Daily enquiries are flooding in from across the industry, all asking the same question: what’s the real situation with aqueous film forming foam (AFFF) fire extinguishers?
With widespread confusion about compliance deadlines and disposal requirements, it’s time to set the record straight.
The Root of the Confusion
The industry chaos stems from ambiguous guidance published by the Environment Agency in January 2022.
Their document, “Compliance Advice for PFOA in Class B Firefighting Foams,” created widespread misinterpretation that all AFFF extinguishers must be removed from service by July 4th, 2025.
Industry sources reveal this directive actually targets specific chemicals – PFOS, PFOA, and PFHxS – predominantly found in fixed firefighting systems and fire brigade foams, not portable fire extinguishers.
Multiple extinguisher manufacturers confirm that products manufactured from 2015/16 onwards have been filled with compliant AFFF formulations, free from these restricted substances.
The reality: Compliant extinguisher AFFF can legally continue in service beyond the July 2025 deadline.
The Next Foam Phase-Out Target
Attention now shifts to PFHxA, currently used in extinguisher AFFF formulations.
DEFRA and the HSE are conducting stakeholder consultations (https://consultations.hse.gov.uk/crd-reach/pfas-fire-fighting-foams) to determine this chemical’s phase-out timeline.
Industry insiders expect no action before 2030, providing a full five-year window for natural replacement cycles through standard extended service requirements.
Industry Recommendations on Foam Fire Extinguishers
Documentation Strategy
Fire extinguisher installers are advised to secure safety data sheets from suppliers for all AFFF extinguishers sold within the past five years.
This documentation serves as crucial evidence when addressing customer compliance concerns.
Managed Phase-Out Approach
Experts recommend implementing a gradual replacement strategy, removing AFFF extinguishers as they reach their five-year extended service intervals.
This approach distributes replacement costs across multiple years, avoiding sudden financial impact on consumers.
Foam Disposal Crisis Looming
Proper disposal requires specialized AFFF incineration – a process with limited capacity.
Warning signs emerged earlier in 2024 when the UK’s largest extinguisher recycling facility temporarily suspended foam extinguisher acceptance due to overwhelming demand exceeding processing capabilities.
Industry analysts warn against a disposal “glut” that could overwhelm incineration processors, potentially creating significant delays and cost increases.
Replacement Options
Water-Based Solutions Dominate
Analysis reveals that Class A fire coverage meets requirements for the majority of current AFFF installations.
The historical preference for foam extinguishers originated in the 1980s, driven not by superior Class B ratings, but by their compact size advantage over the era’s cumbersome 9-litre water units.
Modern 6-litre water spray/mist extinguishers now deliver 13A ratings – with some achieving 21A ratings – while eliminating environmental concerns during both operation and end-of-life disposal.
Specialist Applications
For genuine contained Class B fire risks involving flammable liquids, non-fluorinated foam alternatives remain available through multiple distributors.
Broader Fire Extinguisher Compliance Issues
Investigation reveals that numerous other extinguisher types may fail current regulations.
Products marketed as “environmentally friendly” over the past decade frequently fall short of compliance standards.
Wet chemical extinguishers face similar scrutiny, alongside many “water with additive” formulations.
Industry professionals are urged to obtain comprehensive safety and chemical composition data sheets from suppliers to verify compliance status.
Essential Resources
The Fire Industry Association published comprehensive guidance in September 2024, providing detailed compliance instructions: https://www.fia.uk.com/news/fia-guidance-on-pfas-in-firefighting-foams-restrictions-update-september-2024.html
Businesses managing redundant AFFF extinguisher quantities must adhere to the updated Regulatory Position Statement (RPS) 132 from the Environment Agency: https://www.gov.uk/government/publications/end-of-life-fire-extinguishers-re-use-and-dismantling
This framework covers trade extinguisher storage restrictions, disposal protocols, and licensing requirements.
Non-compliance carries substantial financial penalties, particularly severe where environmental releases occur.
With proper documentation, strategic planning, and adherence to current guidance, the industry can navigate these regulatory changes while maintaining safety standards and environmental responsibility.

