240522 Coalition PFAS NDAA HASC SASCDRAFT 5 22


May 22, 2024


Dear Chairmen Reed and Rogers and Ranking Members Wicker and Smith:

The undersigned associations strongly urge you not to include provisions in the National Defense Authorization Act for Fiscal Year 2025 (FY 25 NDAA) that would circumvent the existing legal and regulatory processes for per- and polyfluoroalkyl substances (PFAS).

Last year, we sent a letter to your Committees that identified concerns about issues such as procurement, disposal and destruction, and effluent limitation guidelines that Congress should not address as part of the NDAA legislative process. Rather, we support accelerating cleanup of PFAS in the environment and encourage Congress to focus on the technology innovation, collaboration, and other solutions needed to advance this important outcome.

The Department of Defense released a report in August 2023 on the critical uses of PFAS that impact the national security supply chain. Our open letter on this analysis underscores that all PFAS are not the same and that limitations on uses in many sectors and products could unnecessarily disrupt such supply chains. Fluorochemistries, including PFAS, deliver irreplaceable properties for essential sectors across the broad economy that Americans use every day. 

Our coalition has also provided input to the Senate Committee on Environment and Public Works for a recent hearing on the CERCLA hazardous substance designation of PFOA and PFOS. We believe that CERCLA is the wrong policy tool, and that EPA should use existing alternative authorities to drive cleanup. The Committees should use their oversight responsibilities to ensure that EPA does so.

We urge you to oppose amendments and language in the FY 25 NDAA that would circumvent established, science-based regulatory processes, including provisions that would ban or restrict procurement and incineration and mandate EPA effluent guidelines.


Aerospace Industries Association

Alliance for Automotive Innovation

Alliance for Chemical Distribution

American Apparel & Footwear Association

American Chemistry Association

American Coatings Association

American Forest & Paper Association

American Petroleum Institute

Fluid Sealing Association

INDA, Association of the Nonwoven Fabrics Industry

National Association for Surface Finishing

National Electrical Manufacturers Association

National Council of Textile Organizations

National Oilseed Processors Association

Plastics Industry Association

PRINTING United Alliance

TRSA - The Linen, Uniform and Facility Services Association

U.S. Chamber of Commerce

240522 Coalition PFAS NDAA HASC SASCDRAFT 5 22