AFFF (Aqueous Film-Forming Foam)

Aqueous Film-Forming Foam (AFFF) is a firefighting foam formulated with fluorosurfactants, typically PFOS-based or fluorotelomer-based PFAS, to suppress flammable liquid fires (Class B fires). AFFF creates a thin aqueous film that spreads over the fuel surface, cutting off oxygen and preventing reignition. Due to the persistence and toxicity of the PFAS it contains, AFFF has become one of the most significant point sources of PFAS contamination in soil and groundwater globally.

EU Regulation 2019/1021 (POPs Recast), as amended; REACH Annex XVII Entry 77 (firefighting foams restriction adopted October 2025); U.S. NDAA FY2020 Section 322; EPA CERCLA designations for PFOA/PFOS.

AFFF is heavily regulated due to its environmental impact. The EU adopted a REACH restriction on PFAS in firefighting foams in October 2025, with enforcement beginning October 2026 starting with portable extinguishers. In the U.S., the Department of Defense is phasing out PFAS-containing AFFF. Manufacturers of fire suppression equipment must reformulate products and document the transition to fluorine-free foams (FFF). Legacy AFFF stockpiles must be managed in accordance with emerging waste handling requirements under RCRA and CERCLA.

A fire suppression equipment manufacturer supplying foam to European airports must certify that all new AFFF sold after October 2026 is free of intentionally added PFAS, or obtain a time-limited derogation under the firefighting foam restriction entry. Existing PFAS-containing foam inventories must follow the restriction’s disposal provisions.