Additive Transition Guide

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Due to a lack of sufficient stock, due to the sudden production shutdown of an additive manufacturer, fire extinguisher manufacturers cannot guarantee optimal maintainability of certain extinguishers.

The attached guide relates to manufacturers' recommendations for substitutions, and failing that, to the replacement of the extinguishers affected by the shortages.

The NF S61-919 standard, linked to the APSAD R4 standard and the NF-Extincteurs standard (French regulation), specifies that maintenance of portable fire extinguishers is not accepted when "spare parts or agents are no longer available" (Article 6).

The maximum authorized time between two maintenance sessions does not allow for the postponement of action beyond two months.

Contrary to this certification, LA PROTECTION INCENDIE aims to promote the maintainability of fire extinguishers according to the NF Services certification.

LEGAL and TECHNICAL BASIS

The sale and use of fire extinguishers containing PFAS of type "C6" remains possible indefinitely.

A PFAS is said to be of type "C6" when 6 Carbon atoms are directly linked to Fluorine atoms.

The additives BIOVERSAL, CAPSTONE 1430, BSX 233, SC-6 and EX-1, derived from Capstone A & B products, all contain a concentration of "C6" type PFAS potentially greater than 25 ppb.

European Commission Regulation 2020/784 of April 8 does not concern PFAS of type "C6".

European Commission Regulation 2024/2462 of 19 September 2024 applies to "C6" PFAS for fire and rescue operations, training, certification testing, and water bombing aircraft. It does not apply to portable fire extinguishers, wheeled fire extinguishers, or fixed extinguishing systems with contained emissions.

Therefore, the regulations do not justify a break in the additives allowing recharging.

In view of the current regulations, a ban is unlikely by 2030.

However, the financial risks in the future and the resale of additive manufacturers will favor an early transition to other fluoride-free products, with long-term damages that have not been assessed.

PFAS remain globally present and the absence of PFAS does not mean the absence of risk

• The paint, coatings, and rubbers on fire extinguishers likely contain PFAS.
  
  
• Substitute additives contain, for example, sulfuric acid, which is directly linked to bodily risks and the absence of release into the environment (INRS - FicheTox_30.pdf).
  
  

Can a manufacturer stop supplying an additive early?

Subject to compliance with European and French regulations relating to the abuse of a dominant position:

SYFEX - Union affiliated with the FFMI (Position note of September 8, 2021)
"There is no regulation requiring the manufacturer or supplier of professional products (covered by standard EN3-7) to provide information on the duration of supply of parts or to supply parts for a specific period."

The shift to a substitute item or process must not create a disproportionate commercial imbalance between qualified companies.

If in doubt, please send your information to abuse@ .fr

A risky situation for French and European industry

Manufacturer DESAUTEL has been anticipating the additive transition for several years. No disruption in maintainability is expected.


Manufacturer ROT has referenced a second supplier of emulsifier to ensure its sustainability and has a safety stock. A kit will then remain necessary for maintenance.


Other manufacturers, previously linked to the INCENDIN group of the STRACO fund (Burnguard / Orchidee / Uniteq / Ruhl / Prophos / Ecochem), offer limited visibility on the maintainability of their extinguishers beyond 2025.

Manufacturers have the ability to certify a fluorinated substitute product until April 10, 2026.

Transition kits for fluorinated to fluorine-free extinguishers are gradually being introduced to limit the need for maintenance-free equipment and to ensure that the choice of locally produced equipment remains advantageous.


During the previous technical development, stocks of fluorinated additives "PFOA" of type "C8" had been sufficient to last until the certification of substitute products.


This time, for short-term gain, this technological change favors the early obsolescence of equipment. This will impact the export/import economic balance and therefore the medium-term valuation of the sector.

Sources:
Composition “Capstone A”: https://pubchem.ncbi.nlm.nih.gov/compound/138394285
Composition “Capstone B”: https://pubchem.ncbi.nlm.nih.gov/compound/118691

Regulations not applicable to the fire extinguisher:
Regulation 2020/784: https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX%3A32020R0784&qid=1730383842787
Regulation 2024/2462: https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=OJ:L_202402462