The bond that won't break

Three weeks ago, on the eighteenth of May, the Environmental Protection Agency proposed to walk back the first federal drinking-water limits this country ever set for  polyfluoroalkyl substances (PFAS). The agency moved to rescind the enforceable limits on four of the six compounds it had regulated only in 2024, and to give water systems two more years, for now that is until 2031. A standard that took thirty years to establish was clipped in an afternoon, with a comment window and a press release.

So what does and does not change? Because that  distinction is the whole point. It changes what we are required to measure. It changes the deadline on a page. It does not change a single molecule of PFAS in a single well. The carbon-fluorine bond doesn’t read the Federal Register, nor does it soften its position in response to a comment period. It will sit in the groundwater of a town in New Jersey or Minnesota or Bavaria long after the administration that rescinded the rule, the lawyers who argued it, and how they argued it have all passed into history. As I have repeatedly stated, nature is the ultimate arbiter. It doesn’t care what you think or believe, but it does respond to what we do. This rollback is the cleanest demonstration I have seen in years of the one thing this  arbiter never does. It does not negotiate.

This may be a story about PFAS. But PFAS is only an example. The real subject is the almost invisible decision that sits quietly, full of consequences, underneath every product ever made: what did you make it out of? That choice is a bet on the future, whether or not anyone treats it as one. And for most of the industrial era, we have been placing those bets while refusing to understand and recognise the odds.

The property that made it perfect made it permanent

PFAS earned their place in the world honestly. The carbon-fluorine bond is among the strongest in all of organic chemistry, and that strength is precisely what made these compounds miraculous. Nothing sticks to them, nothing soaks through them, nothing burns them, nothing wears them down. So we put them everywhere a surface needed to resist the world: the non-stick pan, the waterproof jacket, the grease-proof wrapper around the burger, the firefighting foam that smothered jet-fuel fires on a thousand runways and  flight decks, the etchants and coolants and photolithography chemistries that sit, even now, at the heart of every advanced semiconductor fabricated on Earth.

Consider the parallel that no one drawing up those bills of materials wanted to consider. The bond that resists everything also resists ending. The same indestructibility that made PFAS the perfect coating made it the perfect liability — a molecule engineered to never break down, doing exactly what it was engineered to do, in the blood of nearly every human being ever tested, in the rainwater falling on the most remote corners of the planet, in the soil under the farm and the aquifer under the town. The asset and the liability are not two things to be weighed against each other. They are the same molecule. That is the part that should keep a board awake. We did not get unlucky with PFAS. We got exactly what the chemistry promised. We simply declined to price the second half of the promise.

The bill, compounding

I have built and worked inside cost models for thirty-five years, and the lesson that has hardened into conviction is this: when you defer a real cost, you do not avoid it. You finance it. And a financed liability compounds.

Look at what is being called in now. In 2023, 3M agreed to pay public water systems to the tune of ten billion dollars to settle claims that its PFAS had contaminated American drinking water; DuPont, Chemours, and Corteva settled a parallel claim for approximately $1.2 billion. Those were the opening payments, not the closing ones. 

Since then the settlements have stacked: Tyco at seven hundred fifty million and BASF at three hundred sixteen million to public water systems; statewide deals with New Jersey alone running up to four hundred fifty million from 3M and eight hundred seventy-five million from the DuPont companies, each structured to pay out over twenty-five years — payment schedules that will outlast most of the executives who set them in motion. As of this June, more than fifteen thousand firefighting-foam cases sit in a single federal docket, fifteen state attorneys general have brought their own actions, and the personal-injury wave — the one that prices human illness rather than water treatment — is only beginning to break.

Watch what this does to the financial machinery itself. 3M, which announced it will exit all PFAS manufacturing by the end of 2025, now reports an adjusted sales figure that explicitly excludes its PFAS products, and has seen billions in operating cash flow consumed by litigation payments. The liability has not merely appeared on the balance sheet. It has rewritten the income statement and reorganised the strategy. A margin that was booked, quarter after quarter, for the better part of seventy years is being repaid, with interest, by people who in many cases were not born when the bet was placed. The compounding ran the entire time. It was simply running in a column no one was required to total.

Rolling back the rule does not retire the risk

Here is where the regulatory rollback stops being a complication for the argument and becomes the proof of it.

When an agency rescinds a drinking-water standard, a board could be forgiven for reading it as relief — a liability deferred, a compliance cost avoided, a problem moved off the desk. That reading is a misunderstanding of where the liability actually lives. Rescinding the standard removes the federal requirement to measure. It does not remove the PFAS from the water, the plaintiffs from the courthouse, or the molecule from the human body. The exposure does not leave the building with the rule that tracked it. It stays, growing, in a building where fewer people are now watching it. State limits remain. Tort liability remains, and tort liability has never required an EPA number to find a defendant. The anti-backsliding provisions of the Safe Drinking Water Act are already drawing the rollback toward litigation of its own. The risk did not shrink. It went quiet, which is a different and more dangerous condition.

I have made this argument before in the language of resilience and governance — that when an organization strips a risk from its vocabulary, it strips its own awareness, not the underlying exposure. PFAS is that argument rendered in a single chemical bond. You can stop saying the word. The bond persists in perfect indifference to whether you say it.

A view from inside the cleanroom

I spent years in and around the semiconductor industry, and I will say plainly what the industry knows and rarely volunteers: chip manufacturing is among the most PFAS- dependent activities on the planet. These compounds are woven through the etch and lithography and thermal-management chemistries that make a modern processor possible,  and there is, for a number of critical uses, no drop-in replacement waiting on a shelf. The industry's plea for "essential use" exemptions is not cynical. In several cases it is accurate.

But accuracy about the difficulty is not an argument for deferral. It is an argument for starting early, which is the opposite of what "essential use" is usually deployed to justify. If a material is genuinely essential and genuinely carries a compounding liability, then the liability is not optional and the substitute is not a luxury — it is the single most valuable piece of research the sector is not yet treating as urgent. The bond that won't break is also the bond that won't wait. The right response to "we cannot replace it yet" is a funded program to replace it, run against the clock that nature, not the regulator, is keeping.

The seductive wrong lesson, and the right one

The dangerous conclusion to draw from all of this is the simple one: choose natural materials, and you are safe. That lesson is wrong, and the counterexample is lethal enough to bury an entire argument if a chemist raises it before you do. Asbestos is natural. It is a mineral, pulled from the rock, "nature-derived" in every literal sense, and it is one of the great compounding liabilities of the industrial age, still killing people who were exposed decades ago. Botulinum toxin is natural. Aflatoxin is natural. Nature is not a synonym for benign.

So the screen is not whether a material comes from nature. The screen is whether it is compatible with life — built from the small palette of benign elements that living systems use, assembled at ambient temperature and pressure, and, decisively, unbuildable as readily as it is buildable, because in a living system every output is some other process's input. Nor is the warning sign persistence by itself. Glass persists. Gold persists. They sit in the ground for ten thousand years and harm nothing, because they are inert and immobile and untoxic. The PFAS signature is persistence and mobility and bioaccumulation and toxicity, all at once, in a molecule that travels through water and concentrates up the food chain and refuses to leave the body it enters.

Which gives us a heuristic clean enough to carry into any design review: if four billion years of evolution never produced an organism that learned to eat it, that is not a triumph of engineering. That is the warning label, printed in the only language the arbiter writes in.

What to do on Monday

None of this requires a moonshot. It requires reading your own bill of materials; the reality is that it is actually a portfolio of bets on existing and developing liability curves you have probably never priced.

Let the demand lead. Let biology narrow the solution space to what already works at scale, under pressure, and across four billion years of testing. Treat manufacturability as non-negotiable. That is how this becomes engineering and finance rather than inspiration, and it is how a company retires a PFAS-shaped liability while it is still a choice rather than a verdict.

Nature doesn't negotiate

The carbon-fluorine bond was a loan drawn against a future that has now arrived, and the lenders — the courts, the insurers, the communities, the human immune system — are collecting. The uncomfortable truth is that the next PFAS is already on someone's bill of materials at this moment, booked as a margin, its liability invisible for the same reason the original's was: no one in the room is pricing the bond.

So the question I would leave with any board, any founder, any leader of any  industry, is not whether they believe in sustainability, or where they have landed in the politics of a word. It is a much colder and older question:  Which of the materials you build your business on today would fail, from the first day, the test that PFAS failed? And are you pricing that liability now, while the choice is still yours to make, or are you waiting for the ultimate arbiter to price it for you? Because it will. It always has and sooner or later it does. Whether tomorrow or seven generations from now, without malice and without exception, nature settles every account. The only variable left to us is whether we’ve summoned the discipline, the courage and the will to read the terms before we sign.

References

Environmental Protection Agency (2026) Proposed Rule: Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) National Primary Drinking Water Regulation — Compliance Date Extension. Washington, DC: EPA. Available at: www.epa.gov/sdwa

Environmental Protection Agency (2026) Proposed Rule: Rescission of Maximum Contaminant Levels for PFHxS, PFNA, HFPO-DA (GenX Chemicals), and the Hazard Index Mixture. Washington, DC: EPA. Available at: www.epa.gov/sdwa

Environmental Protection Agency (2024) National Primary Drinking Water Regulation for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Final Rule, 26 April. Washington, DC: EPA.

Harvard Environmental & Energy Law Program (2026) PFAS Regulatory Tracker. Cambridge, MA: Harvard Law School. Available at: eelp.law.harvard.edu

Itumoh, E.J., Data, S., Chen, J.L.-Y., Kah, M., Padhye, L.P. and Leitao, E.M. (2024) 'Addressing the persistence of per- and poly-fluoroalkyl substances (PFAS): current challenges and potential solutions', RSC Sustainability, 2, pp. 3183–3210. Available at: https://doi.org/10.1039/D4SU00152D

New Jersey Office of the Attorney General (2025) Settlement Agreement: State of New Jersey v. 3M Company. Trenton, NJ: NJOAG. Available at: www.njoag.gov

New Jersey Office of the Attorney General (2025) Settlement Agreement: State of New Jersey v. DuPont de Nemours et al. Trenton, NJ: NJOAG. Available at: www.njoag.gov

United States Judicial Panel on Multidistrict Litigation (2026) MDL No. 2873 — Aqueous Film-Forming Foam (AFFF) Products Liability Litigation: Docket Report. Washington, DC: JPML. Available at: www.jpml.uscourts.gov

3M Company (2022) Form 8-K Exhibit 99.1: 3M to Exit PFAS Manufacturing by the End of 2025, filed 20 December. St Paul, MN: 3M Company. Available at: https://www.sec.gov/Archives/edgar/data/0000066740/000006674022000085/a1220228kex-991.htm [Accessed June 2026].

3M Company (2023) Form 8-K filed June 22, 2023: PFAS Public Water Systems Settlement Agreement. St Paul, MN: 3M Company. Available at: https://www.sec.gov/Archives/edgar/data/0000066740/000006674023000048/mmm-20230622.htm