PFAS and HVAC-R: The Refrigeration Industry: Critical Materials and Impending Regulation

In the latest European update on the proposal to restrict PFAS, published in August 2025, the HVAC-R sector is identified as one of the most critical.

The analyses contained in the dossier, which also collects feedback from over 5,600 stakeholders, show that the sector is in class 5 (more than 10,000 tonnes/year) for tonnage of PFAS used and also in a high position for actual release during the life cycle of the plants.

The reasons are many:

• the widespread presence of fluorinated refrigerants,
• the use of gaskets,
• sealants,
• membranes and lubricants containing PFAS,
• an installed base of considerable size.

This combination means that the refrigeration and air conditioning sector generates a significant share, estimated between 5% and 10%, of total PFAS emissions in Europe.

Materials, components and life cycle: three operational nodes

Specifically, the HVAC-R findings highlight three critical areas: refrigerant or lubricant leaks during use and maintenance, degradation or abrasion of fluorinated materials (gaskets, membranes, component coatings), and the end-of-life phase of the systems, including disassembly and treatment of refrigerant and components containing PFAS.

Each of these moments represents a potential source of release and requires attention from a design and maintenance perspective. The result is that the sector, already subject to F-gas regulations, now finds itself anticipating a new level of material constraints .

Towards a technical-regulatory adjustment: what changes for the cold chain?

The European proposal for a universal restriction on PFAS does not yet set a binding timeline, but it does make a firm commitment: the refrigeration industry must begin mapping materials, components, and processes to ensure future compliance. While the practical implementation of the restrictions will be subject to a timeline and procedures yet to be determined, the message is clear: components that use PFAS are being targeted.

For manufacturers, designers, and maintenance personnel, this means starting to require technical declarations on materials, considering non-fluorinated alternatives, implementing component traceability, and designing systems that can be upgraded and managed in light of regulatory changes.

The issue of PFAS introduces a new dimension of technical and environmental responsibility to the world of professional refrigeration: it's not just about refrigerants, but also the materials surrounding compressors, coatings, sealants, maintenance, and end-of-life management.

Decisions made today will impact the supply chain for years to come: material mapping, leak reduction, replacement planning, and component selection can make the difference in ensuring compatibility, efficiency, and reliability in future refrigerant systems.