The Delay Tactics Playbook
Industry Playbook · Aug 2025 · 15 min read
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The Delay Tactics Playbook

25 Patterns Blocking PFAS Transformations — And The Steps That Will Put Your Deadlock Back on Track

Mark Schäfer
Mark Schäfer
Founder, Lotus Nano

Every PFAS transition conversation follows predictable patterns. Not because industry is malicious. Because organizational change is hard.

Some arguments contain legitimate concerns. Cost pressures are real. Supply chain complexity is genuine. Technical alternatives aren't always mature.

The problem isn't the concerns.

It's when legitimate concerns become permanent paralysis.

This framework documents 25 patterns that appear in PFAS transition conversations globally. Some are pure delay tactics. Some start as legitimate concerns but evolve into stalling mechanisms. Most are both.

The goal isn't to "win" arguments. It's to recognize patterns and move conversations forward.

Use this framework when:

  • • You're stuck in circular procurement discussions
  • • Board meetings repeat the same objections quarterly
  • • Suppliers offer the same explanations for 18 months
  • • Internal stakeholders can't align on next steps

This isn't about judging motivations. It's about recognizing when conversations have become loops instead of progress.

Category 1

Scientific & Technical Uncertainty

These patterns emerge in technical and R&D discussions. Some reflect genuine scientific caution. Others weaponize uncertainty to avoid action.

The Science Isn't Settled Yet

01
Contains legitimate concern

What's Legitimate

Science evolves, early research has limitations, and healthy scientific debate exists.

When It Becomes Problematic

Used to demand perfect certainty before any action, indefinitely postponing decisions.

How to Move Forward

Apply precautionary principle where persistence and bioaccumulation exist. Set evidence threshold for action, not paralysis.

Our PFAS Type Is Different

02
Primarily delay mechanism

What's Legitimate

Not all PFAS have identical toxicological profiles or environmental fate.

When It Becomes Problematic

Ignores entire class persistence and regrettable substitution risk. Yesterday's "safer" alternative becomes today's regulated substance.

How to Move Forward

Focus on class-wide action. Moving from C8 to C6 to C4 repeats the same cycle. Exit fluorochemistry entirely where feasible.

Alternatives Don't Perform

03
Legitimate operational challenge

What's Legitimate

Some alternatives genuinely underperform in specific high-stress applications (extreme heat, chemical exposure, critical safety).

When It Becomes Problematic

Applied as blanket statement without testing systems approaches combining fabric engineering, process optimization, and chemistry.

How to Move Forward

Identify where performance gaps are real versus assumed. Test fabric + chemistry + process combinations. Most applications have viable pathways.

Products Won't Work Without PFAS

04
Contains legitimate concern

What's Legitimate

Genuinely essential uses exist: certain medical devices, critical safety equipment, aerospace applications.

When It Becomes Problematic

Applied to convenience applications without verification. "Essential" conflates "performs best" with "societal necessity".

How to Move Forward

Rigorously define essential based on societal need, not performance preference. Verify lack of alternatives independently with time-bound exemptions.

We Need More Research

05
Primarily delay mechanism

What's Legitimate

Understanding alternatives fully before scaling is prudent engineering practice.

When It Becomes Problematic

Becomes indefinite study with no decision timeline. "More research needed" used for years without concrete action.

How to Move Forward

Set time-bound research phase with clear decision criteria and go/no-go milestones. Pilot testing with committed timelines.

Category 2

Economic & Business Viability

Cost concerns are always legitimate. These patterns become problematic when they exaggerate costs, ignore risk calculations, or demand perfect certainty before investment.

Transition Costs Are Prohibitive

06
Legitimate operational challenge

What's Legitimate

Reformulation, retooling, validation, and scaling costs are real and significant, particularly for SMEs.

When It Becomes Problematic

Ignores long-term liability exposure, brand damage, and market access costs. Short-term focus excludes risk calculation.

How to Move Forward

Full cost-benefit analysis including regulatory risk, liability exposure, and market trends. Proactive investment cheaper than reactive crisis management.

This Will Cost Jobs

07
Legitimate operational challenge

What's Legitimate

Transition causes short-term displacement in chemical manufacturing and dependent industries.

When It Becomes Problematic

Used to halt all action without transition planning, workforce development, or just transition principles.

How to Move Forward

Managed transition with workforce retraining programs. Green chemistry creates new employment. Historical chemical transitions show net job creation.

Global Competitors Don't Face This

08
Contains legitimate concern

What's Legitimate

Regulatory asymmetry creates temporary competitive imbalance in global markets.

When It Becomes Problematic

Ignores regulatory convergence trajectory and first-mover advantages in establishing PFAS-free supply chains.

How to Move Forward

EU plus US states create de facto global standard. Leading captures premium positioning. Lagging faces future market exclusion.

Shareholders Won't Accept This

09
Contains legitimate concern

What's Legitimate

Fiduciary duty requires justifying major capital expenditures to shareholders.

When It Becomes Problematic

Ignores ESG materiality and regulatory risk in valuation. Forward-looking investors see inaction as greater risk.

How to Move Forward

Frame as risk mitigation and strategic positioning, not discretionary spend. Leading asset managers increasingly factor PFAS exposure into valuations.

We've Already Invested Millions

10
Contains legitimate concern

What's Legitimate

Sunk costs represent real capital. Asset write-offs impact financial statements and valuations.

When It Becomes Problematic

Past investment dictates future strategy despite changing regulatory landscape. Sunk cost fallacy prevents rational decision-making.

How to Move Forward

Compare sunk costs to future liability, compliance, and market access risks. Depreciation schedules and phased transitions manage financial impact.

Category 3

Regulatory & Legal Positioning

Legal and regulatory complexity is real. These patterns become delay mechanisms when used to justify indefinite inaction whilst waiting for perfect clarity.

Essential Use Exemptions Cover Us

11
Primarily delay mechanism

What's Legitimate

Genuine essential uses require temporary exemptions where no alternatives exist.

When It Becomes Problematic

Applied broadly without rigorous justification or sunset provisions. Self-certification without independent verification.

How to Move Forward

Independent verification of essential claims. Time-bound exemptions with mandated alternative development and regular review.

Regulations Are Unclear

12
Contains legitimate concern

What's Legitimate

Regulatory patchwork creates genuine compliance complexity across jurisdictions.

When It Becomes Problematic

Used to justify inaction whilst waiting for perfect clarity that never arrives.

How to Move Forward

Comply with strictest standard as practical baseline. Regulatory convergence is directional. Early movers shape standards.

We're Already Compliant

13
Primarily delay mechanism

What's Legitimate

Meeting current legal requirements is baseline expectation and fiduciary responsibility.

When It Becomes Problematic

Ignores regulatory trajectory and leading indicators. Current compliance doesn't guarantee future approval.

How to Move Forward

Regulations lag science by years. Proactive action reduces future disruption. Current approval is not long-term safety guarantee.

We Must Challenge This in Court

14
Primarily delay mechanism

What's Legitimate

Legal review of regulatory process can ensure procedural fairness and scientific basis.

When It Becomes Problematic

Pure delay tactic with no substantive technical argument. Uses litigation to stall for years.

How to Move Forward

Distinguish procedural challenge from substantive delay. Litigation as last resort after scientific and ethical arguments exhausted.

Need Federal Action, Not States

15
Primarily delay mechanism

What's Legitimate

Harmonized federal standards are more efficient than state-by-state variation.

When It Becomes Problematic

Used to halt all action whilst waiting for federal consensus that may take years.

How to Move Forward

State action catalyzes federal policy. California, New York lead. Waiting means falling behind regulatory leaders and market access.

Category 4

Supply Chain & Responsibility

Supply chains are genuinely complex. These patterns become problematic when they redirect all responsibility elsewhere whilst taking no internal action.

Supply Chain Too Complex to Track

16
Legitimate operational challenge

What's Legitimate

Global supply chains with thousands of suppliers create genuine transparency challenges.

When It Becomes Problematic

Used as excuse for no action rather than phased approach starting with tier 1 suppliers.

How to Move Forward

Tiered supplier engagement. Start with direct suppliers, extend progressively. Chemical disclosure requirements in procurement contracts.

Real Problem Is Other Industries

17
Primarily delay mechanism

What's Legitimate

Different industries contribute different PFAS load pathways and exposure routes.

When It Becomes Problematic

Deflects all responsibility onto firefighting foam, industrial sites, etc. whilst taking no internal action.

How to Move Forward

All sources contribute. Widespread low-level exposure from consumer goods is distinct pathway. Shared responsibility means everyone moves.

Suppliers Can't Provide Alternatives

18
Contains legitimate concern

What's Legitimate

Supply chain for alternatives less mature than decades of PFAS infrastructure.

When It Becomes Problematic

Assumed without actually engaging suppliers or testing alternatives. Demand signals create supply.

How to Move Forward

Supplier collaboration and development programs. Co-investment in alternative scaling. Demand commitments accelerate supply development.

This Is About Consumer Choice

19
Primarily delay mechanism

What's Legitimate

Consumer preferences and willingness to pay matter for market viability.

When It Becomes Problematic

Consumers cannot make informed choices without disclosure of risks. Shifts responsibility from manufacturer to end user.

How to Move Forward

Manufacturer responsibility for safety. Choice requires transparency. Growing consumer awareness and willingness to pay for safer products.

Consumers Don't Dispose Properly

20
Primarily delay mechanism

What's Legitimate

End-of-life management matters for environmental outcomes and circular economy.

When It Becomes Problematic

Shifts responsibility from persistent chemical design to consumer behavior. Products with persistent chemicals cannot be disposed of safely.

How to Move Forward

Problem starts at design stage. Persistent bioaccumulative substances remain in environment regardless of disposal method.

Category 5

Timeline & Process

Major transitions take time. These patterns become delay tactics when they create illusion of progress without meaningful commitments or milestones.

We Need More Time

21
Contains legitimate concern

What's Legitimate

Thorough testing and validation takes time. Rushing risks product failures and safety issues.

When It Becomes Problematic

Becomes indefinite timeline without milestones or commitments. "More time" used for years.

How to Move Forward

Set decision milestones with go/no-go criteria. Pilot testing with committed timelines. Most applications: 2-5 years maximum.

Industry Self-Regulation Works

22
Primarily delay mechanism

What's Legitimate

Industry expertise valuable in developing practical, implementable solutions.

When It Becomes Problematic

Voluntary commitments lack accountability, timelines, penalties. History shows insufficient action.

How to Move Forward

Binding regulations create level playing field and ensure accountability. Voluntary action supplements but doesn't replace regulation.

Our Target Date Is 2040

23
Primarily delay mechanism

What's Legitimate

Major transitions require multi-year planning, capital allocation, and investment cycles.

When It Becomes Problematic

Commitment decades away without interim milestones. Urgency doesn't match regulatory trajectory.

How to Move Forward

Urgent timeline with annual targets. Most applications should achieve transition within 2-5 years, not 15-20.

We Launched a PFAS-Free Line

24
Contains legitimate concern

What's Legitimate

Starting somewhere shows commitment and builds internal capability and knowledge.

When It Becomes Problematic

Token gesture without plan to extend across all products. Capsule collection deflects whilst core business unchanged.

How to Move Forward

What's roadmap to 100%? What percentage by when? Single collection is start, not solution.

We're Studying the Issue

25
Primarily delay mechanism

What's Legitimate

Understanding problem scope before acting is responsible management practice.

When It Becomes Problematic

Permanent study phase with no action commitment. Analysis paralysis without decision framework.

How to Move Forward

Study phase should be time-bound with clear decision criteria. Set timeline for assessment completion and action commitment.

Using This Framework

These 25 patterns work collectively to create decision paralysis. The solution isn't debating each pattern individually. It's recognizing when conversations have become loops.

When you hear pattern #7 (job losses) combined with pattern #21 (need more time) and pattern #23 (distant target date), you're not hearing three separate concerns. You're seeing a system designed to avoid commitment.

The most effective response isn't countering each argument. It's naming the pattern: "We've been in study phase for 18 months with no decision criteria. What would need to be true for us to commit to a timeline?"

Pattern recognition is the first step. Action is the second.

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