The United Kingdom's Health and Safety Executive (HSE), acting as the Agency for UK REACH, published its Agency Opinion on a proposed restriction of per- and polyfluoroalkyl substances (PFAS) in firefighting foams on July 9, 2026, and opened the statutory Article 71(1) socioeconomic consultation the same day. The consultation closes at 23:59 London time on September 7, 2026. HSE concludes that restricting the placing on the market and use of PFAS in firefighting foams is an appropriate measure to cut identified risks to the environment and to human health via the environment.
Comments are invited only on socioeconomic factors. Observations on the risk assessment (in particular Sections 2.1 and 4.1 of the Opinion) will not be taken into account. The Agency Opinion, Background Document and annexes are available on the HSE Citizen Space consultation page, with the Agency Opinion PDF as the primary instrument.
What did HSE conclude, and how does this sit in the UK REACH process?
Under Article 70 of UK REACH, HSE must formulate an opinion on the risk assessment after the Annex 15 consultation. That opinion is now public. It follows the Defra Secretary of State's request of March 5, 2024 (with Scottish and Welsh Government agreement) that HSE prepare an Annex 15 report on PFAS in firefighting foams (FFF), supported by the Environment Agency, and the six-month Article 69(6) consultation that ran from August 18, 2025 to February 18, 2026.
The proposal takes a group-based approach covering all PFAS in firefighting foams rather than a substance-by-substance ban. Advice from the REACH Independent Scientific Expert Pool (RISEP) and responses to the Annex 15 consultation fed the Opinion. This is the live UK PFAS lever for foams: Great Britain has no EU-style universal PFAS ban, and Defra's February 2026 national PFAS Plan still points to this FFF measure as the near-term restriction track.
Who is in scope, and what is not yet binding?
Manufacturers, importers, formulators and downstream users of PFAS-containing firefighting foams in Great Britain are the primary audience, including airports, oil-and-gas terminals, chemical plants, defence sites and fire and rescue services that still hold aqueous film-forming foam (AFFF) stocks. Northern Ireland continues under EU REACH for chemicals via the Windsor Framework, so this UK REACH Opinion does not itself set the NI obligation.
Nothing is prohibited yet. Placing on the market and use of PFAS in FFF remain lawful until Defra, with the Scottish and Welsh Ministers, decide to make a restriction by statutory instrument. The government decision is expected in 2027. Continuous per-jurisdiction monitoring is how compliance teams catch that instrument the day it lands, rather than rediscovering it weeks later.
What must operators file by September 7, 2026?
Interested parties should submit socioeconomic evidence by September 7, 2026, 23:59 BST, through the HSE consultation. HSE may share submissions with the Environment Agency, independent scientific advisers and the appropriate authorities (Defra and the Welsh and Scottish Governments). Personal data is handled under GDPR, and confidential material should be flagged using the consultation's confidential-attachment route.
Evidence that lands after the close, or that re-argues the risk assessment, will not shape the socioeconomic opinion. Foam makers and large users should file transition-cost data, fluorine-free alternative performance evidence, stockpile and disposal figures, and sector-specific derogation needs now, while the window is open.
| Step | UK REACH basis | Date |
|---|---|---|
| Defra request for Annex 15 report | Article 69 | March 5, 2024 |
| Annex 15 consultation open | Article 69(6) | August 18, 2025 |
| Annex 15 consultation close | Article 69(6) | February 18, 2026 |
| Agency Opinion published; SEA consultation opens | Articles 70 and 71(1) | July 9, 2026 |
| Socioeconomic consultation closes | Article 71(1) | September 7, 2026 |
| Ministerial decision on restriction (expected) | Appropriate authorities | 2027 |
What should compliance teams do before the ministerial decision?
Map every foam SKU and bulk stock against a PFAS / fluorine-free classification, including leased equipment and contractor-held inventories. Quantify remaining AFFF volumes, replacement product qualification status and waste-disposal routes for PFAS foams, because a future Annex XVII-style restriction will typically phase placing on the market ahead of use and may leave legacy stocks in a compliance grey zone.
Align UK plans with the EU PFAS-in-firefighting-foam track without assuming identity of scope, deadlines or derogations. Train procurement and emergency-response leads that the Opinion is not yet law, but that September 7, 2026 is the last formal socioeconomic input point before HSE finalises the opinion package for ministers.
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What to do next: confirm whether your sites still place on the market or use PFAS firefighting foams in Great Britain, diary the September 7, 2026 socioeconomic deadline, file evidence only on costs and alternatives (not risk), brief EHS and procurement on a 2027 decision window, and treat Obsidian as the companion that flags the ministerial instrument and any Annex XVII SI the day it publishes.
