PFAS and commercial refrigeration: what could change?

Commercial refrigeration is already undergoing a profound transformation linked to the new F-Gas Regulation and the progressive reduction in the use of high-GWP fluorinated refrigerants . This process is now accompanied by a second European dossier destined to impact the sector's technological choices : the proposed restriction of PFAS, per- and polyfluoroalkyl substances characterized by high persistence in the environment.

The issue is closely related to the HVACR sector because, according to the definition used in the European procedure, various fluorinated refrigerants and materials containing fluorinated substances used in equipment may be included. However, the proposal has not yet become a definitive ban: in 2026, the process is still undergoing scientific evaluation by ECHA, with possible exemptions depending on the application.

PFAS and F-Gas Restriction are Two Different Paths

It is important to distinguish the PFAS dossier from the F-Gas Regulation . EU Regulation 2024/573 primarily aims to reduce climate emissions from fluorinated gases by introducing a phase-down of HFCs and progressive bans on the placing on the market of equipment containing certain refrigerants based on their GWP and system type.

The PFAS proposal, however, arises under the REACH regulation and addresses a different issue: the environmental persistence of thousands of fluorinated substances. The proposal concerns the production, marketing, and use of PFAS and, among the sectors analyzed by ECHA, also includes the applications of fluorinated gases in refrigeration, air conditioning, and heat pumps.

The two approaches may therefore overlap, but they are not equivalent. A refrigerant with a low GWP may be of interest for the purposes of the F-Gas Regulation and, at the same time, fall within the scope of the future PFAS regulation.

For manufacturers, designers, and operators of commercial refrigeration, this means that the choice of fluid cannot be evaluated solely based on the GWP parameter, but must also consider the evolution of environmental regulations on the substances used.

Not just refrigerants: attention extends to components

The potential impact of PFAS restrictions extends beyond the refrigeration circuit. Fluorinated substances may also be present in gaskets, coatings, lubricants, insulation materials, and other technical components, thanks to properties such as chemical resistance, thermal stability, and low friction.

A future restriction could therefore require the supply chain to more precisely analyze the composition of the products, identify any affected substances, and verify the availability of compatible alternatives.

For companies in the sector, the following will become increasingly important :

• mapping of substances present in the components;
• collaboration and exchange of information with suppliers;
• verification of possible technical alternatives;
• compatibility of new materials with pressures, temperatures and refrigerants;
• reliability assessment throughout the entire life cycle;
• traceability of equipment composition.

Replacing a substance isn't always straightforward. A material used in a seal or valve, for example, must continue to guarantee safety, durability, and chemical compatibility under the expected operating conditions.

For this reason, ECHA is also evaluating the socioeconomic impact of the restriction and the possibility of introducing targeted derogations in cases where technically and economically viable alternatives do not yet exist.

Natural refrigerants increasingly central to new installations

The potential tightening of PFAS regulations is part of an already underway transition toward alternative refrigerants. In commercial refrigeration, the main growth areas are solutions based on CO₂ (R744) and hydrocarbons such as propane R290 , which do not belong to the fluorinated refrigerant family.

Their spread is already being facilitated by the restrictions introduced by the new F-Gas Regulation. For example, several categories of stand-alone refrigeration equipment already have restrictions on the use of fluorinated gases with a GWP greater than 150, while further deadlines will affect chillers and other equipment in the coming years.

However, this doesn't mean that there's a single solution that works for every system . CO₂, propane, ammonia, and synthetic refrigerants have different operational and safety characteristics and require appropriate design, components, and expertise.

For new installations, it's increasingly important to think long-term. The choice of technology must take into account not only efficiency and initial investment, but also future refrigerant availability, regulatory requirements, maintenance, and the expected lifespan of the system.

The future restriction of PFAS could reinforce this trend, pushing the market towards solutions less dependent on fluorinated substances and further accelerating the transformation of European commercial refrigeration.

At present, however, there is still no general European ban on PFAS applicable to refrigeration. ECHA's RAC adopted its opinion in March 2026, while SEAC is completing its socioeconomic assessment; the final opinion is expected by the end of 2026, and the European Commission will then define any regulatory measures.