Latest Updates from the HSE and Defra
The Health and Safety Executive (HSE) has prepared an Annex 15 dossier under UK REACH on per- and polyfluoroalkyl substances (PFAS) in firefighting foams. The document proposes a restriction to address the risks that PFAS pose to the environment and human health due to their persistence, mobility, and toxicity. In addition, Defra has published a formal draft of an updated BATc (Best Available Techniques Conclusion) for the UK Textiles sector.
Impact on Customers: Key Takeaways from the Annex 15 Proposal
The proposal mandates that customers will no longer be able to purchase or use liquid firefighting foams containing any concentration of PFAS. This restriction applies to all foam concentrates.
- Customers who currently rely on these foams for fire suppression will need to transition to alternative, fluorine-free foams, which the proposal notes are generally available and effective.
- Customers in critical sectors—namely aviation, offshore oil and gas, and defence—will have temporary exemptions with defined deadlines for switching to compliant alternatives.
- Customers should be aware that the goal of this broad restriction is to prevent a simple change from one harmful PFAS chemical to another.
Consultation Process and Next Steps
The public consultation on the proposed restriction is open until February 2026. During this time, stakeholders including foam users, fire authorities, airports, petrochemical operators, and waste managers will be invited to comment on feasibility, costs, and alternatives. Following consultation, HSE will finalise its opinion and submit recommendations to Defra and the devolved administrations. A formal restriction decision is expected in 2027, from which point the transition periods will apply. Under current proposals over the next decade PFAS firefighting foams will be phased out entirely across Great Britain, with disposal obligations falling squarely on the foam holders.
