The U.S. Department of Defense (DOD) has published a July 2025 report entitled Update on Critical Per- and Polyfluoroalkyl Substance Uses. House Report 118-121, which accompanied the 2024 DOD appropriations bill (H.R. 4365), requested the Secretary of Defense “to submit a report to the congressional defense committees to coordinate with relevant agencies, industries, and academia to research alternatives to defense critical uses of per- and polyfluoroalkyl substances (PFAS).” The report presents DOD’s plan to research alternatives to mission critical PFAS uses and 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 conclusion of the report notes that “[t]here remains significant uncertainty regarding the presence of PFAS in products that make up a complex supply chain.” According to the report, “[]the difficulties in dissecting the defense industrial base supply chain and supply chain dependencies, in addition to the lack of transparency in chemical and material content data, preclude gathering comprehensive data on all critical PFAS uses.” The report states that the collective international, federal, and state regulatory actions to manage the environmental impacts of PFAS and identify and eliminate PFAS from the market, and the resulting market responses, pose increasing risks to DOD operations due to possible product obsolescence and reformulations. These issues are exacerbated by the variability in how the regulatory authorities define PFAS. To overcome the challenges of using broad, structural-based definitions for PFAS, the report suggests that “a risk-based approach to defining PFAS that considers the chemical/physical properties and exposure pathways” be considered.

According to the report, PFAS are critical to the national security of the United States, and there is a need “to ensure that the dwindling number of domestic PFAS manufacturers remain able to and capable of providing PFAS critical to national security, including those producing the feedstock minerals (fluorspar and possibly others) and chemicals and all the intermediate chemicals leading to the manufacture of fluoropolymers, fluorinated gases, and other critical fluorochemicals broadly defined as PFAS.” The alternative would be to source mission critical PFAS from China and other foreign entities of concern, “defeating the purpose of establishing domestic supply chains for key sectors such as semiconductors, batteries, and energetics.” The conclusion states that to mitigate obsolescence risks and mission impacts, DOD “must implement a strategy to ensure short term domestic availability of the end-to-end PFAS supply chain critical for defense (e.g. supporting the manufacturing base to develop better abatement technologies and reduce emissions) while proactively seeking long term PFAS alternatives which meet both performance specifications and regulatory thresholds where possible.”