Additive Transition Guide

DOWNLOAD THE GUIDE HERE

https://www.lpi-incendie.fr/img/cms/GUIDE TRANSITION ADDITIF - 2025 - v3.pdf

In view of the shortage highlighted by some manufacturers, the attached guide is linked to their recommendations for substitutions, and failing that, to the replacement of the extinguishers concerned.

The NF S61-919 standard specifies that maintenance of portable fire extinguishers is not accepted when "spare parts or agents are no longer available" (Article 6). The maximum time allowed between two maintenance operations does not allow actions to be postponed beyond 2 months.

FIRE PROTECTION aims to promote the maintainability of fire extinguishers according to NF Services certification.

LEGAL and TECHNICAL BASIS

The use of fire extinguishers with PFAS type "C6" remains possible until December 31, 2030

Fire extinguishers can be kept during the replacement of the fluorinated additive with a fluorine-free additive.
The residual concentration following cleaning will necessarily be less than 0.02 mg/L (legal limit: 50 mg/L)

Regulation 2025/1988 of the European Commission of 2 October 2025 is the only text that concerns portable fire extinguishers in circulation

Compared to the previous regulation (2024/2462), This text has the following consequences:

- Increase the PFAS usage threshold by 40. The The limit was set at 25 ppb (0.025 mg/L). It is now 1 mg/L.

- Extend the duration of use by approximately 1 year for the training, coaching and certifications.

- Mathematically favor imported devices and impact the environment considering that a volume diluted with drinking water is less dangerous than the same volume which will never be mixed with water drinkable.

+ Finally define processing obligations (despite the threshold of 1 mg/L is far too low, and that the date of October 23, 2026 leaves run a right to pollute)
It is irresponsible that the threshold of 0.025 mg/L was not left.

+ Avoids the planned obsolescence of the containers of the previous text by accepting that emptied containers may contain a product of substitution

PFAS concentration in portable fire extinguishers

A PFAS is said to be of type "C6" when 6 atoms of Carbon are directly bonded 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 PFAS of type "C6" greater than 25 ppb (0.025 mg/L)

- In premix: Between 0.025 mg/L and 0.24 mg/L (between 25 and 240 ppb): Reauthorized thanks to the October 2025 regulation.

- In separate dose not mixed with water: More than 1 mg/L (over 1000 ppb): Banned from December 31, 2030.

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

• Paintings, rubbers, surface treatment. PFAS remain present on the fire extinguishers.

• THE substitute additives have unevaluated long-term damage

Can a manufacturer stop production early? provide an additive?

Subject to compliance with European regulations and French cases related to abuse of dominant position:

SYFEX - Union affiliated with the FFMI (Position note of September 8, 2021)
"No regulation imposes on the manufacturer or supplier of products professionals (covered by standard EN3-7) nor to inform of the duration of supply of parts or to supply parts for a period determined."

The referral to a substitute article or process does not must not create a disproportionate trade imbalance between qualified companies.

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

An industry in transition

Manufacturer DESAUTEL anticipated the additive transition for several years. No break in maintainability is planned.

The manufacturer ROT has referenced a second supplier of emulsifiers to guarantee its sustainability. It has a safety stock.

Other manufacturers are moving towards a conversion kit.

New European regulations are hoped for to further limit discharges into the environment and the import of products pollutants impacting our industry.

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

Regulation 2025/1988: https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:32025R1988