Refrigerant gases and F-Gases: the open issue of exemptions between regulations and plant reality

The revision of the F-Gas Regulation has outlined a clear direction: progressively reduce the use of high-GWP refrigerants and accelerate the transition to lower-climate solutions . However, in design practice, this path comes up against a variable that cannot be ignored: system safety .

It is precisely at this point of equilibrium that the issue of regulatory exemptions comes into play, provided for those cases in which available alternatives are not technically feasible or do not guarantee adequate operating conditions. The principle is sound, but its concrete application opens up margins of interpretation that are generating uncertainty throughout the entire supply chain.

Exemptions: Technical Tool or Gray Area?

Safety -related exemptions are designed to address specific situations, but they risk becoming a regulatory gray area if not accompanied by clear application criteria. The problem isn't the existence of the exemption, but rather the difficulty in defining its operational boundaries.

In many contexts, especially in complex or retrofit applications, refrigerant selection cannot be based solely on GWP. Factors such as:

• the security classification,
• the installation conditions,
• the characteristics of the environments,
• compatibility with the existing system.

In the absence of unequivocal indications, the risk is that the assessment will be delegated to the individual operator, with consequences for responsibility, design, and compliance.

Real impact on the work of designers and installers

For those who work in the refrigeration sector on a daily basis, the issue of exemptions isn't theoretical but operational . It means deciding how to design a system today, knowing that regulatory and technological conditions are rapidly evolving.

The challenge is not just identifying the most sustainable refrigerant, but finding a solution that is technically feasible, safe, and compliant. In this context, the lack of shared guidelines complicates risk management and slows down the decision-making process.

The result is a paradox: a regulation created to accelerate the transition risks , in some cases, generating design uncertainty , especially in less standardized applications.

Towards a balance between innovation and technical responsibility

The path toward climate-friendly refrigerants is now clear and irreversible. However, for this transition to be truly effective, clear implementation tools must accompany environmental objectives.

Exemptions must not become a shortcut, but neither should they create ambiguity. We need shared criteria, consistent interpretations, and a more structured dialogue between legislation and plant design practice.

For the refrigeration sector, the issue is not choosing between sustainability and safety, but integrating both in a sound design.