PFAS fire-fighting foam 2026/2030 – management plan, spills & foam replacement | Word/PDF/Excel

Do you have PFAS-containing fire-extinguishing foam in a fire protection system, a large foam tank, or a suppression system? From 23 October 2026, specific requirements apply to handling, emission minimization, labeling, and—for certain continued uses—a site-specific PFAS management plan. This document package helps Swedish facility owners, fire protection managers, environmental coordinators, and service providers compile actual foam and concentration data, document spills, track waste, and plan a safe transition to fluorine-free foam.

Important clarification: 23 October 2026 is not a general total ban on all PFAS foams. EU Regulation 2025/1988 introduces entry 82 to REACH Annex XVII with different deadlines for placing the product on the market, continued use, and specific exemptions. The management plan obligations under point 7 must be assessed based on the actual total PFAS, use, and relevant transitional rule. The template does not constitute authorization to use, sell, or dispose of foam.

The five document templates – practical workflow

1. A01 – Site-specific PFAS management plan: write one plan per relevant facility. Document actual conditions of use, local foam volumes, emission minimization, collection and treatment, cleaning routines, spill response measures, and strategy for switching to fluorine-free foam. Log annual review and at least 15 years of availability for inspection under REACH entry 82 point 7.
2. A02 – Foam concentration, mg/l, and exemption assessment: record the actual system, type of foam, measured total PFAS, analysis certificate, category of use, and correct date. Exactly 1 mg/l is at the limit; untested or unclear foam must not automatically be treated as PFAS-free.
3. A03 – Spills and separate collection: document incidents, estimated quantities, technically/practically feasible collection of foam and contaminated water, relevant recipient, treatment that destroys or irreversibly transforms PFAS, and actual receipts.
4. A04 – Labeling and control: check if and where the REACH entry specific PFAS warning should be present. Separate the product placed on the market from unused stock, waste, and wastewater from foam use.
5. A05 – Foam replacement and annual plan review: inventory alternatives, check actual fire protection suitability through a qualified specialist, document cleaning and waste chain, and follow up on project milestones and document versions.

Excel with nine Swedish tabs

Overview, Sites, Foam Concentration, Use, Collection, Labeling, Spills, Phase-out, and Sources. The workbook contains 707 formulas, status selections, and administrative control flags. It distinguishes, for example, between 0.99 mg/l and 1.00 mg/l, missing laboratory certificates, incomplete facility plans, labeling without photo evidence, and spill response measures that were closed without complete treatment documentation. No fictitious facility or test data is pre-filled.

Excel must never approve handling or phase-out on its own. An indicator such as “plan basis – manual review” only means that the prepared administrative fields are filled in. Legal, fire safety, waste management, and technical functionality require responsible specialists and actual evidence.

What applies from October 2026?

Through the Commission Regulation (EU) 2025/1988, entry 82 to REACH Annex XVII is introduced. The main restriction applies to fire-extinguishing foam with a total of 1 mg/l PFAS or more, with general application from 23 October 2030 and specific earlier and later deadlines. Certain PFAS are also covered by independent older restrictions or bans under REACH and the POPs Regulation. It is therefore misleading to assume that all PFAS foam can be used until 2030.

Plan and emission minimization from 23 October 2026: the specific obligations in entry 82 point 7 cover qualified continued use within the scope of the provision. The plan shall, among other things, describe conditions of use and volumes, collection and treatment, cleaning, spill management, and phase-out. Annual review and at least 15 years of retention are required where the plan obligation applies. The Swedish Chemicals Agency's Swedish guidance outlines restrictions and action requirements.

Transitions – not a single date for all systems

Handheld fire extinguishers: foam with PFAS above the relevant limit could, under the general rule, be placed on the market until 23 October 2026, with a specific deadline of 23 April 2027 for alcohol-resistant foam. Continued use of foam in handheld fire extinguishers has a specific deadline until 31 December 2030. Separate POPs rules may ban certain substances earlier.

Training and testing: continued use for training, exercise, and testing is covered by a specific deadline until 23 April 2027. There is a narrow exemption for functional testing of fire-fighting systems when all emissions are contained. This requires concrete technical and legal assessment.

Seveso, offshore, and ships: certain specifically designated facilities and ships are covered by deadlines until 23 October 2035. Civil aviation/airports are not automatically covered by the Seveso exemption. Another special rule may apply to municipal fire services at Seveso facilities.

Fluorine-free foam in previously PFAS-contaminated equipment: a specific value of 50 mg/l may apply if cleaning has actually been carried out according to best available techniques and other conditions are met. It is not a general limit value for regular PFAS foams or for handheld fire extinguishers.

Who should use the package?

Facility owners with fixed suppression systems, Seveso operations, industrial property owners, fire protection managers, environmental managers, fire service functions, and service companies that need to document foam replacements and PFAS management. The template can serve as a narrow continuation of Template Store's broader chemical risk assessment, but is not a replacement for a fire protection investigation.

Frequently Asked Questions

Must all property owners have a 15-year PFAS plan?

No. Assess whether the operation actually uses PFAS foam and in the manner covered by entry 82 point 7. A company without such foam does not automatically have this specific plan obligation.

Is 1 mg/l a limit value that always means the foam must be replaced immediately?

No. It is the concentration limit for the specific REACH restriction; use, transitional periods, labeling, collection requirements, and other applicable PFAS bans must be assessed separately.

Is a certificate stating “PFAS-free” sufficient?

Not always. Request traceable documentation on which PFAS were analyzed, the sample matrix, method, detection limit, unit, and any residues from the equipment.

Can we empty old foam into the sewer and document it in Excel?

No. Excel is a log, not an approval of emissions. Relevant requirements for collection, waste classification, environmental supervision, transport, and treatment must be followed and handled by authorized actors.

Can the template be used as a finished fire protection design?

No. Foam replacement, cleaning, and safe functional testing must be planned and verified by competent fire and environmental specialists so that the function of the fire protection is not impaired.

Are all documents in English or are the PDF files digitally fillable?

Five work templates, a Swedish guide, and Excel are in Swedish; a separate English User Guide is included. DOCX and XLSX are editable. PDF is searchable and printable but not an interactive fillable form.

Legal sources, version, and limitations

Primary legal source: (EU) 2025/1988, which amends REACH (EC) 1907/2006, Annex XVII, entry 82, points 1–11. Swedish authority sources: Swedish Chemicals Agency and Swedish Environmental Protection Agency on hazardous waste. Separately check POPs Regulation (EU) 2019/1021.

Version 1.0, AI-assisted internal source review November 9, 2026. No external independent legal review, analysis of foam samples, fire protection certification, authority review, approved remediation, or proven waste destruction has been carried out. The product provides administrative documentation support and is no guarantee of legal compliance or fire safety. The digital ZIP file is linked separately to Shopify Digital Products before any future activation.