As we reported in our December 4, 2023, blog, the United States Department of Defense (DoD) stated clearly that banning all per- and polyfluoroalkyl substances (PFAS) would undermine US military readiness. A July 2025 report from the DoD provides an update and approach to phasing out PFAS for military uses, but it will take years to achieve this.
The critical role of PFAS in military operations points to the complexity involved when removing PFAS from manufacturing and (potentially) from the environment. PFAS are used in thousands of products, including aerospace, construction, energy (including green energy), food processing, cosmetics, and much more.
DoD Report on PFAS
The DoD Report is titled “Update on Critical Per- and Polyfluoroalkyl Substance Uses.” In the report, the DoD presents their plan to: “(1) coordinate with relevant agencies, industry, and academia to research alternatives to mission critical PFAS uses, and (2) scientifically evaluate and review key technical standards for PFAS critical materials to ensure that the standards are effective, accurately represent the required performance, and ensure that viable PFAS-free alternatives are not artificially excluded.”
The DoD report states that PFAS needed for the production, performance, and sustainment of DoD systems are critical to the national security of the United States. They also state that an increasing number of “mission-critical PFAS and PFAS-enabled products are at risk for obsolescence due to market phase-outs, manufacturer liability, complex geopolitical escalation dynamics, and regulatory complexity, uncertainty, and inconsistency, which impact all levels of the PFAS supply chain.”
According to one report, military applications for PFAS include “aircraft, munitions, missile systems, protective clothing, energy and battery storage, electronics, refrigerants, fire suppression and firefighting foams, sealants, cleaning fluids, and waterproofing.”
The US DoD states that the use of PFAS is “needed for the production, performance, and sustainment of DoD systems…”
PFAS are Critical for DoD but Risky to Produce
According to the report, “To mitigate mission impact, the DoD must implement a dual strategy to safeguard the continued domestic availability of PFAS critical for defense over the next 10 years or longer through regulatory and industry engagement, while proactively seeking PFAS alternatives which meet performance specifications and applicable regulatory thresholds for new or existing chemicals” (emphasis added).
While the DoD (and its contractors) will require PFAS for the foreseeable future, the liability associated with PFAS is continuing to lead to litigation. This is affecting not just the manufacturers of PFAS, but those using the products, consumer goods, and those making certain claims about products being natural, healthy, or non-toxic.
Manufacturers of PFAS are facing billions of dollars in liability. The most recent PFAS settlement in New Jersey is valued at $2 billion. As we reported in our June 18, 2024, blog, one lawyer said there isn’t enough gold in Fort Knox to cover the damages and settlements associated with PFAS. See that June blog for a list of some of the significant PFAS settlements.
In the report, the DoD states, “The diminishing manufacturing sources and material shortages (DMSMS) pose the most significant risks to access critical-use PFAS until viable alternatives are developed and qualified, which can take anywhere from 5-20+ years.”
With companies phasing out PFAS production and the DoD stating the necessity of PFAS for military readiness, “something” has got to give. What that something is, is yet to be seen.
To read the DoD report in its entirety, click here.
For more information, see our PFAS Resource page and our Litigation Support/Expert Services page.
Environmental Advisors
Dragun Corporation has assisted the regulated community with environmental compliance, assessment/remediation, and litigation support since 1988. If you need assistance with an environmental matter, please contact Jeffrey Bolin, M.S., CHMM, at 248-932-0228, Ext. 125.
Alan Hahn drafted this blog. Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management. He has worked in environmental management for more than 45 years. He has written hundreds of blogs and articles. His published work includes Michigan Lawyers Weekly, Detroiter, Michigan Forward, GreenStone Partners, Manure Manager Magazine, Progressive Dairy, and HazMat Magazine.
Jeffrey Bolin, M.S., reviewed this blog. Jeff is a partner and senior scientist at Dragun Corporation. He is a published author, a frequent speaker, and an expert witness. His expertise in environmental due diligence, PFAS, vapor intrusion, and site assessments has led to projects in the US, Canada, and overseas. See Jeff’s Bio.
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