F-Gas and PFAS: Two regulations that could change the choice of refrigerants

The refrigerant transition in Europe could be increasingly influenced by the interaction between the F-Gas Regulation and the future restriction of PFAS under REACH . The two instruments, in fact, intervene in the same market from different perspectives: the former primarily aims to reduce the climate impact of fluorinated gases, while the latter aims to limit the use and emissions of substances characterized by high persistence in the environment.

The topic has returned to the forefront of debate following the publication of a new analysis specifically addressing potential overlaps and areas not covered by the F-Gas Regulation. According to the estimates, without further measures, significant quantities of F-gases classifiable as PFAS could continue to be used in the EU.

For HVAC/R manufacturers, designers, and operators, the consequence is important: a refrigerant with a very low GWP is not automatically excluded from the PFAS debate . The choice of fluids may therefore increasingly require an assessment that simultaneously considers climate impact, environmental persistence, availability of alternatives, and safety requirements.

F-Gas and REACH address different environmental issues

The F-Gas Regulation (EU) 2024/573 acts primarily through HFC phase-downs, equipment bans, leak prevention, fluid recovery, and training and certification requirements.

Its main objective is to reduce emissions of fluorinated greenhouse gases by progressively favoring refrigerants with lower GWP or non-fluorinated alternatives.

The proposal for a universal restriction of PFAS under REACH, however, addresses a different issue. PFAS are a very large family of substances characterized by carbon-fluorine bonds that are extremely resistant to degradation; their persistence can lead to accumulation in the environment and contamination of water and soil.

Therefore, the two regulatory frameworks are not necessarily mutually exclusive. A refrigerant may have a low GWP and therefore be compliant with some climate objectives of the F-Gas Regulation, but still be assessed for environmental persistence or degradation products under REACH.

HFOs and TFAs enter the refrigerant debate

One of the most discussed issues concerns some new generation fluorinated refrigerants, including certain HFOs and blends containing substances falling within the PFAS definition used in the European proposal .

The issue is also linked to the potential formation of trifluoroacetic acid (TFA) following the atmospheric degradation of certain fluorinated compounds. TFA is a highly persistent substance, and its environmental behavior has entered the European debate on PFAS management.

This does not mean that all HFOs or fluorinated refrigerants will automatically be banned. The REACH proposal is being assessed by distinguishing between sectors, applications, availability of alternatives, and possible exemptions.

The sector of fluorinated gas applications , including refrigeration, air conditioning and heat pumps, is however explicitly included in the European assessment.

For the HVAC/R supply chain, it is therefore essential to avoid simplifications: the future of each refrigerant will depend on a combination of chemical classification, application, available alternatives, and final decisions that will be adopted at the European level.

The PFAS restriction is not yet final

The European process on the universal restriction of PFAS is still ongoing.

The European institutions are assessing the impact of the proposal on various sectors, also considering the possibility of targeted derogations and transition periods for applications where technically adequate alternatives are not yet available.

At the moment it is therefore not correct to speak of a general ban on PFAS refrigerants that has already been approved .

The picture is still evolving, and final decisions will need to take into account performance, safety, availability of alternatives, and the economic impact on various industrial sectors.

The choice of refrigerant is increasingly becoming a long-term decision

For designers and manufacturers, the interaction between F-Gases and PFAS therefore adds a new layer to refrigerant selection.

GWP remains a fundamental parameter, but it may no longer be sufficient to assess the regulatory sustainability of a solution throughout the entire life of the plant.

Also becoming increasingly important are:

• possible membership of the fluid to the PFAS family;
• products generated by environmental degradation;
• future availability of refrigerant;
• presence of non-fluorinated alternatives;
• application security;
• possibility of maintenance throughout the entire useful life of the system.

This scenario strengthens the interest in non-fluorinated refrigerants such as CO₂, ammonia, propane, water and other natural fluids , already used in numerous RACHP applications.

The refrigerant transition is therefore entering a more complex phase: it's no longer simply a matter of switching from a high-GWP gas to one with a lower climate impact. The design must simultaneously consider climate, environmental sustainability, safety, and regulatory stability of the chosen solution , reducing the risk of having to deal with further substitutions over the life of the system.