Shipping Material & Testing
View this service
PFOS and PFAS in the Maritime Sector
The maritime industry is undergoing a major shift in how environmental and chemical regulations influence daily operations. One of the most significant areas of concern involves PFOS and the wider PFAS family.
PFOS (Perfluoro octane Sulfonic Acid) is a synthetic fluorinated chemical long valued for its resistance to water, heat, and oils. Per- and Polyfluoroalkyl Substances (PFAS) represent a larger group of more than 4,000 related compounds known for their durability and chemical stability. Although these properties made PFOS and PFAS useful in shipboard applications, they are now driving strict regulatory controls because these substances persist in the environment, do not degrade naturally, and can accumulate in water systems and marine life.
A common misconception is that PFOS is irrelevant to maritime compliance because it is not listed as a hazardous material under the IMO’s Inventory of Hazardous Materials (IHM) and does not appear in MEPC.379(80) as updated by MEPC 405(83) or the Hong Kong Convention (HKC).
In reality, PFOS is heavily regulated through other legal frameworks.
The European Union provides the clearest example:
This is why PFOS compliance is increasingly relevant during technical reviews, procurement evaluations, IHM maintenance, and internal audits.
PFOS and PFAS were common ingredients in older maritime materials. Ships built before global restrictions can still contain PFOS, especially in:
As these materials age or are replaced, shipowners must understand the regulatory obligations that apply.
Multiple global and regional frameworks influence how ships manage PFOS and PFAS:
PFOS and many PFAS compounds persist in marine environments for decades and bioaccumulate in organisms. Because ships handle materials that fall under global chemical laws, restrictions on PFOS impact multiple shipboard systems.
Typical sources include:
Ships built before roughly 2010 have a significant chance of containing PFOS unless replacements were completed.
A major point of confusion in the industry is the belief that PFOS foam ban originates from SOLAS.
They do not.
SOLAS sets performance requirements and type-approval standards for firefighting systems, but it does not regulate chemical composition.
The PFOS foam bans come from environmental laws:
Many shipowners have already phased out PFOS foams to comply with port regulations, class requirements, and environmental laws. When PFOS foams are replaced, SOLAS requirements apply to ensure the new foam is type-approved and compatible.
The industry now faces a major milestone with the newly adopted SOLAS amendments under MSC.532(107):
From 1 January 2026, ships may not use or store any firefighting media containing PFOS.
This applies to:
Because many older foams do not disclose PFOS content, shipowners are encouraged to verify stocks early and complete the transition before the vessel’s first survey after 1 January 2026.
Replacement foams must:
Removed foam must be disposed of through authorised facilities capable of handling POPs waste.
Once PFOS foam is identified, a structured and safe replacement process is required:
The 2026 SOLAS deadline triggers broader responsibilities regarding PFAS management. More regulations are expected, and shipowners must prepare proactively.
Key Priority Actions
Proactive preparation ensures compliance, reduces operational risk, and avoids delays during port inspections.
PFOS and PFAS rules are becoming a major part of how ships are operated and maintained today. Whether it is firefighting systems, coatings, spare parts or even simple consumables, these regulations affect many areas that shipowners deal with every day. The EU Ship Recycling Regulation, the EU POPs Regulation, REACH, Port State Control inspections and guidance from class societies together create a strong framework that limits the use of PFOS and ensures any remaining materials are handled safely.
Shipowners who start preparing early by replacing old PFOS based foams, checking their suppliers, keeping proper records and planning for future PFAS restrictions will avoid last minute pressure and stay ahead of upcoming requirements.
The truth is simple: managing PFOS and PFAS is no longer just a compliance task. It has become an essential part of running a safe, environmentally responsible and future ready vessel.
