A Regulatory Outlook on PFAS and High-GWP Clean Agents in Fire Suppression

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The global regulatory landscape around fire suppression chemicals is shifting rapidly. What was once standard practice, installing systems based on widely accepted agents like FK-5-1-12 and HFC-227ea, is now underscrutiny due to environmental and climate concerns.

Agents such as FK-5-1-12 and HFC-227ea (commercially known as Novec™ 1230and FM-200™ respectively) are facing mounting regulatory pressure from multiple fronts. With frameworks like the Kigali Amendment, REACH, and national laws such as the EU F-Gas Regulation and the U.S. AIM Act, phase-down and phase-out timelines are already in motion. Adding to this momentum, 3M has announced it will cease production of Novec™ 1230 by the end of 2025.

These developments mark a fundamental change in how fire suppressionagents are evaluated, not just for their immediate performance, but for their environmental impact and long-term viability.

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Key Regulatory Drivers

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Kigali Amendment to the Montreal Protocol

Adopted in 2016 and entered into force in 2019, the Kigali Amendment targets hydrofluorocarbons (HFCs) due to their high GWP. Countries agreed to gradually reduce the production and consumption of HFCs by more than 80% over the next 30years. Developed countries, including the EU and U.S., began reductions in 2019, while developing countries will follow different schedules starting in 2024 or 2028. Full implementation could prevent up to 0.5°C of global warming by 2100.

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REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)

Managed by the European Chemicals Agency (ECHA), REACH aims to improve the protection of human health and the environment from risks posed by chemicals. Under this framework, PFAS substances like FK-5-1-12 are under evaluation for potential restriction due to their persistence and bioaccumulative nature. Abroad PFAS restriction proposal is currently under review.

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EU F-Gas Regulation

Regulation (EU) No 517/2014 controls fluorinated greenhouse gases and imposes a quota system and phasedown schedule. A 2024 revision proposes stricter bans: new installations using HFC-227ea (a type of F-gas, also known as FM-200), may be prohibited as early as 2026, with a complete phase-out by 2032. The regulation supports the EU’s broader goal of climate neutrality by 2050.

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U.S. AIM Act (American Innovation and Manufacturing Act)

Enacted in 2020, the AIM Act authorizes the EPA to phase down HFC production and consumption by 85% by 2036. It includes allowance trading programs and permits the agency to restrict specific substances by sector. HFC-227ea is among the substances impacted, with sector-based bans and restrictions expected.

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Why This Matters to Specifiers and Facility Owners

While these agents are still widely available, their future viability is increasingly uncertain. Projects specified with FK-5-1-12 or HFC-227ea today may face:

• Unclear total cost of ownership, as availability declines and handling costs rise
• Incompatibility with future ESG and  procurement frameworks
• Installation bans or retrofitting pressure  within a few years
• Complex and costly end-of-life procedures under PFAS and GHG (greenhouse gases) disposal rules

These challenges make it essential to look beyond legacy systems and start evaluating solutions built for long-term compliance and environmental responsibility.

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A Path Forward: Sustainable Agents Without the Trade-Offs

Considering these shifts, some organizations are already migrating to PFAS-free alternatives such as aerosol-based fire suppression systems. Unlike gas-based agents, condensed aerosol systems do not rely on pressurized cylinders, fluorinated chemicals, or complex pipe networks.

DSPA aerosol systems, for example, use a solid compound that produces a dense cloud of fire-suppressing particles when activated. The technology offers:

• Zero GWP and zero ODP
• No PFAS
• Long maintenance-free lifespans (up to 15 years)
• Scalable design for both new builds and retrofits
• Compact format for use in distributed architectures, like:
• • Cable tunnels
  • BESS rooms
  • Electrical cabinets

As pressure mounts to align fire suppression with sustainability goals, condensed aerosol represents a pragmatic, proven option.

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Conclusion

Sustainability can no longer be a secondary consideration in system design. As regulations evolve and legacy chemicals lose support, it’s time to future-proof fire suppression with agents that not only protect lives and assets, but also the environment.

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