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New Zealand’s Environmental Protection Authority (EPA) has confirmed that the transition period for fluorotelomer-based firefighting foams will end on 3 December 2025. After this date, C6 fluorotelomer foams can only be used with EPA’s explicit approval and must meet strict purity and usage standards outlined in the Fire Fighting Chemicals Group Standard 2021 (HSR002573).

Key Changes

• C6 fluorotelomer foams will require prior permission for continued use in firefighting systems. Import and manufacture will remain permitted if they comply with group standards and purity requirements.

• All applications for continued use must be submitted to the EPA as soon as possible.

No Extension for Legacy PFAS Foams

There will be no extension for legacy PFAS foams which are classified as persistent organic pollutants (POPs). Their use in any system ends completely on 3 December 2025, following the earlier phase-out of uncontained uses in December 2022.

Background

Since 2020, New Zealand has been phasing out firefighting foams containing PFAS due to their persistence in the environment and potential health risks. The 2021 Fire Fighting Chemicals Group Standard regulates both legacy and C6-based foams by setting requirements for labelling, disposal, and transitioning to safer alternatives.

For more information, see the official group standard here.

New Zealand’s Environmental Protection Authority (EPA) has set 30 April 2025 as the final deadline for importers, manufacturers, and suppliers to comply with updated labelling, Safety Data Sheet (SDS), and packaging notices. These updates align with the seventh revised edition of the Globally Harmonised System for Classification and Labelling of Chemicals (GHS 7) and introduce new regulatory requirements for hazardous substances under the Hazardous Substances Notices. When the transition period ends, full compliance with the new standards will be mandatory.

Background

In April 2021, EPA updated the regulations for:

• Labelling of hazardous substances

• Safety Data Sheets (SDSs)

• Packaging compliance

A four-year transition period was provided for industry stakeholders to adopt the updated requirements. The transition ends on 30 April 2025, when full compliance becomes mandatory.

Who Must Comply

Importers and Manufacturers

As of 30 April 2025, all hazardous substances must meet the following updated compliance standards:

• Hazardous Substances (Labelling Notice) 2017 – Updated 30 April 2021

• Hazardous Substances (Safety Data Sheets Notice) 2017 – Updated 30 April 2021

• Hazardous Substances (Packaging Notice) 2017 – Updated 30 April 2021

Suppliers

• All hazardous substances in the supply chain must comply with the updated GHS 7 standards.

• There will be no additional grace period beyond 30 April 2025 for stock-in-trade.

Compliance Requirements

Labelling and SDS Compliance

• Labels and SDSs that are already compliant with GHS 5 are likely to meet GHS 7 standards.

• Reclassification will be required for substances with desensitised explosive and flammable gas classifications due to classification framework changes.

• Minor updates to precautionary statements may be needed.

If a label or SDS does not comply with GHS 5, updates will be needed before the deadline.

Packaging Compliance

• Full compliance with the 2021 Packaging Notice is required by 30 April 2025,.

• The updated regulations align with international packaging standards for:

  • Transport of dangerous goods

  • Child-resistant packaging

Alternative Compliance Provisions

The updated notices allow for alternative compliance using standards from Australia, the U.S., Canada, or the EU, if they meet the following conditions:

• New Zealand-specific labelling and SDS details are added.

• Packaging meets the child-resistant and permanent identification standards of international jurisdictions.

Record Keeping Requirements

Importers and manufacturers using alternative compliance provisions must:

• Document their compliance strategy and the jurisdiction they are following.

• Maintain records for at least two years after the substance is no longer supplied.

Next Steps

• Review your hazardous substance compliance with GHS 7.

• Update labels, SDSs, and packaging before 30 April 2025.

• Consult EPA notices for complete regulatory details.