Strengthening American Competitiveness Requires an Effective PFAS Management Policy
Our modern way of life is made possible by the industrial advances enabled by purpose-built chemistries, such as many PFAS compounds. From life-saving medical devices to the semiconductor-driven digital society to the aerospace technologies critical to military readiness, PFAS play an essential role in American innovation, national security, and economic competitiveness.
Not all PFAS are the same. Losing access to PFAS due to overly broad, class-based regulations threatens critical domestic industries that directly support over 6 million jobs and contribute more than $1 trillion annually to GDP. Such an approach would harm American competitiveness, allowing other global competitors such as China to fill the gap.
Managing PFAS effectively requires policies that recognize the myriad unique properties of these compounds. Many PFAS are highly heat, oil, and water resistant and serve critical functions in key industries that drive American competitiveness and innovation. By utilizing a risk-based approach to guide regulatory efforts, the U.S. Environmental Protection Agency (EPA) can ensure that managing PFAS compounds and uses becomes more effective, resource-efficient, and supportive of critical industries.
During President Trump’s first term, his Administration launched the PFAS Action Plan – the first cross-agency plan in history to address emerging compounds of concern. The Trump Administration and Congress now have a pivotal opportunity to build on this legacy and put America on a path to manage PFAS effectively and responsibly, while enabling and accelerating continued innovation.
This moment demands strong federal leadership from the EPA and Congress to establish a uniform, risk-based policy that includes:
Adopting a Risk-Based Framework for Categorizing Commercially Active Subgroupings of PFAS Compounds that avoids repetitive scrutiny of substances that have already been evaluated and approved. This approach will allow federal and state regulators to focus assessment efforts on a finite set of chemistries.
Standardizing the Federal Definition of PFAS, by focusing first on commercially active PFAS compounds with safety profiles of significant concern, will provide regulatory clarity for industry and regulators so they can prioritize which compounds may require further assessment, and identify those compounds for which alternatives should be considered.
Issuing Federal Guidance on Contamination Remediation will facilitate the effective identification and remediation of sites contaminated with PFAS identified as persistent, bioaccumulative, and toxic (PBT).
Permitting Essential Use Considerations will prevent overly broad definitions of PFAS and related restrictions from inadvertently limiting uses of PFAS compounds in applications that serve critical functions in modern society and where suitable alternatives do not exist.
Streamlining the Process for Rapid Evaluation and Approval of Effective Alternatives, modeled on the successful SNAP Program under Title VI of the Clean Air Act that keeps America innovating.
Simplifying the TSCA Section 8(a)(7) Reporting Rule for purposes of state and federal efficiency, paving the way for a more practical and manageable reporting system for commercially active PFAS and PFAS-containing products.
Together, these actions will strengthen American competitiveness while protecting consumers and the environment.