COMAH & offshore foam disposal

Why it matters now

• 5 Jul 2025In force

  PFOA foam use banned. Using firefighting foams that contain PFOA, and systems contaminated with them, has been banned since 5 July 2025 under the UK POPs regulation. Old PFOA foam can't be used, so it is waste, and the PFOA in it must be destroyed.

  Source: Environment Agency: Using persistent organic pollutants (POPs), updated 26 Jan 2026; UK POPs Regulation (EU) 2019/1021 as it applies in the UK

• 7 Sep 2026In force · England

  RPS 376: storing PFOA foam waste. The Environment Agency now lets producers store PFOA foam waste while it awaits high-temperature incineration, if they meet its conditions. These include secondary containment for liquids, emailing the EA before relying on it, and sending the EA written confirmation that an appropriately permitted site will accept the waste. It covers concentrates, mixtures and flushings, plus PPE, absorbents, containers and equipment that haven't been decontaminated. The EA says UK high-temperature incineration plants are currently working at capacity for these wastes, and that they are not allowed to be exported for disposal. Review due by 5 July 2027. It does not cover wastes from an activation that aren't compatible with incineration acceptance criteria and need physico-chemical treatment instead.

  Source: Environment Agency: RPS 376, published 7 Sep 2026

• Jun 2026Proposal

  UK foam restriction proposed, not yet law. HSE's Agency Opinion concludes that restricting PFAS in firefighting foams is appropriate, with transition periods set by sector. It proposes 10 years for COMAH sites and for offshore oil and gas installations. HSE also notes that, under some assumptions, demand for high-temperature incineration could exceed the expected capacity at the end of that 10-year period. The socio-economic consultation closed on 7 September 2026. Defra's decision is expected in 2027. Until then, non-PFOA fluorinated foams are not banned in Great Britain.

  Source: HSE: UK REACH restriction on PFAS in firefighting foam (consultation and Agency Opinion, June 2026); Defra: PFAS Plan, updated 17 Aug 2026

• Oct 2025EU / NI

  The EU has its own foam rules. Commission Regulation (EU) 2025/1988 restricts PFAS in firefighting foams in the EU, with longer transitions for some uses. HSE notes that EU REACH continues to apply in Northern Ireland. If you have COMAH or offshore operations in Northern Ireland, check how it applies to you.

  Source: Commission Regulation (EU) 2025/1988 of 2 October 2025 (EUR-Lex); HSE: About REACH (EU REACH continues to apply in Northern Ireland)

Rules last checked 30 October 2026. Proposals can change before they become law. Outside England, rules differ: tell us your site postcode.