08/15/2025

DOD Delays AFFF Ban by One More Year, Citing Replacement Hurdles

Inside EPA | Pavithra Rajesh | August 11, 2025

DOD Delays AFFF Ban by One More Year, Citing Replacement Hurdles

The Department of Defense (DOD) has formally extended its deadline to end the use of aqueous film-forming foam (AFFF), which contains PFAS, by one year to Oct. 1, 2026, utilizing the second of two year-long extensions and arguing it needs more time to successfully transition to PFAS-free alternatives.

“I have determined that the second waiver of the prohibition with a statutory deadline of October 1, 2026 is necessary to sustain the operational availability of sufficient firefighting systems to ensure the protection of life and safety at Department of Defense (DoD) installations and during military operations,” DOD Secretary Pete Hegseth says in a July 31 letter, cleared for publication Aug. 1, to the Committee on Armed Services.

“Although the Department has made significant progress in transitioning away from AFFF use, it needs additional time to ensure a methodical and safe transition of approximately 1,000 facilities and over 6,000 mobile assets. I thus certify that the second one-year section 322(e) waiver is necessary for the protection of life and safety,” Hegseth continues.

The fiscal year 2020 National Defense Authorization Act (NDAA) required DOD to stop using AFFF, which contains per- and polyfluoroalkyl substances (PFAS), by Oct. 1, 2024. But the law allows DOD to invoke two one-year extensions -- with a latest deadline of Oct. 1, 2026 -- through a waiver process.

Last year, DOD invoked the first waiver, and now the second waiver gives DOD its latest deadline in 2026 for transitioning facilities and mobile assets from AFFF to fluorine-free foam (F3), a process which the departments calls “complex, time-consuming, and supply-constrained.”

“I certify that -- despite the [Military Departments’ (MILDEPs)] progress in advancing these tasks -- F3 solutions that meet the military specification issued pursuant to subsection 322(a) are not yet available for all installations and equipment (including where such solutions may be incompatible with certain tactical assets), and the MILDEPs require additional time, beyond October 1, 2025, to procure, install, and/or modify systems to transition from AFFF worldwide, while maintaining mission readiness and safety standards,” Hegseth says.

The move was expected, since earlier this year, as required by the NDAA, DOD officials briefed lawmakers on their plans to invoke the second extension, citing various difficulties such as the large number of assets that need to transition.

The slides explained that DOD has made “significant progress” toward meeting the FY20 NDAA phase-out requirement, but that challenges and factors prevent the military from meeting the 2025 extended deadline.

‘Working Aggressively’

In the letter, DOD reiterates that it published a military specification (MILSPEC) for F3 in January 2023 and since then has qualified six F3 products that are available for purchase.

“The Military Departments (MILDEPs) have begun to acquire MILSPEC-compliant F3 products and are working aggressively to remove AFFF from mobile assets and facilities, and to replace those AFFF stocks with F3 or other fluorine-free fire suppressant technologies,” Hegseth says.

The letter adds, “To ensure a successful transition, the MILDEPs developed comprehensive AFFF replacement plans and are updating the plans quarterly.”

“The transition schedules consider available resources, the number and location of each AFFF-using facility and asset, and the required system modifications needed for compatibility with the selected fire suppression system alternative. Additionally, the Department is evaluating the availability of other fluorine-free firefighting agents that can be used in certain tactical firefighting equipment currently incompatible with the available MILSPEC-qualified F3 agents.”

According to the briefing slides, DOD has spent more than $62 million in research, development, test and evaluation (RDT&E) to replace firefighting agents between fiscal year 2017 and FY24, and it plans to expend another $3 million this year.

As far as future efforts in RDT&E, DOD said it plans to develop new F3 formulas that can be used with saltwater and in extreme operational conditions, and to demonstrate and validate new formulations to improve firefighting capabilities beyond the current F3 products.