The requirement to document PFOS-free fire-extinguishing foams applies to all types of foam on board, i.e. both fixed systems and portable equipment.
Briefly summarized, there are three ways to document PFOSfree foam:
If none of the above can be provided successfully, the foam will need to be replaced with PFOS-free foam, with documentation according to 1), 2) or 3) above.
For the DNV surveyor to verify that the PFOS documentation corresponds to the actual foam on board, the documentation must contain sufficient information to trace it to the foam in use. Such information may include the manufacturer, foam type, production date / batch number and relevant TA/MED certificate references. Furthermore, the marking of and documentation for the foam(s) carried on board must include adequate information to demonstrate traceability back to the PFOS documentation.
DNV has prepared a template that can be used by manufacturers to prepare the PFOS-free declaration. The template is attached to this news. It is not mandatory to use this template – it simply aids you in ensuring the necessary information is provided.
For more information on the retroactive requirement, reference to relevant regulations, guidance for changing foam, etc., please read our previously issued news (see reference below).
To avoid follow-up actions, Conditions of Authority or part-held surveys, preparation should start early to ensure the necessary documentation for all foams on board is in place before the survey.
DNV Technical and Regulatory News No. 37, November 2025: PFOS prohibited in fire-extinguishing media from 1 January 2026
