Focus Laws and Regulations

26.03.2026

PFAS and refrigeration: a new phase of European consultation on restrictions begins

ECHA launches a new consultation on PFAS: potential impacts also for the refrigeration and F-gas sectors.

The European regulatory process on PFAS (per- and polyfluoroalkyl substances) enters a crucial phase. The European Chemicals Agency (ECHA) is preparing to launch a new public consultation on its updated opinion on the proposed restriction of these substances, used in numerous industrial sectors, including refrigeration.

This is a key step that could also have significant impacts on the HVAC/R sector, already involved in the transition process towards refrigerants with a lower environmental impact.

 

A strategic consultation for the future of PFAS

The consultation, scheduled for 2026, represents a key step in the European decision-making process. Following the technical assessment conducted by ECHA's scientific committees, stakeholders will have the opportunity to provide input on the potential socioeconomic impacts of the proposed restrictions.

The goal is to collect data and observations on crucial aspects such as:

  • availability of alternatives to PFAS in different industrial sectors
  • economic impacts of the restrictions
  • technical feasibility of substance substitution

This comparison phase will be crucial in defining the final framework for future European regulations.

 

PFAS and European legislation: a consultation that opens new scenarios for refrigeration

In the refrigeration and air conditioning sector, PFAS are present in various applications, particularly in certain types of fluorinated refrigerants. The proposed restriction is part of a regulatory framework already geared toward reducing F-gases and progressively eliminating substances with a high environmental impact .

The options under evaluation include several scenarios , including:

  • extended restrictions with limited transition periods
  • temporary exemptions for specific applications
  • more stringent conditions to limit emissions throughout the life cycle

For the HVAC/R industry, this means a further push towards the adoption of alternative solutions, such as natural refrigerants and low-GWP technologies.

 

A complex and progressive regulatory process

The proposed restriction on PFAS, initiated in 2023 by five European countries, is one of the most far-reaching ever considered in the chemical sector, involving thousands of substances and numerous industrial sectors.

The process involves several phases: from the technical risk assessment to the public consultation, up to the final proposal by the European Commission, expected by the end of 2026.

For companies in the HVAC/R supply chain, this scenario requires increasing attention to regulatory developments and strategic planning of the technologies to be adopted.

 

Towards a new phase in the refrigerant transition

The launch of the consultation on PFAS confirms how the European regulatory framework is evolving towards increasingly stringent environmental criteria.

For the refrigeration sector, this is a further step in the process already begun with the F-gas phase-down : refrigerant management no longer concerns only GWP, but also the environmental persistence and long-term impact of the substances.

In this context, the ability to anticipate regulatory changes and adopt sustainable solutions represents a strategic factor for business competitiveness and compliance.

FAQ

The new consultation phase launched at the European level concerns the possible introduction of broad restrictions on the use of PFAS, currently being evaluated by institutions. The process involves industry and technical stakeholders to define the methods, timing, and scope of application of any potential restrictions.

The restrictions could have a significant impact because some substances used in refrigerants belong to the PFAS family. This could lead to restrictions on the use of certain fluids and the need to develop alternatives, with implications for the design, availability, and costs of HVAC/R systems.

The European debate has raised the possibility of exemptions or specific treatments for the HVAC/R sector, to avoid overlap with the existing F-Gas Regulation. Some studies suggest maintaining a separate regulation for refrigerants, considered strategic for many technological applications.