What the 2026 PFOS Foam Ban Means for RoRo

From 1 January 2026, SOLAS Chapter II-2 prohibits using or storing fire-extinguishing media that contain PFOS above 10 mg/kg (0.001% by weight). For RoRo and car-carrier operators that means every foam stock aboard — fixed deck and machinery-space systems, portable extinguishers, and reserve concentrate in foam lockers — must be confirmed PFOS-free or replaced. Existing ships comply by the first survey on or after 1 January 2026.

What exactly does the SOLAS amendment ban?

Perfluorooctane sulfonic acid (PFOS) in fire-extinguishing media, above a trace threshold. The amendment to SOLAS Reg. II-2/10.11, adopted under resolution MSC.532(107) — with parallel changes to the 1994 and 2000 High Speed Craft Codes via MSC.536(107) and MSC.537(107) — prohibits use or storage of any fire-extinguishing medium containing PFOS in concentrations above 10 mg/kg (0.001% by weight). It applies to both fixed and portable systems. The ban entered into force on 1 January 2026.

PFOS is one compound in the broader PFAS family that made legacy aqueous film-forming foam (AFFF) effective on hydrocarbon fires — and persistent in the environment. The regulation targets the chemistry, not a vessel type, so it lands across the whole fleet rather than on vehicle decks specifically.

Why does it hit RoRo and car carriers in particular?

Because vehicle carriers carry a lot of foam. A PCTC or large RoRo runs fixed foam or deluge arrangements over machinery and weather-deck areas, foam monitors and applicators, portable and wheeled foam extinguishers, and reserve concentrate held in foam lockers. Each of those is a place PFOS-bearing AFFF can still be sitting. The compliance task is not one tank — it is an inventory of every foam-containing system and store aboard.

This is a suppression-media housekeeping item, not a new detection requirement. It runs alongside — but is separate from — the SOLAS II-2/20 detection amendments that require individually identifiable smoke and heat detection on new vehicle carriers from 1 January 2026, with existing RoRo passenger ships following by the first survey on or after 1 January 2028. An operator scoping 2026 drydock work has to plan for both.

What is the compliance deadline?

It depends on keel-laying date. Ships constructed (keel laid) on or after 1 January 2026 must be delivered with no PFOS-containing foam aboard. Ships keel-laid before that date must comply no later than the first survey on or after 1 January 2026 — where "first survey" is the first annual, periodical or renewal survey of the relevant safety certificate. For most of the existing fleet that pulls the real deadline into the 2026 survey window, not some distant horizon.

What evidence does a surveyor expect?

Proof the replacement medium is clean, and proof the old medium was disposed of properly. Classification guidance from Lloyd's Register and DNV points to a manufacturer's declaration for the new foam — type, production period, batch number, and reference to its Type Approval or MED certificate — and confirmation that prohibited media were removed to appropriate shore-based reception facilities rather than discharged. MSC 110, meeting in 2026, approved a Unified Interpretation of II-2/10.11 to clarify how the ban may be documented, so flag and class expectations on paperwork are tightening, not loosening.

Does new foam change the EV-fire problem?

No — and it is worth being clear about that. Swapping to fluorine-free foam is an environmental and regulatory compliance move; it does not address the lithium-ion thermal-runaway sequence on a vehicle deck. A cell venting hydrogen and electrolyte vapour before visible smoke is a detection-timing problem, and the suppression medium — CO2, water deluge, or fluorine-free foam — only acts once a fire is already declared. The foam ban is mandatory work that operators should treat as compliance hygiene, kept separate in their heads from the detection window that decides whether a vehicle-deck fire is prevented or merely contained.

• Build a fleet foam inventory now: fixed systems, portable and wheeled extinguishers, monitors and applicators, and every drum of reserve concentrate.
• Confirm the deadline against each ship's survey schedule — existing ships are caught at the first survey on or after 1 January 2026.
• Collect the paperwork: a manufacturer declaration and Type Approval/MED reference for new media, plus a shore-reception disposal record for the old.
• Treat the foam swap as compliance, not fire-safety improvement — the detection gap on a vehicle deck is unchanged by it.

Sources

• DNV — "PFOS prohibited in fire-extinguishing media from 1 January 2026" (SOLAS II-2 / MSC.532(107); 10 mg/kg threshold; new vs existing-ship timeline).
• Lloyd's Register — Class News 16/25, "Prohibition of use of PFOS in fire-extinguishing media" (MSC.532/536/537(107); fixed and portable; disposal to shore reception facilities; manufacturer declaration).
• DNV — "IMO Maritime Safety Committee (MSC 110)" (Unified Interpretation of II-2/10.11 on documenting the PFOS ban).
• Allianz Commercial — Safety and Shipping Review 2025 (250 ship fire incidents in 2024, +20% YoY, a decade high).
• [VERIFY: SOLAS II-2/20 vehicle-carrier detection dates (individually identifiable detection, new ships 1 Jan 2026; existing RoRo passenger ships first survey on/after 1 Jan 2028) are cross-referenced from class summaries — confirm the exact regulation paragraph and resolution before publication.]