PFAS and F-Gas: A Double Regulatory Challenge for the HVAC&R Industry

The refrigeration and air conditioning sector is currently at the centre of a complex regulatory evolution .

The revision of the European Regulation on fluorinated gases (F-Gas) is accompanied by the proposal to restrict PFAS , a large family of fluorinated chemicals currently at the centre of the European debate.

During the Asercom convention, the European HVAC&R Industry Association (EPEE) highlighted how the potential overlap between these two regulatory initiatives could create new critical issues for the sector, especially in terms of technology availability and industrial planning.

The PFAS restriction proposal is based on a very broad definition, encompassing thousands of fluorinated substances characterized by high chemical stability and environmental persistence. These very characteristics, however, underpin the performance that has favored their use in many industrial applications, including refrigeration.

Regulatory overlap between PFAS and F-Gas

One of the most sensitive issues concerns the potential double regulatory burden that could arise from the simultaneous application of the PFAS proposal and the new F-Gas regulation.

The latter already introduces progressive limits on the use of fluorinated refrigerants through the HFC phase-down, increasingly stringent GWP thresholds, and sector-specific bans for specific applications. The introduction of a broader restriction on PFAS could therefore further reduce the technological options available for many HVAC&R applications.

Natural alternatives such as CO₂, ammonia, or hydrocarbons are increasingly popular solutions, but they are not always applicable in all contexts due to constraints related to safety, operating pressures, or installation conditions.

Impacts on plant materials and components

The PFAS issue isn't just about refrigerants. Many fluoropolymers used in HVAC&R components , such as gaskets, valves, insulation, or wiring, fall into the fluorinated substances family and could therefore be affected by any restrictions.

Depending on the industry, replacing these materials isn't straightforward: it requires years of research, testing, and supply chain qualification to ensure the same levels of reliability, chemical compatibility, and durability. In some cases, the development cycle for new solutions can take as long as 15-20 years.

The temporary exemptions provided for some applications are still considered by the industry to be insufficient to manage a technological transition of this magnitude.

A regulatory process still open

The European regulatory process for PFAS is still evolving. The socioeconomic assessment phase of the proposal is expected in 2026, while the possible entry into force of restrictions could occur between 2028 and 2029, with subsequent transition periods.

At this stage, the HVAC&R industry is called upon to actively participate in the public consultation process to help define a balanced regulatory framework. The stated goal of industry associations is to ensure that the regulatory transition takes into account technical requirements, safety, and industrial competitiveness.