On 17 July 2025 the US Department of Defense cleared the document “Update on Critical PFAS Uses” for open publication.

DoD Seal

Background
The U.S. Department of Defense (DoD) released an update in response to House Report 118-121 (H.R. 4365, FY2024 DoD Appropriations Bill) directing a coordinated effort with agencies, industry, and academia to research alternatives for mission-critical PFAS uses. The plan also calls for a scientific evaluation of technical standards to ensure PFAS-free alternatives are not unfairly excluded, and recommends a National Academies study on essential uses and substitutes.

Scope of the Report
Prepared by the Chemical and Material Risk Management Program (CMRMP) under OASD(EI&E), the report outlines a phased approach to:

  1. Prioritise R&D for alternatives to mission-critical PFAS.
  2. Evaluate and review technical standards for PFAS materials to confirm they accurately reflect performance needs and allow viable PFAS-free options.

The update builds on the 2023 DoD PFAS Critical Use Report, presenting newly identified mission-critical uses in the DoD supply chain. Due to limited visibility into full product compositions and manufacturing processes, the data is not comprehensive.

Key Findings

  • PFAS uses in the DoD supply chain remain essential to U.S. national security due to both military and civil-military applications.
  • Regulatory changes at international, federal, and state levels create risks of product obsolescence, reformulation, and supply disruptions.
  • Inconsistent PFAS definitions across agencies complicate regulation and supply chain stability.
  • Structural-based definitions do not address toxicity or hazard profiles; a risk-based definition considering chemical/physical properties and toxicology is recommended.
  • Loss of domestic PFAS production capacity could force reliance on foreign suppliers, risking critical sectors like semiconductors, batteries, and energetics.

Strategic Needs
To address obsolescence risks and ensure supply chain security, the DoD must:

  • Maintain short-term domestic PFAS supply by supporting manufacturing, improving abatement technologies, and reducing emissions.
  • Pursue long-term PFAS alternatives that meet both performance and regulatory requirements.
  • Strengthen visibility into supply chain dependencies to safeguard mission readiness.

Conclusion

There remains significant uncertainty regarding the presence of PFAS in products that make up a complex supply chain.
PFAS are critical to the national security of the United States, not because they are used exclusively in military applications (although some are), but also because of the civil-military commonality and the potentially broad impact on the civilian marketplace.
While PFAS remain critical for defense operations, regulatory uncertainty, inconsistent definitions, and supply vulnerabilities necessitate proactive planning. Balancing short-term supply security with long-term transition to safe, effective alternatives is essential to U.S. national security interests.

Source: U. S. Department of Defense, Update on Critical Per- and Polyfluoroalkyl Substance Uses (July 2025).

For resources, case studies, and industry updates on the proposed PFAS restriction, visit the ESA’s new PFAS Information Hub.

Sandy Van den Broeck,
ESG Director, ESA