Singapore’s PFAS foam phase-out: what the revised NEA guideline requires
BriefingRegulationSingapore
Since 1 January 2026, Singapore has phased out the import and use of firefighting foams containing PFOA, PFOS or PFHxS above set trace thresholds. NEA revised its industry guideline in March 2026, and a prohibition on long-chain PFCAs follows on 16 December 2026.
Updated October 2026 for Version 02 of the NEA guideline (27 March 2026), the phase-out in force since 1 January 2026 and the long-chain PFCA prohibition from 16 December 2026. First published November 2025.
On 27 March 2026, Singapore’s National Environment Agency (NEA) issued Version 02 of its Industry guideline on the phase out of PFAS containing firefighting foams. The guideline was prepared by a joint working group of NEA and the Oil and Petrochemical Industry Technical & Safety Committee. It replaces Version 01, dated 12 November 2025.12
PFAS, the per- and polyfluoroalkyl substances that give fluorinated foams such as AFFF (aqueous film-forming foam) their film-forming performance, persist in the environment. Singapore is a Party to the Stockholm Convention on Persistent Organic Pollutants. The Convention’s exemptions for three PFAS groups expired in December 2025: PFOA, PFOS and PFHxS, with their salts and related compounds (Section 3.1).1
The phase-out is no longer a future date. Since 1 January 2026, Singapore has phased out the import and use of firefighting foams that contain any of the three above their thresholds. NEA first announced this in a circular in March 2024.3 Operators must be able to show that the foam on site complies, and the guideline places principal responsibility for foam, firewater and PFAS wastes on the owner or occupier (Section 6.1).
What has applied since 1 January 2026
Table 1 of the guideline sets the threshold for each substance. Version 02 describes these as unintentional trace contamination thresholds. Companies shall provide test reports, safety data sheets (SDS) or technical specifications to NEA on request. NEA accepts test reports from laboratories accredited by the Singapore Accreditation Council or an equivalent overseas body (Section 3.1).
Training foam is treated the same as operational foam and must not contain non-compliant PFAS. Non-compliant foam may be used for testing or maintenance only where all releases can be contained (Section 3.2). Firewater, wastewater, runoff and other wastes containing non-compliant PFAS shall be contained and disposed of as toxic industrial waste (TIW) through an NEA-licensed toxic industrial waste collector (TIWC) (Section 5.4).
Regulatory detailTest methods, disposal and responsibility
Test methods. The guideline lists US EPA Methods 533, 537 and 1633, EN 17681-1 (modified for foams) and the Total Oxidisable Precursor Assay (Section 3.1).
Stocks above the thresholds. Companies storing or using foams at or above the thresholds are required to engage NEA-licensed TIWCs for collection and disposal (NEA/HS/6.6, paragraph 3).3
Responsibility. The owner or occupier has principal responsibility for the foam, its concentrate, firefighting water, waste management and their effects, and this responsibility does not pass to the Singapore Civil Defence Force (SCDF) during an emergency response (Section 6.1). Companies in mutual support arrangements should work together to follow the guideline (Section 6.2), and SCDF’s role does not remove a company’s obligation to cover PFAS releases in its business continuity plan (Section 6.3).
What changed in the March 2026 revision
The threshold values and the list of substances are unchanged. The substantive change is in the acceptance criteria for cleaned systems (Section 5.3). Both versions accept a system whose residual PFAS does not exceed the Table 1 limits. As a second route, Version 01 accepted cleaning to ALARP, as low as reasonably practicable, “with justification of why the threshold limits specified in Table 1 cannot be reached”.2 Version 02 accepts systems that “have been cleaned using any cleaning method outlined in Section 5.2” to ALARP.
The test of ALARP has therefore moved from an argument about why a limit cannot be met to a record of how the system was cleaned. Section 3.1 also adds the words “unintentional trace contamination” to the description of the thresholds.
Cleaning legacy systems to ALARP
Section 5.2 states that companies shall take all reasonable and practicable steps to clean their firefighting systems and equipment. Table 2 defines the scope. For fixed systems, it covers the foam tank, foam piping up to the proportioner or nearest isolation valve where foam is always pre-filled, and any piping network packed with foam. For foam trucks and carriers, it covers the foam tank and its piping. Portable foam extinguishers are replaced entirely, or cleaned if they are to be refilled (Section 5.1).
Sampling addresses how PFAS behaves after cleaning. Residues absorbed into elastomers, bladders, proportioning equipment and long stagnant pipe runs can diffuse back into the new foam over time, which is known as rebound. The guideline allows the level of contamination to be established by analysing a representative sample of the new concentrate or foam solution taken after a one-month residence time in the cleaned system, and states that this period accounts for rebound (Section 5.3).
Archer treats ALARP cleaning as an engineering- and data-led exercise. The cleaning plan is set from the construction of each system and from sampling results, and effort is directed where it reduces residual PFAS. This keeps the cost of cleaning proportionate to the result, and the records it produces are the evidence Section 5.3 now asks for.
For engineersThe hot-water cleaning protocol in Section 5.2
- Flush. Continuous water flushing of the system or equipment until no foaming is seen at the output.
- Soak and flush. At least three soaking and flushing cycles of 24 to 48 h each, using hot water at 50 °C or higher at the start of each soak, maintained as best as practicable through the soaking cycle.
- Mechanical assistance. Mechanical means, such as high-pressure washing or surface agitation, may be used to agitate the cleaning fluid and remove solidified foam residue.
- Refill and sample. Fill with the new foam and, after one month of residence, sample the concentrate or solution for analysis (Section 5.3).
Choosing and proving the replacement foam
No new foam should be considered a drop-in replacement in existing systems without its suitability pre-confirmed and performance verified.
NEA guideline, Version 02, Section 4.1
Section 4.1 lists the factors to assess. They include concentrate viscosity, distinguishing fluid (Newtonian) from shear-thinning or thixotropic (non-Newtonian) concentrates, compatibility with proportioning hardware, material compatibility, concentrate stability, suitability for every flammable liquid stored, application method, temperature extremes, expansion ratio, application rate, burn-back resistance, extinguishment time and vapour suppression. Section 4.2 adds operational factors, including compatibility with the equipment of mutual-aid responders and the volume of firewater a fire could produce.
In Archer’s experience, these factors lead directly to engineering work. Many synthetic fluorine-free foam (SFFF) concentrates are more viscous than the AFFF a system was designed around, and some are non-Newtonian. This changes friction losses, induction and discharge, so hydraulic models need updating and proportioners, bladder tanks and foam pumps need checking against their operating ranges. A foam chosen on its certification label alone has not met the Section 4.1 test.
For engineersHydraulics, hardware and foam selection
Hydraulic modelling. Archer updates the hydraulic model for the properties of the selected concentrate, so that proportioners, bladder tanks, foam pumps and fixed systems stay within their required operating ranges in the design-basis scenarios.
Hardware compatibility. A compatibility review confirms that existing hardware can deliver the new foam within tolerance, covering flow rates, back-pressure limits, concentrate induction parameters and minimum operating pressures. Equipment built for AFFF is not assumed to be compatible.
Foam selection. Selection follows a performance-based approach matched to fuel types, hazard profiles and application methods, consistent with Sections 4.1 and 4.2.
Regulatory detailLong-chain PFCAs from 16 December 2026
Long-chain perfluorocarboxylic acids (LC-PFCAs), with chain lengths of at least C9 and not more than C21, their salts and related compounds, were listed in Annexes A and C of the Stockholm Convention by decision SC-12/12 in May 2025.7 The UN depositary notification was issued on 16 December 2025.8
In Singapore, LC-PFCAs appear in the list of controlled hazardous substances under the Second Schedule of the Environmental Protection and Management Act (EPMA), with effect from 1 August 2025.6 NEA circular NEA/HS/6.6/SC02 of 26 January 2026 states that from 16 December 2026 the manufacture, import and export of LC-PFCAs, and of products containing them, will not be allowed. Existing stocks imported before that date may be depleted. NEA is reviewing whether any of the Convention’s specific exemptions are relevant to local industry and will provide details in due course.5
LC-PFCAs are not among the substances in Table 1 of the foam guideline (Version 02).
For operatorsActions by area of focus
| Area | Actions now |
|---|---|
| Engineering | Gap analyses covering hydraulic capability, foam hardware integrity and overall fire system performance. Update hydraulic models for the properties of the new foam and verify that proportioners, pumps and discharge devices operate within their required ranges. |
| Operations | Staged cleaning to minimise downtime, with work sequenced by zone for large or distributed networks such as tank farms, jetties, pump houses and underground systems. PFAS wastes contained and disposed of as TIW through a licensed TIWC (Section 5.4). |
| Asset management | Test reports, SDS or technical specifications for the foam on site kept on hand (Section 6.1). PFAS foam inventory tracked, replacement campaigns scheduled, and asset registers updated with foam status and cleaning records, including the method used for each system cleaned to ALARP. |
Large terminals and high-hazard sites often need a transition plan that runs across more than one maintenance cycle: priority systems identified early, staged cleaning and commissioning, procurement and qualification of the new concentrate, and verification of system performance. Phasing the work reduces operational disruption, spreads capital expenditure and allows technical decisions to be validated step by step.
The position in Singapore is now settled for the three listed PFAS groups. Foam above the Table 1 thresholds can no longer be imported or used, training foam included. Legacy systems are cleaned to the thresholds or to ALARP using the Section 5.2 methods, then sampled after a month of residence. Replacement foam is accepted only after its suitability in the existing system has been confirmed and its performance verified. The long-chain PFCA prohibition from 16 December 2026 is the next date to plan against.
Notes
- National Environment Agency and Oil and Petrochemical Industry Technical & Safety Committee Working Group, Industry guideline on the phase out of PFAS containing firefighting foams, Version 02, 27 March 2026, Sections 3.1, 3.2, 4.1, 4.2, 5.1 to 5.4, 6.1 to 6.3. Link. ↑
- National Environment Agency and Oil and Petrochemical Industry Technical & Safety Committee Working Group, Industry guideline on the phase out of PFAS containing firefighting foams, Version 01, 12 November 2025, Section 5.3. Link. ↑
- National Environment Agency, Phase out of fire-fighting foams containing PFAS chemicals listed under the Stockholm Convention, circular NEA/HS/6.6, 15 March 2024, paragraphs 2 and 3. Link. ↑
- National Environment Agency, Listing of chemicals under the Stockholm and Rotterdam Conventions, circular, 23 September 2022. Link. ↑
- National Environment Agency, Updates on the phase out of chlorpyrifos, MCCPs (chlorination levels ≥ 45% chlorine by weight) and LC-PFCAs under the Stockholm Convention, circular NEA/HS/6.6/SC02, 26 January 2026. Link. ↑
- National Environment Agency, Table 1: List of controlled hazardous substances (hazardous substances listed in the 2nd Schedule of the EPMA), list updated as of 31 December 2025. Link. ↑
- Secretariat of the Stockholm Convention, The new POPs under the Stockholm Convention, decision SC-12/12. Link. ↑
- United Nations, Stockholm Convention on Persistent Organic Pollutants: amendments to Annex A, depositary notification C.N.672.2025.TREATIES-XXVII.15, 16 December 2025. Link. ↑
