Additive Transition Guide

DOWNLOAD THE GUIDE HERE

GUIDE TRANSITION PFAS - v5.pdf

Faced with the break highlighted by manufacturers, the guide is linked to their recommendations, and failing that, to the replacement of the fire extinguishers concerned.

According to the NF S61-919 standard, maintenance of portable fire extinguishers is not accepted when "spare parts or agents are no longer available" (Article 6).
The applicability of this standard depends on the policy of maintenance companies (and their level of certification), and on the insurability of the protected assets if a Q4 attestation is required.

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

LEGAL and TECHNICAL QUESTIONS

Can my maintenance company sell me a fire extinguisher containing fluorine after October 23, 2026?

No.

Can my maintenance company perform:
- A preventive maintenance service with a screw-in or floating dose containing PFAS between October 23, 2026 and December 31, 2030?

Yes. The maintenance company is, within the framework of the maintenance service, a " downstream user ".

Its service helps to limit the obsolescence of fire extinguishers and to allow their optimal use until December 31, 2030.

The company must build up these stocks by October 23, 2026, to carry out the maintenance work that will help smooth out the budget for these clients. The invoice will, for example, highlight a single line item for services including all parts.

Empirically, in view of the cost of the CONVERSION KITS, and in view of the inflation of additives (+80% in 5 years), it remains economically logical to carry out maintenance in 2026 or even 2027, rather than replacing a fire extinguisher after 5 years, which will itself be more expensive to maintain on its 5th anniversary.

- A preventive maintenance service involving mixing concentrated additive with water between October 23, 2026 and December 31, 2030?

No. This mixture induces the production of a new fluoride solution.

- A corrective maintenance service for recharging a used fire extinguisher containing PFAS, between October 23, 2026 and December 31, 2030?

No. The residual concentration in the fire extinguisher will remain above 1 mg/L despite emptying the tank.

Any remaining product, even diluted, must not be released into the environment.

The concentration of PFAS in a fired fire extinguisher is between 150 and 2500 mg/L.

Can a manufacturer, La Protection Incendie, or a maintenance company give or sell a dose of additive to a third party so that the latter can carry out maintenance beyond October 23, 2026?

No. The donor or seller here is a "Distributor" who carries out a "Marketing".

The maintenance company must therefore build up its stock by agency by October 23, 2026. Building up a safety stock helps to facilitate a smooth and economical transition in the protected installations in order to smooth out budgets.

Is European Commission Regulation 2025/1988 of 2 October 2025 positive for the environment?

Yes and no.

Yes, because the ban on PFAS is a good thing, and because the text finally introduces a penalty for releases into the environment.

No, because there is no justification for extending the deadlines for uses other than fire extinguishers until 2035 (over 95% of emissions).

There is no proof that substitute products are ultimately less dangerous. The lack of clear communication from additive manufacturers ultimately contributes to environmental pollution.

Given the components of substitute products, French manufacturers are generalizing the use of separate-dose additives across their entire range to ensure the best possible recovery of the products without mixing them with clean water.

What are the trade names of additives containing PFAS?

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

The additives BIOVERSAL, ZEON, Valext LD, CAPSTONE 1430, BSX 233, SC-6 and EX-1, derived from Capstone A & B products, even in premix form, all contain a concentration of "C6" type PFAS well above 1 mg/L. (between 150 and 6000 mg/L).

Do PFAS remain present in so-called "fluoride-free" fire extinguishers?

Probably.

PFAS are still permitted for uses related to paint, rubber design and surface treatments.

What is the best treatment for these products?

This is a European issue, particularly regarding the control of PFAS levels in the air following incineration, including for household waste.

The maintenance company will transport the components to a dedicated and approved company (Eco Planet Recycling, Quality Environnement, etc.). They can then provide you with a processing certificate, or even a Tracking Slip from the TrackDechets platform.

Can a manufacturer prematurely stop supplying an additive?

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

SYFEX - Union affiliated with the FFMI (Position note of September 8, 2021)
"No regulation requires the manufacturer or supplier of professional products (covered by the EN3-7 standard) to inform customers of the duration of parts supply or to supply parts for a specific period."

The shift towards a substitute product or process must not create a disproportionate trade imbalance between qualified companies.

Ultimately, the sustainability of industrial sites beyond 2032 remains closely linked to the ability to promote an affordable transformation of fire extinguishers now.

Sources:

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

Regulation :

Regulation 2025/1988: https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:32025R1988 REACH Regulation
Exchanges with the INERIS institute
Exchanges with the Ministry - Directorate General for Risk Prevention