFOS-specific certificate. The procurement process finds an approved alternative, the foam is installed, and the certificate filed — but the certificate does not explicitly address PFOS. The surveyor asks for evidence of PFOS absence. It is not in the file.

Third, no logbook entry for removal and delivery. The old foam was removed, the tanks were cleaned, and the new foam was loaded. The work was done correctly. But the logbook records the new foam loading without recording the removal and delivery of the old media to a reception facility. The evidence chain is incomplete.

None of these are failures of intent. They are failures of evidence management — which is exactly what the survey will test.

The Action Point

For PFOS firefighting foam ships, the survey is the deadline.. What happens before the survey determines whether you meet it.

For each vessel in your fleet, the starting point is straightforward: identify when the first SEQ survey falls on or after 1 January 2026, establish what foam is currently aboard and from which production batch, and determine which verification pathway applies. If the maker’s declaration or laboratory report cannot be obtained in time, the sampling and testing pathway under NPR-CEN/TS 15968 needs to be initiated well in advance of the survey date.

The evidence file — declaration or test report, replacement certificate where applicable, logbook entries for removal and delivery — needs to be complete before the surveyor boards. Assembling it during the survey is not a viable approach.

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