PFAS Update - PFHxA and Fire Fighting Foam

Updates to PFHxA and Fire Fighting Foam

PFHxA: Restrictions as of October 10, 2026

Commission Regulation (EU) 2024/2462 introduces REACH restrictions on PFHxA, its salts and PFHxA-related substances for specified uses.

From 10 October 2026, restrictions apply to defined product groups and uses, including certain consumer textiles and leather, fur or hide products in clothing and accessories, consumer footwear, food-contact paper and cardboard, mixtures supplied to the general public and cosmetics.

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The principal concentration limits are:

• 25 ppb for the sum of PFHxA and its salts, measured in homogeneous material.

• 1,000 ppb for the sum of PFHxA-related substances, measured in homogeneous material.

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Other specified textile and leather uses have a later date of 10 October 2027. The regulation contains a defined scope, derogation, and transitional provisions. This is not a blanket restriction on PFHxA in every electronic or industrial product. Applicability depends on the substance, product, use and relevant legal provisions.

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Action: Screen potentially affected products, confirm applicable derogations and obtain supplier evidence. Do not treat a general PFAS declaration as a substitute for checking the specific legal requirements.

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PFAS firefighting foams: Compliance needs attention

Commission Regulation (EU) 2025/1988 introduces restrictions and transitional requirements for PFAS-containing firefighting foams. These requirements are separate from the PFHxA restrictions under REACH Entry 79.

From 23 October 2026, specified continued uses are subject to conditions, including limiting use to Class B fires and reducing emissions and human exposure to levels as low as technically and practically possible. Requirements also address collection and treatment of unused foam, relevant waste and wastewater where technically and practically possible, as well as labelling and site-specific management plans in the circumstances specified by the regulation.

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Portable fire extinguishers have separate transition dates:

• The applicable transition for placing PFAS-containing foam on the market for portable fire extinguishers ends on 23 October 2026.

• A later date of 23 April 2027 applies to alcohol-resistant foam.

• Use of PFAS-containing firefighting foam in portable fire extinguishers remains permitted under the specified derogation until 31 December 2030.

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These provisions do not amount to a blanket ban on every extinguisher or firefighting-foam application.

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Action: Review factory, warehouse and testing-site inventories. Confirm the rules for each foam type and application, and align fire protection, waste handling and service-provider arrangements with the applicable requirements.

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‍‍What to Do Next

•    Assess products that may contain PFAS and identify CAS numbers of concern.

•    Determine volume and sales territories for products affected by PFAS regulations.

•    Build a program for collecting, analyzing, tracking, and monitoring PFAS in your products.

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Turn PFAS uncertainty into an action plan. Ask for our PFAS assessment report and get a review of your product documentation, compliance gaps, and practical next steps. Contact us today to discuss next steps.

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Get your BlueCircle PFAS Assessment Quote Today

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Links

PFHxA:Commission Regulation (EU) 2024/2462

PFASin firefighting foams: Commission Regulation (EU) 2025/1988

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