From 1 January 2026, new international requirements adopted by the International Maritime Organization will affect the use of fluorinated firefighting foam on board ships. For shipowners and operators, this is not only a question of replacing a foam product, but of ensuring that existing firefighting systems are suitable, compliant and verifiable under the updated regulatory framework.

Understanding what the IMO requirements address, and what they do not, is essential for making informed technical and compliance decisions.

What is changing from 1 January 2026

The IMO has adopted measures that restrict the use of firefighting foam systems using fluorinated foam concentrates. These requirements are implemented through applicable IMO instruments, including SOLAS, and enter into force from 1 January 2026, subject to flag state implementation.

The requirements apply to relevant ship types and fixed firefighting foam installations. While details may vary depending on flag state interpretation, the overall regulatory direction is clear: fluorinated firefighting foams are being phased out in favour of fluorine free alternatives.

Foam replacement versus system suitability

A key point often misunderstood is the distinction between replacing the firefighting foam concentrate and ensuring that the firefighting system itself is suitable for PFAS free foam.

PFAS free foam refers to the formulation of the foam concentrate. System suitability, however, relates to the condition of tanks, piping, valves, pumps and other components that have previously contained fluorinated foam.

Where fluorinated foam has been used, residual fluorinated substances may remain within the system even after draining. As a result, a system filled with PFAS free foam cannot automatically be considered PFAS free or compliant without further consideration.

This distinction between foam replacement and system suitability is addressed through what we refer to as FoamSafe Transition™, with FoamSafe™ applied to prepare existing systems beyond the foam product itself.

Why system condition matters under IMO requirements

The IMO framework places increasing emphasis on verifiable compliance and system integrity. For shipowners, this means being able to demonstrate that the firefighting installation is suitable for the foam in use and does not present a risk of residual contamination.

If residual fluorinated substances remain in the system, they may:

• contaminate newly installed PFAS free foam
• lead to findings during surveys, inspections or audits
• create uncertainty regarding compliance with IMO and flag state requirements

For these reasons, system condition becomes a compliance consideration, not merely a technical detail.

Responsibilities and role boundaries

Under the IMO and SOLAS framework, the responsibility for compliance ultimately rests with the shipowner or operator.

Foam suppliers are responsible for the specification and performance of the foam concentrate they deliver. System suppliers are responsible for the design and integrity of the equipment they provide. Neither party can, by default, take responsibility for the condition of existing systems that have previously contained fluorinated foam unless this is explicitly within their agreed scope.

FoamSafe Transition™ provides a framework that helps clarify this boundary by addressing system condition and readiness separately from foam supply.

The role of system cleaning in the transition

System cleaning addresses the gap between foam replacement and system suitability. It focuses on the removal of residual fluorinated substances from existing firefighting foam systems to support a compliant transition.

Within the context of NGP FoamSafe Transition, system cleaning supports:

• preparation of existing installations for PFAS free foam
• reduction of contamination risk after foam replacement
• documented system suitability during class surveys
• clearer responsibility boundaries between involved parties

System cleaning does not replace foam replacement, but complements it as part of a controlled transition.

What shipowners should consider now

With the 2026 requirements approaching, shipowners and operators should consider:

• identifying which firefighting systems have historically contained fluorinated foam
• reviewing existing documentation and system condition
• clarifying scope and responsibilities with foam and system suppliers
• planning the transition in line with flag state and class expectations

Early preparation reduces the risk of non conformities, unplanned costs and operational disruption.

Key takeaway

IMO 2026 is not only about changing the type of firefighting foam on board. It is about ensuring that firefighting systems are suitable, compliant and defensible under an evolving regulatory framework.

For shipowners, operators and suppliers alike, understanding the distinction between foam products and system condition, as addressed through NGP FoamSafe Transition, is fundamental to achieving a compliant and verifiable transition to PFAS free firefighting foam.