The recently announced stockpile represents significant opportunities, but much of that depends on unresolved details that companies must continue to monitor.

By Charles E. Carpenter, Joshua W. Marnitz, and Austin J. Pierce

Key Points:

  • The $12 billion stockpile has been characterized as similar to other US strategic “reserves” but has a distinct setup with both public and private funding.
  • Questions remain on how the stockpile will take into account US policy priorities and function in practice.

Introduction

On

  • Any product in excess of the 50 ppm total fluorine threshold is presumed to contain “intentionally added” PFAS and subject to the rule unless this presumption is rebutted with “credible evidence.”
  • Washington State’s adoption of a total fluorine threshold breaks from other states that previously adopted total organic fluorine thresholds,