The European Union (EU) has always been a little bit ahead of the U.S. in terms of refrigerant regulations. That’s why it’s important to pay attention to what’s going on there, as it can sometimes be a preview to the legislation enacted in this country.

The European HFC phasedown began with the EU F-Gas Regulation guidelines of 2014, which mandated that production of virgin HFCs in the EU be reduced by approximately 7% in 2016, 37% in 2018, and 55% in 2021, compared to the baseline. Experts had hoped that end users would take steps to reduce their use of fluorinated (F) gases (known as HFCs in the U.S.) in anticipation of these drastic reductions, however, that did not happen. As a result, prices of some HFCs initially skyrocketed and became scarce, resulting in a thriving black market for illegally imported refrigerants that continues to be a problem.

As the phasedown continued, European lawmakers became increasingly dissatisfied with the rate of change, leading the European Commission to develop a proposal in April 2022 to amend the F-Gas Regulation and accelerate the refrigerant transition. The European Parliament then adopted the proposal in March 2023 while calling for a steeper phase down of HFCs and a full phaseout of HFC production and consumption by 2050. The European Council subsequently adopted the proposal, so now all three legislative bodies will negotiate (called a trilogue) in order to come to an agreement on the final regulations, which are expected to be published later this year.

Not surprisingly, HVACR manufacturers were unhappy with the revised regulations, and in a press release, the European Heat Pump Association (EHPA) noted that if the new timeline becomes law, it would “mean a ban on F-gases from as early as 2026 for some heat pump types, slamming on the brakes for heat pump deployment and undermining the EU’s climate and energy security ambitions.”

In a recent webinar about refrigerant regulations, Torben Funder-Kristensen, head of industry affairs, climate solutions, at Danfoss, said there is no need to worry too much right now, as the final regulations are not a done deal.

“The F-Gas Regulation is not finished yet, and that's very important,” he said. “Nothing has been finally written, but within this year, we will have a new text for the F-Gas Regulation.”

He added that the new text will undoubtedly include a lot of GWP restrictions for specific applications, among other things.

“There are definitely some technical issues that need to be solved,” Funder-Kristensen continued. “Timing is crucial, because it takes time to develop platforms for new technologies, and those platforms need also to be supported by the right safety standards.”

However, these are not the only refrigerant regulations taking place in the EU. PFAS restrictions are also being developed, which could result in many refrigerants being banned, including the low-GWP alternatives that were developed in response to the HFC phasedown.

PFAS, which stands for per- and polyfluoroalkyl substances, are man-made chemicals that are prized for their high resistance to heat, water, and oil. They are useful in many applications, including nonstick cookware, clothing, and refrigerants used in air conditioning and refrigeration equipment. However, their widespread presence in water, soil, and air samples has raised concerns about their potential impacts on human health and the environment.

The problem is that PFAS describe more than 12,000 different substances, which makes them very difficult to regulate. And should all these substances be banned, it would be a challenge to maintain our modern lifestyle, said Funder-Kristensen.

“The EU is in the process of making restrictions on the use of PFAS,” he said. “The restriction proposal has been submitted, and industry organizations are working on submitting feedback that would explain where we use those substances as well as what would be the alternatives in case substitutes are needed. We will know more about the outcome of the total process in 2025, and the target for the first really early bans to kick in would be 2027.”

Again, European HVACR manufacturers are sounding the alarm, noting that should the proposal become effective, the 18-month transition period for switching to alternative options — many of which could be banned under the new F-Gas Regulation — would be impossible to meet. Uncertainty is high, said Funder-Kristensen, and stakeholders in the industry are really worried because of the considerable changes ahead.

Amazingly enough, there is no link between the F-Gas Regulation and the proposed PFAS restrictions — they are two separate regulations that are not harmonized. But in reality, they overlap, as they target the same substances — F gases, said Funder-Kristensen.

“This is really a very special situation,” he said. “We know that several of the ultra-low GWP refrigerants, like R-1234yf, will fall under the EU PFAS restriction, which could limit the choice of refrigerants for fulfilling the F-Gas Regulation. We have a high risk of having a double regulation, and if that happens, the one with the strictest measures will prevail.”

It is, as Funder-Kristensen noted, a “perfect storm moving toward us.”