What changes on 23 October 2026?
Commission Regulation (EU) 2025/1988 of 2 October 2025 was published on 3 October 2025, entered into force on 23 October 2025, and amended Annex XVII to REACH Regulation (EC) 1907/2006. On 23 October 2026, several specific conditions take effect for firefighting foams containing per- and polyfluoroalkyl substances (PFAS). This is not a universal ban on all PFAS in every product. [1, 2]
- EU act
- 2 October 2025
- OJ publication
- 3 October 2025
- Specific deadlines
- 23 October 2026
Placing on the market versus continued use
The derogation for placing on the market PFAS-containing firefighting foams for portable extinguishers, where the sum of PFAS reaches 1 mg/L or more, has a deadline of 23 October 2026. Specific additional derogations remain, including until 23 April 2027 for certain alcohol-resistant foams in portable extinguishers. Critically, placing on the market and use are distinct: a permitted-use derogation exists for certain portable extinguishers until 31 December 2030, subject to the regulatory conditions. [1]
Labelling of products, unused stocks and waste
As of 23 October 2026, firefighting foams placed on the market with a combined PFAS concentration of at least 1 mg/L must carry the specified label, excluding portable extinguishers from this particular labelling rule. From the same date, users must label unused stock and PFAS-containing waste, including wastewater generated from firefighting foams, where the threshold is reached. The warning must be clearly visible, legible and indelible, using the language required by the relevant Member State. [1, 2]
Permitted uses: containment, treatment and management plan
For ongoing uses that fall within point 7 of the new restriction, additional conditions apply from 23 October 2026: minimising releases and exposure, separate collection and suitable treatment where feasible, and a site-specific PFAS firefighting foam management plan. The plan covers volumes, maintenance, accidental spills and substitution, is reviewed annually and remains available for inspection for at least 15 years. These requirements must not be applied indiscriminately to every portable extinguisher or user; scope and derogations must be checked. [1, 2]
Practical checks for companies
Manufacturers, importers, distributors, site operators and professional users should inventory the relevant foams and extinguishers, check safety data sheets, verify total PFAS concentrations, intended use and exemptions, and review labels, stocks, waste-handling procedures and supplier evidence. Other transition dates in 2027, 2030 and 2035 can apply to specific activities; a single generic PFAS deadline would be misleading.
Official sources
Regulatory update of 23 October 2026. Always check foam type, PFAS threshold, use, derogation and applicable legal deadlines.