SOLAS Reg. II-2/10.11 — in force since 1 January 2026

PFAS was engineered to resist everything. Including replacement.

The same chemistry that made it the perfect firefighting agent makes it cling to tanks and pipework long after the foam is gone. Simply draining a tank is non-compliant — residual cross-contamination will fail laboratory analysis.

Book FoamSafe Transition

Self-service check · two minutes

What foam is in your system right now?

Answer five questions about your foam system and get a preliminary compliance status for the vessel: which rules apply to it, what documentation a surveyor will ask for, and a one-page assessment you can forward to your technical manager.

NGP FoamSafe Transition

The foam is the easy part.

New fluorine-free foam is a purchase order. A compliant system is engineering. PFAS from decades of legacy foam persists on internal surfaces and components — and it fails the laboratory analysis your class society will read. FoamSafe treats the transition as system preparation, not a consumables change: cleaned, verified, refilled and certified in one accountable scope.

  1. Inspection & Setup

    • A scope survey of tanks, pipework, dead-legs and access points — every risk mapped before a single litre moves
    • Equipment rigged with zero operational disruption: the job fits inside your maintenance window
  2. Extraction

    • Legacy concentrate is pumped out with high-capacity systems — fast, controlled, sealed straight into UN-approved IBCs
    • From that moment the waste is NGP’s responsibility: labelled, logged and moved under an unbroken chain of custody
  3. Wash & Fill

    • The system is treated with our Fluor Clean products — chemistry developed specifically for PFAS removal
    • The chemistry attacks the adsorption bond itself — PFAS releases from steel, coatings and residue, and leaves the system under control
    • Refilled with Class-approved fluorine-free foam (F3), to the OEM’s specified mix ratio
  4. Certification

    • Rinse water from the tank’s lowest point, analysed by an accredited laboratory — PFOS, PFOA and total PFAS, typically against a < 20 ppb limit
    • The old foam ends above 1,100 °C — Certificate of Destruction guaranteed, and entered in the vessel’s logbook
    • Fire test and induction check by the class partner — a documentation package DNV, Bureau Veritas and Lloyd’s Register accept

Remove PFAS. Properly.

Water flushing lowers the number. It doesn’t pass the test.

PFAS doesn’t float free, waiting to be rinsed away. It bonds to the system itself — adsorbed into metals, coatings and decades of foam residue. A water flush dilutes the concentration; the bonded layer stays. And at limits measured in parts per billion, what stays is enough to fail.

Our Fluor Clean products are engineered to do what water can’t: break that bond, so the PFAS can be removed under control and handled as the waste it is.

The regulation’s only objective cleaning specification is 50 mg/L total PFAS in foam from equipment cleaned to best available techniques. NGP’s own acceptance criterion is below 20 ppb total PFAS in rinse water sampled from the lowest point — a different measurement matrix, so the two figures are not directly comparable, but a far stricter bar.

The hidden cost trap

Don’t pay for the same clean twice.

The standard approach floods your system with chemicals — then bills you again to incinerate every litre of wastewater it just created. NGP engineered most of that away: chemistry that leaves far less wash water shrinks both invoices at once.

Drastic cost reduction

Proprietary NGP chemistry leaves minimal wash water — you save on the chemicals going in and the hazardous-waste disposal going out.

Slashed downtime

Specialised high-pressure rigs and dedicated crews finish in a fraction of the standard time — the vessel returns to commercial operation fast.

Waste & liability

The waste becomes our responsibility — not yours.

PFAS waste can’t be dumped, diluted or sent down the wastewater line — it must be destroyed above 1,100 °C. Agree it on the order, and NGP takes 100 % control of the waste logistics from pump-out to destruction: labelled, logged, and moved under chain-of-custody documentation at every hand-off.

Guaranteed Certificate of Destruction — after every job.

  • PFOS ≤ 10 mg/kg
  • Lab-verified · NPR-CEN/TS 15968
  • Certificate of Destruction
  • DNV · BV · LR documentation

Proven on your kind of ship

Offshore, cargo and passenger.

This is the scope NGP has delivered on around eighty vessels since 2023 — subsea construction vessels, container ships and ferries. It does not change with the vessel type, only the sequencing.

Offshore and subsea

  • Normand Tonjer· Solstad · subsea construction · Singapore
  • Siem Symphony· Singapore

Cargo and container

  • Henriette Maersk· under way · Italy
  • Norse Wind· Denmark
  • Norse Energi· Amsterdam
  • Petrolina Ocean· Cyprus

Ferries and passenger

  • Torghatten· 7 vessels · Norway
  • MF Lysingen· Norway
  • Petter Dass· Norway

Henriette Maersk

Changed under way. Zero off-hire.

Foam replacement and full system cleaning completed while the vessel was under way. Off-hire is the first objection every fleet manager raises. On this hull there was none.

Where we have done this

Alongside, in yard, or under way. Wherever the vessel is.

Around eighty vessels since 2023, from Bergen to Singapore. We bring the crew, the equipment and the waste chain to the ship, so the job fits your schedule rather than ours.

Marioff foam system cleaning and foam replacement

Cleaning and refill of a Marioff fixed foam concentrate system on Solstad Farstad's subsea construction vessel Normand Tonjer.

Singapore

Torghatten foam replacement

Foam replacement on 7 Torghatten ferries with eco-friendly, fluorine-free foam.

Norway

MF Lysingen - Foam replacement

Fluor-free foam conversion and full system cleaning completed on MF Lysingen.

Norway

Torghatten — seven ferries

Fleet-wide foam replacement, systems cleaned and refilled with fluorine-free foam

Norway

MF Lysingen · Petter Dass

Passenger vessels transitioned alongside

Norway

Norse Wind

Cargo vessel, foam out, system cleaned and verified

Denmark

Norse Energi

Transitioned in Amsterdam

Netherlands

Henriette Maersk

Foam replacement and full system cleaning completed under way — zero off-hire

Italy

  • Norway
  • Denmark
  • Netherlands
  • Italy
  • Cyprus
  • Singapore

The regulatory horizon

The window is closing.

PFAS compliance isn’t one deadline — it’s a tightening series. And every step assumes your system, not just your foam, can pass a laboratory analysis.

  1. In force

    PFOS, PFOA and more

    SOLAS PFOS ≤ 10 mg/kg. EU POP PFOS ≤ 0.025 mg/kg. PFOA, C9–C14 PFCAs and PFHxS limits — all already in force.

  2. October 2026Next deadline

    PFHxA + labelling

    PFHxA limited to ≤ 0.025 mg/kg in firefighting foams. From 23 October: mandatory labelling of foam holding ≥ 1 mg/L total PFAS, a foam management plan reviewed annually, Class B use only and separate waste collection.

  3. August 2028

    Legacy interim ends

    The interim allowance for PFOA in installed legacy systems runs out.

  4. October 2030

    The full ban

    General prohibition of PFAS in firefighting foams — sum of all PFAS ≥ 1 mg/L. Foam from equipment cleaned to best available techniques: < 50 mg/L.

  5. October 2035

    Ships and offshore

    End of the transition for civilian ships with foam on board before 23 October 2025 and offshore oil and gas installations. The interim duties still apply throughout.

Chemical cleaning crucial

Critical PFAS limit values

Chemical cleaning crucial

From NGP’s compliance material; entry 82 figures verified against Reg. (EU) 2025/1988. References open the governing act at EUR-Lex and the IMO.

Questions about FoamSafe Transition?

Is replacing the foam enough to be compliant?

No. Simply draining a tank is non-compliant — PFAS from legacy foam persists on internal surfaces and components, and residual cross-contamination will fail laboratory analysis.

Why isn’t water flushing sufficient?

PFAS adsorbs to steel, coatings and residue. Water flushing lowers the number but doesn’t break the adsorption bond — Fluor Clean chemistry does, so the PFAS can be removed under control.

What happens to the old foam and wash water?

Both are collected in UN-approved IBCs and moved under an unbroken chain of custody, then destroyed above 1,100 °C — with a guaranteed Certificate of Destruction after every job.

How is the result verified?

Third-party laboratory analysis (NPR-CEN/TS 15968) with lowest-point sampling, plus fire test and induction check by the class partner — a documentation package DNV, Bureau Veritas and Lloyd’s Register accept.

Can it be done without taking the vessel off hire?

In most cases, yes. Equipment is rigged with zero operational disruption and the job is scoped to fit inside your maintenance window — on Henriette Maersk the full foam replacement and system cleaning was completed while the vessel was under way, with no off-hire.

Which deadlines apply?

PFOS limits are already in force under SOLAS — at your first survey on or after 1 January 2026. PFHxA limits, mandatory PFAS labelling and the foam management plan requirement land on 23 October 2026; the interim allowance for legacy PFOA ends August 2028; the general prohibition of PFAS in firefighting foams follows in October 2030. Civilian ships with foam already on board before 23 October 2025, and offshore oil and gas installations, have a transition period to October 2035 — but the 2026 interim duties apply throughout.

Does the EU restriction apply if the vessel never calls at EU or EEA ports?

No. REACH entry 82 binds the placing on the market and use of foam in the EU and EEA; a vessel that never calls there is not covered by it. SOLAS II-2/10.11 applies to every vessel regardless, and flag administrations and charterers’ vetting programmes increasingly ask for the same laboratory evidence.

What is the 50 mg/L limit?

Entry 82 allows up to 50 mg/L total PFAS in foam originating from equipment that has been cleaned using best available techniques. It is the regulation’s only objective cleaning specification — and the reason drain-and-fill fails. NGP’s own acceptance criterion, below 20 ppb total PFAS in rinse water from the lowest point, is a different measurement matrix and cannot be compared directly, but it is considerably stricter.

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