Why do you need a foam management plan?
EU Regulation 2025/1988 represents a significant step forward in the regulation of PFAS-containing firefighting foams. While previous restrictions focused on individual fluorinated surfactants, this regulation introduces a comprehensive ban on PFAS-containing firefighting foams across the European Union. EU Regulation 2025/1988 also requires users to establish a foam management plan if they continue to use PFAS-containing firefighting foams during the applicable transition periods.
In this article, you will learn what a foam management plan is, which requirements it must meet, and how to implement it successfully.
What is a foam management plan?
A foam management plan is a document that governs the use, storage, and disposal of PFAS-containing firefighting foam concentrates. Its purpose is to minimise the risks associated with these substances and support the transition to fluorine-free alternatives.
The plan should contain all relevant information about the foam concentrates in use, their properties, applications, and the applicable regulatory requirements.
Who needs a foam management plan?
From 23 October 2026, the following users are required to establish a foam management plan:
Establishments covered by the Seveso III Directive (2012/18/EU), i.e. establishments subject to major accident hazard regulations. Civil aviation (including civilian airports) is not included in this category;
Installations in the offshore oil and gas industry;
Military vessels;
Civilian ships with firefighting foams placed on board before 23 October 2025.
Of course, the firefighting foam must comply with all applicable PFAS concentration limits for firefighting foams and qualify for the relevant sector-specific transition periods.
Organisations that have already completed their transition to fluorine-free firefighting foams are not required to establish such a plan.
What must a foam management plan include?
EU Regulation 2025/1988 specifies the requirements for a foam management plan in detail in point 7(d) of the Annex.
Details of use conditions and quantities
The management plan must provide detailed information on the conditions of use and quantities of firefighting foam at the site. This includes the specific fire scenarios in which the foam is intended to be used and the quantities required for different applications.
This information is essential to demonstrate compliance with the conditions set out in the regulation, particularly the requirement to minimise emissions into the environment.
Information on collection and adequate treatment
The plan should also provide information on the collection and adequate treatment of PFAS-containing waste.
This includes procedures for the safe collection and disposal of unused firefighting foams and PFAS-containing waste, ensuring that the PFAS content is destroyed or irreversibly transformed.
Details of cleaning and maintenance procedures​
Another important element of the foam management plan is the documentation of the types and methods of equipment cleaning and maintenance.
This should include specific procedures and maintenance intervals for firefighting systems to ensure that they remain fully operational and that no PFAS-containing residues are left behind.
Plans for accidental releases
The management plan must also include procedures to be implemented in the event of accidental releases, leaks, or spills of firefighting foam.
These should cover emergency response measures and requirements for documenting follow-up actions to minimise the impact on the environment and human health.
Strategy for replacing PFAS-containing firefighting foams
Finally, the foam management plan should include a strategy for replacing PFAS-containing firefighting foams with fluorine-free alternatives.
This strategy should identify suitable fluorine-free products and establish a timeline for the transition.
The management plan must be reviewed annually and kept available for inspection by the competent authorities for at least 15 years.
Conclusion
A foam management plan is an essential tool for organisations that continue to use PFAS-containing firefighting foams. It not only helps ensure compliance with regulatory requirements but also contributes to protecting human health and the environment.
By carefully developing and implementing a foam management plan, organisations can make an important contribution to fire safety and environmental sustainability.
This information was prepared to the best of our knowledge. Nevertheless, it does not constitute legally binding information. Errors or a different interpretation of the regulations cannot be completely avoided.
