Are European airports required to replace current foams (AFFF) with fluorine-free foams (F3)?
Answer
At this stage, the replacement of AFFF foams with fluorine-free foams is not mandatory under the regulatory framework in the domain of civil aviation rules by EU-EASA and European current regulations.
However, due to European environmental regulation, the use of some AFFF is banned and considering future deadlines and the European objective of a complete ban of PFAS in firefighting foams, airports should proactively plan the transition to fluorine-free foams.
The transition from AFFF foams to fluorine-free foams is driven by a phased ban - due to health and environmental concerns - on the production and use of certain fluorinated substances (PFAS) that are used in AFFF historically used by Aircraft Rescue and Fire Fighting Services at airports.
At this point, in accordance with the international Stockholm Convention, the European Regulation (EU) 2019/1021 “POPs" (Persistent Organic Polluants) bans on production and use the fluorinated foams containing PFOS (since 2009 and PFOA (since 2020) with some exemptions until end of 2022 and July 2025 for operational uses, depending on if discharges of foamed water are collected.
Additionally, the European Regulation (EC) 1907/2006 "REACH” bans the production and use of additional PFAS in firefighting foams, including PFHxA, to be banned before April 10, 2026, for regular firefighting uses and before October 10, 2029, for civil aviation firefighting (including airports)
Additional bans on any PFAS in firefighting foams are currently under discussion in the EU, leading many foam manufacturers to plan for discontinuing all PFAS-containing products.
As a result, depending on their chemical composition, some AFFF foams are now already banned or will be in future years:
- "C8 foams", containing ‘long-chain” (more than 8 carbons) PFAS, are banned since 01/2023 at airports, where collecting foamed water is not ensured.
- Most of "C6 foams” (more recent generation of AFFF) will be banned in UE, with a specific 5-year delay (10/2029) for ARFF operations at airports.