PFAS and refrigerants: Toward a regulatory distinction for the HVAC/R sector

The European debate on per- and polyfluoroalkyl substances ( PFAS ) is increasingly directly involving the HVAC/R sector, raising significant questions about the future of fluorinated refrigerants . At the heart of the discussion is the need to distinguish between the use of PFAS in areas with a high environmental impact and the use of refrigerants in refrigeration systems , preventing widespread regulation from compromising technologies that are crucial for energy efficiency and the operational continuity of plants.

PFAS and refrigerants: an overlap that needs to be clarified

From a chemical standpoint, some fluorinated refrigerants fall within the definition of PFAS, but their technical and functional role in HVAC/R systems is profoundly different from other industrial uses of these substances. In refrigeration circuits, refrigerants are contained, managed, and recovered according to already stringent regulations, with specific requirements for safety, maintenance, and end-of-life.

This substantial difference highlights the need for a regulatory distinction , capable of considering the controlled life cycle of refrigerants and the contribution they offer to the reduction of energy consumption and indirect emissions.

Targeted regulation and technological continuity

A possible evolution of the regulatory framework aims to maintain fluorinated refrigerants within a dedicated regulatory regime , already based on GWP criteria, progressively reduce quotas, and transition to lower-impact alternatives. This approach would allow:

• avoid overlaps between different and potentially conflicting regulations;
• ensure a gradual and technically sustainable transition to new refrigerants;
• preserve the operational continuity of commercial and industrial refrigeration systems;
• support technological innovation without introducing widespread bans that are difficult to enforce.

Non-differentiated regulation, on the other hand, risks creating planning uncertainties, slowing down investments, and generating critical issues in the management of existing plants.

Impacts on design, maintenance and the cold chain

For refrigeration professionals, the evolving PFAS framework requires increased attention to material traceability, component selection , and fluid management throughout the entire system life cycle . Designers and maintenance personnel are required to more accurately assess material compatibility, alternative solutions, and system upgrade strategies, while maintaining high safety and efficiency standards.

In this scenario, the HVAC/R sector's ability to communicate with legislators becomes crucial to ensuring clear, technically sound rules that are consistent with the operational needs of commercial and industrial refrigeration.

Towards a balance between environmental protection and operations

The potential regulatory distinction between PFAS and refrigerants represents a key step for the future of the sector. The goal is to find a balance between environmental protection, technological innovation , and system reliability , avoiding simplified solutions that ignore the complexity of refrigeration systems.

For the refrigeration industry, this regulatory transition phase requires attention, continuous updating, and the ability to adapt, but it can also become an opportunity to strengthen the sector's role as a knowledgeable and responsible technical player in the energy transition.