On July 21, 2026, the UK Health and Safety Executive (HSE) published its agency opinion on the restriction proposal for per- and polyfluoroalkyl substances (PFAS) in firefighting foams, formally launching a 60-day public consultation. The consultation will close on September 7, 2026.
Key Conclusion
In its opinion, HSE explicitly states that the use of PFAS in firefighting foams poses risks to the environment and human health (via environmental pathways), and that existing regulatory measures are insufficient to adequately control this risk. The agency recommends implementing a restriction under UK REACH regulations in Great Britain (GB).
Three Restriction Options
HSE has proposed three restriction options, with the core differences lying in the treatment of unused stockpiles and waste:
Option | Core Measures | 30-Year Emission Reduction | Estimated Cost |
RO1 | Ban on placing on the market and use of PFAS firefighting foams ≥1 mg/L, with transition periods and management plans | 529 tonnes (35%) | £613 million |
RO2a | RO1 + mandatory collection and high-temperature incineration of unused stockpiles | 1,368 tonnes (91%) | £696 million |
RO2b | RO2a + extension to PFAS-containing waste and wastewater from use | 1,422 tonnes (94%) | £704 million |
HSE favors recommending Option RO2a, believing it strikes the optimal balance between cost-effectiveness and emission reduction outcomes.
Sector-Specific Transition Periods
To ensure fire safety is not compromised during the transition, HSE has established differentiated transition periods for various sectors:
- Portable fire extinguishers: 6 months for placing on the market / 5 years for use
- Fire and rescue services: 18 months (extendable to 10 years for COMAH sites)
- Civil aviation: 5 years
- Defence (land-based): 5 years
- Petrochemical/chemical COMAH facilities: 10 years (most complex retrofitting requirements)
- Offshore oil and gas installations: 10 years (challenges include space constraints and seawater compatibility)
- Civilian/military vessels: 10 years (to align with dry-dock maintenance cycles)
Public Consultation
This consultation seeks input solely on socioeconomic factors. HSE particularly welcomes information and evidence regarding:
- Specific data on transition costs
- Technical feasibility and availability of alternative foams
- High-temperature incineration (HTI) disposal capacity and costs
- Practical challenges of transition across various sectors
About CIRS Testing
CIRS Testing, a wholly owned subsidiary of CIRS Group, is an international authoritative third-party testing institution. CIRS Testing has been accredited by China National Accreditation Service for Conformity Assessment (CNAS) and China Metrology Accreditation (CMA). With a mission to enable product compliance for clients and enhance quality for healthy life, CIRS Testing will help clients gain a competitive advantage in the global marketplace by ensuring product safety and quality, and enhancing brand competitiveness.
CIRS Testing has several laboratories, such as hardlines lab, environment lab, daily chemicals lab, medical devices lab, microbial lab (P2), toxicological lab and efficacy lab. CIRS Testing also participated in the compilation of several national standards/ group standards and has a number of technical patents.
Our Services
- Downstream User Import Notification/Full Registration (DUIN)
- Only Representation for non-GB based companies
- Communication within Substance Group
- Review/Prepare Substance Identity Report
- Prepare & Submit Inquiry Dossier to the HSE
- Classification, Authoring/Review SDS & Labels for UK CLP
- PFAS-free Assessment Services
- PFAS Substance Analysis and Identification Service
If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.
Further information
