IMO 2026 PFOS Foam Ban: Your Compliance Path
The Regulatory Change That Will Transform Maritime Firefighting
As Thailand’s exclusive partner for FireDos precision firefighting systems, SATU is committed to helping Thai maritime operators navigate one of the most significant regulatory changes in decades.
January 1, 2026: The International Maritime Organization (IMO) will implement amendments to MARPOL Annex II prohibiting the use of firefighting foam containing PFOS (Perfluorooctane Sulfonic Acid) on all vessels operating under IMO regulations.
For Thai vessel operators, shipping companies, ports, and offshore facilities, this deadline creates an immediate need for strategic planning. The ban requires not just replacing foam concentrates, but ensuring your entire firefighting system remains effective, compliant, and operationally ready throughout the transition.
SATU brings German-engineered FireDos technology to Thailand, providing a uniquely advantageous solution that transforms this regulatory challenge into an opportunity for operational improvement.
Why Partner with SATU for Your Transition
As Thailand’s authorized FireDos partner, SATU offers unique advantages for Thai maritime operators:
- Local Expertise with Global Technology: Our Thai engineering team combines intimate knowledge of local maritime operations with FireDos’s world-leading German engineering
- Comprehensive Thai Support: Complete implementation services including Thai-language consultation, system design, installation, commissioning, and ongoing maintenance
- Regulatory Navigation: Expert guidance on Thai Maritime Department requirements alongside IMO compliance
- Proven Regional Experience: Successful FireDos installations across Thailand’s maritime and industrial sectors
- Dedicated Thai Training: Thai-language operator and maintenance training programs for your team
2. Environmental Testing Without Foam Discharge
In Thailand’s environmentally sensitive coastal waters, this FireDos capability provides exceptional value:
- The only system that allows complete functional testing without discharging any foam to Thailand’s marine environment
- Verify operational readiness through water-only testing while protecting Thailand’s precious coastal ecosystems
- Eliminate foam concentrate waste during testing, reducing operational costs
- Simplify compliance with both Thai environmental regulations and IMO requirements
3. Perfect Performance in Thailand’s Maritime Conditions
FireDos systems are ideally suited for Thailand’s unique maritime environment:
- No electrical components means reliable operation during Thailand’s monsoon season power fluctuations
- Water-driven design ensures functionality even during power outages common in remote Thai waters
- Consistent proportioning regardless of the pressure variations experienced in Thailand’s diverse maritime operations
- Simple mechanical operation reduces maintenance requirements – ideal for vessels operating on Thailand’s extended trade routes
- Direct proportioning without complex calibration needs – perfect for Thailand’s busy ports and offshore operations
The FireDos Technology Advantage: Perfect for Thailand's Maritime Sector
FireDos water-driven foam proportioning systems offer revolutionary benefits that make them ideal for Thailand’s unique maritime environment:
1. Seamless Transition Without System Replacement
FireDos proportioners work equally well with both existing and new environmentally acceptable foams, creating a uniquely simple transition path:
- Install a FireDos system now through SATU INNOVATIVE and continue using your current foam concentrates
- When ready, simply switch to new environmentally acceptable foams with no system modifications
- The same proportioner continues working with perfect precision regardless of foam type
- No need for disruptive equipment replacement or modifications during the transition
This approach is especially valuable for Thai vessels and facilities that need to maintain operational readiness in remote locations or during Thailand’s busy maritime seasons.
How SATU Delivers FireDos Excellence in Thailand
Our comprehensive implementation process ensures your successful transition:
1. Thai-Focused Assessment
Our local engineering team evaluates your specific needs within Thailand’s maritime context, considering local regulations, operational patterns, and environmental conditions.
2. Customized System Design
We design FireDos solutions specifically for your vessels or facilities, optimized for Thailand’s maritime environment and your operational requirements.
3. Professional Installation
Our certified Thai technicians ensure proper installation, integration with existing systems, and comprehensive testing.
4. Thai-Language Training
We provide detailed operational and maintenance training in Thai language for your team, ensuring complete understanding and operational confidence.
5. Ongoing Local Support
Our Bangkok-based support team provides rapid response, routine maintenance, and continuous technical assistance throughout Thailand.
6. Compliance Documentation
We deliver comprehensive documentation in both Thai and English to demonstrate compliance with Thai Maritime Department and IMO requirements.
Why FireDos Technology Outperforms Alternatives for Thai Operators
Thai maritime operators face unique challenges that make FireDos technology especially valuable:
Compared to Bladder Tank Systems:
- FireDos eliminates the need for foam discharge during testing – protecting Thailand’s sensitive marine environments
- No bladder deterioration concerns in Thailand’s tropical climate
- No capacity limitations for Thailand’s larger vessels and facilities
- Simple maintenance compared to complex bladder replacement in remote Thai locations
Compared to Electronic Proportioning Systems:
- FireDos operates without electricity – crucial during Thailand’s monsoon season power fluctuations
- No complex electronics vulnerable to Thailand’s humid, salt-air environment
- Reduced maintenance requirements – ideal for vessels operating throughout Southeast Asia
- No calibration issues with Thailand’s varied water supply conditions
Compared to Around-The-Pump Systems:
- FireDos maintains consistent accuracy regardless of flow variations common in Thailand’s diverse maritime operations
- Broader proportioning range for flexibility across different Thai vessel sizes and facility requirements
- Compatibility with any pump system – ideal for Thailand’s diverse maritime fleet
- Precise proportioning regardless of Thailand’s varied water temperature and pressure conditions
Case Study: FireDos Success in Thailand
Thai Offshore Support Vessel Fleet When a leading Thai offshore service provider needed to upgrade their firefighting systems while preparing for future regulatory changes, SATU INNOVATIVE provided FireDos proportioners for their entire fleet.
Results:
- 40% reduction in testing and maintenance costs
- Zero foam discharge during regular testing and maintenance operations
- Complete system verification without environmental impact
- Simplified crew training and operation
- Ready compliance path for the 2026 IMO PFOS ban with no additional system modifications required
Take Action Now with Thailand's FireDos Experts
The January 2026 deadline creates urgency for planning your transition strategy. SATU INNOVATIVE provides a clear path forward:
- Request a Thai-specific assessment of your current systems and compliance requirements
- Consult with our local experts about implementation strategies tailored to your Thai operations
- Develop a transition timeline that ensures continuous operational readiness
- Begin implementation with Thailand’s trusted FireDos partner
Contact SATU Today!
Don’t wait until the deadline approaches. Prepare now with Thailand’s FireDos experts.
SATU INNOVATIVE CO., LTD.
Bangkok Office: 34/279 Vibhavadi-Rangsit 47, Sanambin, Donmuang, Bangkok 10210 Thailand
Tel: +66-62-469-4617
Email: solutions@satu-innovative.com
Website: www.satu-innovative.com
SATU INNOVATIVE: Bringing German Engineering Excellence to Thailand’s Maritime Sector
Frequently Asked Questions
From 1 January 2026 the IMO prohibits PFOS-containing firefighting foams on SOLAS vessels under MARPOL Annex amendments. Operators must transition to PFAS-free foam concentrates.
All SOLAS-class vessels carrying foam systems including tankers, bulk carriers, offshore supply vessels, FPSOs and fire boats flagged in Thailand or internationally.
BIOEX ECOPOL, National Foam KNOCKDOWN and other AR-SFFF/FFF foams meeting MED, LASTFIRE and FM 5130. SATU stocks BIOEX as a primary replacement.
FireDos water-driven proportioners are foam-agnostic. Most existing units switch to PFAS-free foam with only nozzle and induction checks. SATU performs the conversion and certification.
Port State Control detention, insurance claim denials and MARPOL fines. SATU can issue a compliance gap report within 14 days.
IMO 2026 PFOS Foam Ban: What Thai Shipowners Must Do Before 1 January
Published April 2026 · SATU Innovative · Reading time: 9 minutes
On 1 January 2026, a decade of regulatory signalling becomes operational reality. Firefighting foams containing perfluorooctane sulfonate (PFOS) — long a mainstay of marine fire protection — are prohibited from use and carriage on SOLAS-class vessels under the International Maritime Organization’s amendments to MARPOL and the International Code for Fire Safety Systems (FSS Code).
For shipowners, terminal operators and classification-society-surveyed fleets across Thailand, the deadline is not a distant policy debate. It is a procurement decision, a class-survey item and, for many vessels, a dockyard scope of work that should already be scheduled.
This article sets out what the IMO 2026 PFOS foam ban covers, which vessels and operators fall within scope, how existing foam systems are affected, what PFAS-free alternatives are available in Thailand, and the step-by-step conversion checklist SATU Innovative recommends to reach compliance without disrupting operations or insurance cover.
1. The regulatory timeline — how we got to 1 January 2026
PFOS was first flagged as a persistent organic pollutant under the Stockholm Convention in 2009. The marine sector received a specific exemption at that time because foam concentrates with PFOS were, until recently, the only proven extinguishing medium for certain hydrocarbon fires. That exemption has been closed down in stages.
The key milestones directly relevant to Thai-flagged and Thai-operating vessels are:
- IMO MSC.1/Circ.1312 (revised) — cleaning and inspection standards for foam systems.
- MEPC resolutions (2019 – 2024) — amendments reinforcing MARPOL Annex II and V’s treatment of PFAS-bearing residues.
- MSC 105 / MSC 107 amendments to the FSS Code — requiring foam concentrates to be free of PFOS for new installations and, from 1 January 2026, for carriage and use on SOLAS-regulated ships.
- Port State Control Memoranda (Tokyo MoU, Paris MoU and Indian Ocean MoU) — PFOS presence will become a detainable deficiency from the effective date.
The Thai Marine Department has indicated it will align its Port State Control inspection regime with the Tokyo MoU position. After 1 January 2026, a vessel carrying or using PFOS-containing foam is non-compliant regardless of flag — a PSC detention is the realistic worst case; denial of insurance claims arising from a fire incident using banned foam is the financial tail-risk.
2. Which ships are affected
The ban applies to all SOLAS-regulated vessels. In practical terms, this means:
- Cargo ships ≥ 500 GT on international voyages — tankers, bulk carriers, general cargo, container ships.
- Passenger ships carrying more than 12 passengers on international voyages.
- Tankers carrying oil, chemicals or liquefied gases — the most stringent fire-fighting foam requirements under SOLAS Chapter II-2.
- Offshore supply vessels, MODUs and FPSOs under SOLAS via Resolution A.1023(26).
- Fire boats and rescue craft in port service where SOLAS or equivalent domestic regulations apply.
Non-SOLAS vessels — small coastal craft, inland fishing fleets, recreational yachts — are not directly caught by the IMO rule. However, most Thai owners of those vessels still source foam from the same supply chain transitioning to PFAS-free product.
Terminal and refinery fire brigades are also affected indirectly. Where a port receives SOLAS vessels, its emergency response foam must remain compatible — meaning shore supplies are now effectively required to be PFAS-free too.
3. The engineering impact on existing foam systems
The honest headline is that most physical foam systems on ships do not need to be ripped out. The ban targets the concentrate, not the hardware. That said, converting a vessel correctly is not a drop-in swap, and a careless conversion can compromise firefighting performance at the very moment you need it most.
Four areas need engineering attention:
- Foam concentrate tanks. Residual PFOS-bearing foam bonded to tank walls and seals will contaminate new PFAS-free concentrate. Tanks must be drained, triple-rinsed with demineralised water, physically wiped and verified clean before refilling. Residues are hazardous waste under Thai regulations.
- Proportioners. Mechanical water-driven proportioners such as the FireDos range are foam-agnostic by design. Every proportioner requires a commissioning check after a foam change: induction accuracy, seal material compatibility, and flow-test verification.
- Discharge hardware. Monitors, branchpipes, pourers, rim-seal chambers, sprinkler/deluge nozzles — fluorine-free foams expand at slightly different ratios and can have different drainage and knockdown behaviour. Nozzle orifice sizes should be verified against the new concentrate’s data sheet.
- Pipework and storage seals. PFAS-free concentrates are generally compatible with stainless steel and NBR/EPDM seals, but alcohol-resistant (AR) foams can interact with certain low-cost synthetic seals.
Expect a conversion cost dominated by the concentrate itself, tank cleaning waste disposal, and a commissioning discharge test — not by capital hardware.
4. PFAS-free foam options available in Thailand
There are now multiple families of fluorine-free firefighting foam (FFF and AR-SFFF) with MED, LASTFIRE and FM 5130 approvals suitable for marine use. SATU stocks and distributes BIOEX as the primary replacement for Thai operators, and supports conversion to National Foam, Solberg and Dr. Sthamer ranges.
- BIOEX ECOPOL — French-manufactured AR-SFFF. ECOPOL A is the most common retrofit choice for tankers and terminals handling hydrocarbons and polar solvents. EN 1568 parts 3 & 4, MSC.1/Circ.1312 compliant, MED B-tested, LASTFIRE Positive (1%), FM 5130 approved. Available in 25 kg, 200 kg and 1 000 kg IBC packaging from Bangkok stock.
- National Foam KNOCKDOWN VF — 3% fluorine-free AR-FFF with UL, EN and FM approvals. Excellent burnback, widely used in US refinery retrofits.
- Solberg RE-HEALING RF3 / RF6 — the original fluorine-free range, widely used in Nordic and Australian retrofits, with MED and FM approvals.
- Dr. Sthamer vaPUREx — German-engineered AR-FFF, strong performance on alcohol fires.
Selection comes down to four practical questions: the fuel types carried, the proportioner type installed, the flow rates required, and the owner’s preferred approval body.
5. The SATU conversion checklist
Total calendar time is typically 4 – 8 weeks including waste disposal and certification; dockside down-time is usually 2 – 5 days.
- Compliance gap assessment. Document the existing foam inventory — type, concentration, manufacture date, approval class. Identify all storage locations.
- Select the replacement foam. Based on fuels, flow rates, proportioner and approval body. Order early — global demand has spiked.
- Schedule tank cleaning and waste disposal. PFOS residues handled as hazardous waste via licensed incineration.
- Drain, triple-rinse, verify. Rinse with demineralised water until fluorine content tests fall below the class-agreed threshold.
- Refill with new concentrate. Use new seals on fill ports. Record batch numbers on a certificate for the foam record book.
- Proportioner commissioning test. Water-only induction test at rated, minimum and maximum turn-down flows.
- System discharge test. Wet discharge confirming expansion ratio, 25% drainage time, burnback resistance.
- Certification and record book. Issue class-approved certificate. Update fire safety training records and data plates.
- Crew familiarisation. Brief deck officers, duty engineers and firefighting teams on behavioural differences of the new foam.
6. How SATU supports the transition
SATU Innovative is the authorised FireDos service partner for Thailand and the regional distributor for BIOEX PFAS-free concentrates. We support shipowners, refiners, offshore operators and port fire brigades through the full conversion cycle:
- Compliance gap audit — 14-day desktop and on-board review producing a class-ready report. Offered free of charge to Thai-flagged and Thai-home-ported vessels through the 2026 transition.
- Engineering design — proportioner selection, pipework/seal review, foam system upgrade.
- Supply — BIOEX concentrate from Bangkok stock with 2 – 10 working day lead times.
- Tank cleaning and waste disposal — turnkey with full manifest and destruction certification.
- Commissioning and discharge testing — NFPA 25 and IMO MSC.1/Circ.1312 aligned procedures.
- Annual ITM — inspection, testing and maintenance contracts for the post-conversion system.
- Training — crew familiarisation on PFAS-free foam behaviour, at the owner’s site or our Rayong training ground.
The window is narrower than it looks
Nine months of calendar time between now and the deadline sounds comfortable until you factor in class survey scheduling, dockyard slot availability, foam concentrate lead time, waste disposal manifesting and crew training. Fleets that start the gap assessment in April 2026 are arriving at an already congested service window. Fleets that start in September will be negotiating for emergency dockyard slots in December.
The conversion itself is not difficult. The logistics window is the binding constraint.
If you operate a SOLAS vessel under Thai flag or with Thai-based fire protection scope, SATU will run a 14-day compliance gap assessment at no cost and deliver a class-ready report.