If your premises still has foam extinguishers on the wall, there is a reasonable chance nobody has checked what is actually in them. The deadline for removing PFOA-containing firefighting foam from service passed on 3 December 2025, and a great deal of what has been written about it since is either out of date or simply wrong.
Here is what the rules actually say, and what a facilities manager needs to do about it.
What changed, and when
The restriction comes from EU Regulation 2019/1021 on persistent organic pollutants, known as the POPs Regulation. It targets perfluorooctanoic acid, or PFOA, one of a family of chemicals collectively called PFAS. These compounds gave aqueous film-forming foam its performance on flammable liquid fires, and they are also extremely persistent in the environment.
The original phase-out date was 4 July 2025. That date was extended. Commission Delegated Regulation (EU) 2025/1399 was published in the Official Journal on 14 July 2025, came into force on 3 August 2025, and moved the deadline to 3 December 2025.
This matters because a number of Irish fire safety suppliers published guidance around the original date and never updated it. If you are reading advice that states a total prohibition from July 2025, you are reading something that was overtaken by events.
The misreading: it is not a ban on all foam
The most common error in circulation is that foam extinguishers are now illegal. They are not.
The Environmental Protection Agency, which oversees implementation of the POPs Regulation in Ireland, is explicit on this point. There is no ban on the use of all AFFF in portable fire extinguishers or fire suppression systems. What is prohibited is foam containing PFOA above a specified concentration.
Two categories fall outside the restriction:
- Fluorine-free foams — these contain no PFOA at all and are unaffected. They are the standard replacement product and are widely available.
- Foams below the concentration threshold — the prohibition does not apply where PFOA concentration is below 0.025mg/kg. Most portable AFFF units are already below this level.
There is a catch on the second point, and it is the one that catches businesses out. If you are relying on being below the threshold, you need test result evidence to demonstrate it. An assumption is not a defence. If you cannot produce documentation showing what is in your extinguishers, you are not in a position to argue you are compliant.
What this means in practice
For most commercial premises in Ireland, the practical position is straightforward. You need to establish what you have, and you need to be able to prove it.
Step one: identify what is on site
Check your fire register and your most recent extinguisher service report. A competent servicing provider will have recorded the type and, for units supplied recently, the foam specification. Older units, particularly anything installed before 2020, are more likely to be conventional AFFF with no documentation of PFOA content.
Step two: establish whether you can evidence compliance
If your supplier can produce a declaration or test evidence that the foam falls below 0.025mg/kg, the units can stay. If they cannot, the practical answer is replacement. Chasing historic documentation for a twelve-year-old extinguisher is rarely worth the effort compared with the cost of a new unit.
Step three: check your stockpile obligation
If your total inventory of AFFF exceeds 50kg, you have a notification obligation to the EPA. This is more likely than it sounds on larger sites — a hotel or a school with a substantial number of 6-litre foam units can pass the threshold without anyone having considered it. Multi-site operators should be counting across the estate, not per building.
Step four: dispose of it properly
Extinguishers being removed from service because of PFOA content are hazardous waste. They cannot go in a skip and they cannot be discharged for training purposes — the prohibition covers testing, training and application, not just deployment on a real fire. Your servicing provider should be handling collection and documented disposal as part of the replacement.
What to replace foam with
This is where a fire risk assessment matters more than a like-for-like swap. Foam extinguishers are typically installed to cover Class B risk — flammable liquids. The question is whether that risk actually exists on your premises.
In a surprising number of commercial buildings, it does not. Offices, retail units and school classrooms often carry foam extinguishers by habit rather than by assessment. Where there is no genuine Class B risk, water or water mist units cover the Class A risk perfectly well and remove the problem entirely.
Where Class B risk is real — plant rooms, kitchens with fuel storage, workshops, fuel handling areas — fluorine-free foam is the direct replacement. Performance on modern fluorine-free formulations has improved substantially, and the EPA maintains a list of suitable products.
Commercial kitchens are a separate case. Cooking oil and fat fires are Class F, and neither foam nor water is appropriate. Wet chemical is the correct unit there, and that has not changed. If you are unsure which agent suits which risk, our guide to the types of fire extinguisher sets it out.
Where this fits with your other obligations
Extinguisher provision in Ireland sits under the Fire Services Acts 1981 and 2003 and the Safety, Health and Welfare at Work Act 2005, with the technical requirements set out in Irish Standard I.S. 291. Our page on fire extinguisher regulations covers those duties in full. The PFOA restriction does not replace any of that — it sits alongside it. You still need the right type of extinguisher, in the right place, in the right quantity, serviced annually by a competent person, with monthly visual checks recorded in your fire register.
The practical point is that a foam review and an annual service are the same site visit. If your extinguisher service is due, that is the moment to resolve the foam question rather than treating it as a separate project.
A reasonable position to take
If you are eight months past the deadline and have not looked at this, you are not unusual. The extended date, the conflicting guidance and the fact that the restriction is a chemicals regulation rather than a fire safety one have all combined to keep it off facilities managers’ radar.
The exposure is real but manageable. A documented review, evidence where units are staying, and a replacement plan where they are not, is a defensible position. Having no idea what is in your extinguishers is not.
RFC service and supply fire extinguishers for commercial premises across Dublin and Leinster. If you are unsure what is on your walls, we can establish it as part of a free site survey and set out what needs to change.
