Obligation to report foaming agents with PFOA: Everything you need to know

Obligation to report foaming agents with PFOA: Everything you need to know

Foaming agents containing PFOA must be reported to the competent authority. This obligation arises from the EU regulation on persistent organic pollutants. The notification obligation applies to owners of foaming agents that weigh more than 50 kg and where the PFOA limit value is exceeded. In this article you will find all the information on reporting, including a template for reporting foam concentrates containing PFOA.

Health risks of PFOA

What are the potential health risks associated with the use and handling of foaming agents containing PFOA?

There are a number of potential health risks associated with the use and handling of PFOA (perfluorooctanoic acid) and PFOA-containing foaming agents. Here are some of the main health risks associated with PFOA:

  • Carcinogenicity: PFOA has been linked to cancers, particularly kidney cancer and testicular cancer. The International Agency for Research on Cancer (IARC) has classified PFOA as “possibly carcinogenic to humans.”
  • Reproductive health: There is evidence that PFOA can affect fertility. Links have been found between PFOA and difficulty conceiving in women, and reduced sperm quality in men.
  • Liver and immune system: PFOA can affect liver function and weaken the immune system. This can lead to liver disease and increased susceptibility to infections.
  • Hormonal effects: PFOA is an endocrine disruptor, meaning it can cause hormonal changes in the body. This can lead to a variety of health problems, including endocrine system disorders.
  • Thyroid problems: Some studies have shown a link between PFOA exposure and thyroid problems, including hypothyroidism (underactive thyroid).
  • Health risks for children: Children may be particularly vulnerable to PFOA because they are still developing. PFOA exposure can affect neurological development and growth.
  • Persistent compounds: A particular health risk with PFOA is that it is a persistent compound that breaks down very slowly in the body and the environment.
  • Contamination of drinking water: PFOA can be found in drinking water sources, especially near sites where foaming agents have been used. This can lead to direct exposure and health risks for the public.

In light of these health risks, many countries have enacted strict regulations to restrict the use of PFOA and PFOA-containing products and minimize public exposure. It is important to take precautions and follow all applicable safety guidelines when handling these substances.

Which foam concentrates are subject to mandatory reporting?

The reporting obligation applies if the following conditions are met:

  • The total quantity of foam concentrate exceeds 50 kg. The individual containers can also be smaller. The sum of all foam concentrate stocks containing PFOA counts.
  • The limit value of 25 ppb for PFOA or one of its salts or 1000 ppb for the sum of the PFOA precursor compounds is exceeded. Further details on the PFOA limit value can be found here.
  • Use is still permitted (for example, the PFOS limit value is not exceeded).

To whom must the foam concentrate be reported?

The notification must be made to the competent monitoring authority of the respective federal state. As a rule, these are regional or local authorities, depending on the federal state. Examples include the district government, the trade supervisory office or the regional council. You can find the competent authority on the EU ICSMS platform by selecting the Regulation “2019/1021/EU Persistent Organic Pollutants Regulation” under “Directive/Regulation”.

What information must be included in the notification?

The notification should contain the following information:

  • Substance or group of substances according to the entries in Annex I and II of the POP Regulation (in this case PFOA).
  • EC number/list number.
  • CAS number.
  • Type of stock (foaming agents are considered a mixture).
  • Description of the mixture.
  • Total quantity of the substance.
  • Concentration of POPs in the mixture or article.
  • Information from the stock holder on the storage of the stock and on the measures taken to prevent the release of POPs into the environment (evidence of safe, efficient and environmentally sound management).
  • Description of the use.
  • Additional information.

Here you will find a template for the notification of foaming agents containing PFOA, which was kindly provided by the Federal Institute for Occupational Safety and Health (BAuA). This template collects the individual notifications from the state authorities and forwards them to the EU.

When must the foam concentrate be reported?

The notification must be made within twelve months of the regulation coming into force. This period has already elapsed for PFOA and the reporting obligation applies immediately. It must be repeated annually. From July 4, 2025, the use of foam concentrate containing PFOA is no longer permitted. From this date, the foam concentrate must be disposed of and no further notification is required.

Why is it necessary to report foaming agents?

PFOA is regulated in the EU regulation on persistent organic pollutants. Article 5 (2) of this regulation stipulates that stocks must be reported to the competent authority:
“Holders of stockpiles of more than 50 kg consisting of or containing substances listed in Annex I or II, the use of which is authorized, shall notify the competent authority of the Member State in which the stockpiles are located of the nature and size of those stockpiles.”

The term “stocks” can be somewhat misleading. Very few people are likely to understand the foam concentrate in a fire engine or in the tank of an extinguishing system as a “stock”. The European authorities have agreed on an interpretation aid for Article 5 (2) of the POP Regulation. According to the definition in Article 2 (13) of the Regulation, a “stockpile” is a quantity of substances that has been collected. Therefore, any stockpile of substances, mixtures or articles of more than 50 kg should be taken into account, regardless of how they are stored.

Does the foaming agent also have to be reported if the PFOA limit value is not exceeded, but the limit values for C9-C14 PFCA are exceeded?

No, the decisive factor is the PFOA content. Although C9-C14 PFCA substances are also regulated (more details can be found in this article on PFAS in foaming agents), they fall under a different EU regulation (REACH Regulation (EC) No. 1907/2006). This regulation does not require notification. So if the foam concentrate does not contain PFOA but contains C9-C14 PFCA, no notification is required. This could possibly change in the future, as it is assumed that the long-chain PFCA substances will be banned in accordance with the Stockholm Convention and thus fall under the POP Regulation and its reporting obligation. However, this is not yet the case. Further information on this topic can be found in the article mentioned above.

How should these materials be treated at the end of their service life?

Guidelines for the safe disposal of foaming agents containing PFOA:

The safe disposal of foaming agents containing PFOA is of great importance as these substances are persistent organic pollutants (POPs) and can cause environmental impacts. The following guidelines should be observed when disposing of these materials:

  • Collection and identification: Foams containing PFOA should be properly collected and identified. It is important to ensure that they are separated from other waste.
  • Special collection points: Collection of foams containing PFOA should be carried out at special collection points or in specialized facilities. These facilities have the necessary safety precautions to properly treat the substances.
  • Recycling and reuse: Where possible, foams containing PFOA should be recycled or reused. This can help reduce waste and minimize environmental impact.
  • Incineration with caution: In some cases, incineration may be an option to dispose of foams containing PFOA. However, this should be done with extreme caution as incineration can generate toxic waste. Incinerators should have the necessary exhaust gas cleaning systems.
  • Landfill disposal: If no other options are available, foams containing PFOA can be disposed of at special hazardous waste landfills, in compliance with all applicable regulations and safety measures.
  • Regulations and governmental requirements: It is critical to comply with local, national and international regulations and governmental requirements regarding the disposal of foams containing PFOA.
  • Consider environmental impacts: When disposing of foams containing PFOA, the potential environmental impact should always be considered. Measures should be taken to avoid environmental damage.

The safe disposal of PFOA-containing foaming agents requires careful planning and compliance with applicable regulations to minimize environmental impact and protect human and environmental health.

What happens if the foam concentrate exceeds the PFOS limit value?

Perfluorooctane sulfonic acid (PFOS) is also regulated in accordance with EU Regulation 2019/1021. The use of PFOS in foaming agents (above the limit of 10 ppm)
is not permitted and stocks must be treated as waste. As the use is not permitted and the reporting obligation relates to the authorized use, there is therefore no reporting obligation. If the PFOS limit is not exceeded, the foam concentrate may be used and there is no obligation to report due to the (low) PFOS content.

Do foam fire extinguishers also have to be reported?

Yes, foam fire extinguishers must also be reported if they contain AFFF and the PFOA limit value is exceeded. And of course the threshold of 50 kg also applies here. But how is this calculated?

Foam concentrate in a fire extinguisher that contains PFOA is considered a “mixture in a container”. Therefore, only the mixture must be included in the calculation, not the container itself. For cartridge or tube extinguishers, the contents of the cartridge or tube should be counted. If the fire extinguisher has a premixed foam compound (foam compound/water mixture), the entire premixed mixture must be used as the basis for the calculation. In practice, this can lead to considerable differences. In the case of cartridge extinguishers, the reporting limit can only be exceeded after several hundred extinguishers have been used. In contrast, the threshold for premix foam extinguishers can be exceeded with just 5-10 extinguishers.

Environmental impact of foaming agents containing PFOA

How do these foaming agents affect the environment, especially water and soil?

The environmental impact of PFOA-containing foaming agents is of particular interest as PFOA (perfluorooctanoic acid) and similar substances are considered persistent organic pollutants (POPs). These chemicals are characterized by their longevity and environmental persistence, which means that they are slow to degrade in the environment and can therefore accumulate. Here are some key points regarding the environmental impact of PFOA-containing foaming agents:

  • Water pollution: Foaming agents containing PFOA can enter bodies of water, either through accidents or improper disposal. They can accumulate in bodies of water and impair water quality. PFOA is poorly soluble and tends to accumulate in sediments.
  • Soil contamination: Soil contamination can occur during firefighting exercises with PFOA-containing foam concentrates. These substances can penetrate the soil and have a negative impact on soil quality. This in turn can affect agricultural use and the environment.
  • Biomagnification: PFOA and similar substances can undergo biomagnification in the food chain. This means that they can accumulate in higher concentrations in organisms at the top of the food chain, which can affect birds of prey and humans in particular.
  • Environmental regulations: Due to the environmental impact, many countries and regions have imposed strict regulations on the use of PFOA and similar substances in foaming agents.
  • Health concerns: The environmental impact of PFOA is closely linked to health concerns. PFOA can enter the environment and pose a risk to human health, especially if it is detected in drinking water sources.


PFOA-containing foaming agents are chemical substances used in various applications such as firefighting foam. Due to their environmental impact and potential health risks, strict regulations and reporting requirements have been introduced for these substances.
The reporting obligation for foam concentrates containing PFOA is based on the EU Persistent Organic Pollutants (POP) Regulation. Operators who have more than 50 kg of such foaming agents and exceed the specified PFOA limit value must report this quantity. The notification is made to the competent monitoring authority of the federal state.

The notification should contain information on the substance, the quantity, storage, use and additional details. The notification must be made within twelve months of the regulation coming into force and repeated annually.

There are also special rules for foam fire extinguishers and other products that contain PFOA. The reporting obligation depends on the quantity and the PFOA content.

The environmental impact of PFOA-containing foaming agents is significant, as PFOA is considered a persistent organic pollutant. These substances can pollute water and soil, accumulate in the food chain and pose potential health risks to humans and the environment.

The safe disposal of foaming agents containing PFOA requires special care and compliance with applicable regulations. This may include recycling, incineration or specialized landfills.

The use of PFOA-containing foaming agents is associated with a variety of health risks, including cancers, reproductive problems, liver and immune system disorders, hormonal changes and thyroid problems. Special care should be taken when handling and being exposed to these substances.

Overall, due to their environmental impact and health risks, foaming agents containing PFOA are subject to strict regulations and reporting requirements to protect the environment and human health.

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