The UK's largest independent industrial refrigeration engineering company.
Dr. Robert Lamb
Group Sales & Marketing Director
rlamb@star-ref.co.uk
Temperature Controlled Storage & Distribution
Brewing and Distilling
Brief history of the regulation
The EU F-gas Regulation has undergone significant evolution over nearly two decades, reflecting Europe’s increasing commitment to mitigating the environmental impact of fluorinated greenhouse gases.
Beginning in 2006, the first European F-gas Regulation (EC) No 842/2006, introduced essential foundations, including certification and leak checking requirements.
In 2014, the second European F-gas Regulation (EU) No 517/2014, marked a critical shift with the introduction of the F-gas quota system, a phase-down approach designed to reduce overall hydrofluorocarbon (HFC) consumption. This iteration also saw the imposition of Global Warming Potential (GWP) limits, pointing to the EU’s increasing ambition to mitigate the environmental impact of the refrigeration and cooling sectors.
Last year, in 2024, the third iteration of the European F-gas Regulation (EU 573/2024), which took effect on 11 March 2024, delivered the most stringent measures yet. These include a steeper phase-down trajectory to support meeting the 2050 climate change goals. The updated Regulation aligns with the EU Green Deal, the 2050 climate neutrality targets, and the Kigali Amendment to the Montreal Protocol. The Amendment calls for an 85% reduction in HFC use between 2019 and 2036 for developed countries and is projected to prevent up to 0.4°C of global warming by the end of the century.
The new European F-gas Regulation stipulates tighter bans on high GWP refrigerants in new equipment, servicing existing equipment and extended containment measures to include HFOs and mobile systems, with a target of net zero by 2050.
The 2014 F-gas Regulation set a phase-down schedule for HFCs that stopped at a 79% reduction from the 2015 baseline by 2030. In contrast, the new 2024 Regulation introduces a much steeper trajectory, targeting a 95% reduction by 2030. Particularly, it sets a significant cut in 2027, when the available quota will drop to just 10% of the 2015 baseline—a remarkable tightening compared to the previous target of 25% for the same year.
The new 2024 F-gas Regulation also broadens the scope and redefines the substances affected as ‘fluorinated greenhouse gases’ (GHGs) – extending beyond HFCs. The change prevents chemical suppliers from altering gas name conventions and definitions to circumvent any HFC-specific regulation. The new Regulation therefore covers a wider array of fluorinated greenhouse gases, including HFCs, HFOs, PFCs (perfluorocarbons), and other fluorinated substances.
Additionally, it is worth noting that HFC and HFO manufacturers are under increasing scrutiny due to environmental concerns over PFAS, persistent chemicals that do not break down in nature and are harmful to human health. Most F-gases and fluoropolymers used by the sector are considered as PFAS according to the Organisation for Economic Co-operation and Development (OECD) chemical definition.
To date, a number of European countries have made a proposal for a broad ban at EU level on all PFAS. This is currently being dealt with under the REACH Regulation, the main EU law to protect human health and the environment from the harmful effects of chemicals.
Additionally, on 10th April 2025, the UK government’s Environmental Audit Committee (EAC) announced a new enquiry into the risks and impacts of PFAS substances to ask what the government should do to strengthen the UK’s approach. This leaves the door open for further legislation affecting the use of low GWP HFCs and HFOs, which might be implemented in the near future.
This latest regulation represents a critical inflexion point for the cooling industry, demanding accelerated adoption of low-GWP alternatives.
The UK Perspective on the European F-gas Regulation 2024
The UK currently still follows the retained Regulation (EU) 517/2014 framework. Any new phase-down steps or bans (2025, 2030, etc.) will take effect in the UK when the UK government implements equivalent legislation. It is important to note that industry experts expect that the UK will align in principle, but this is not yet confirmed, and it is currently under review.
As the UK Government evaluates amending the regulation to set more challenging targets in line with the new EU F-gas Regulation, The Climate Change Committee (CCC) published its Seventh Carbon Budget (CB7) report on 26th February 2025, advising the UK to align its regulations with EU standards. Under the Balanced Pathway, this could require a 73% reduction in F-gas emissions by 2040 compared to 2022 levels. This could result in potential refrigerant shortages and rising prices due to restricted quotas.
Key measures of the new F-gas Regulation
The new quota system introduces a steeper reduction in the amounts of HFCs (in CO₂-equivalent) that importers and producers may place on the EU market. With a more aggressive schedule, the new regulation mandates a 95% reduction by 2030 and a full phase-out by 2050.
This schedule exceeds EU obligations under the Kigali Amendment to the Montreal Protocol, which for developed countries mandates 15% of baseline by 2036.
Below are two graphics showing the maximum amount of HFCs allowed to be placed on the EU market each year under the F-Gas Regulation 2024 and the F-Gas Regulation 2014, allowing for comparison between the two.
HFCs used in metered dose inhalers are now included within the EU’s F-gas quota system. This will mean increased competition for quota due to greater demand for a limited supply of HFCs, tightening availability and putting upward pressure on prices. This might also affect the supply chain, and businesses might experience reduced allocations or delayed access, especially during peak periods, as medical applications are typically prioritised for health and safety reasons.
Additional prohibitions on F-gas equipment, products and use of F-gases also apply.
The Regulation covers additional equipment and gases, expanding measures to prevent leakage during transportation, installation, servicing, and disposal of equipment and products.
More digitalisation and electronic automation of customs control will allow enhanced enforcement and monitoring in the Member States and combat illegal trade.
Starting in 2025, producers will receive rights equivalent to 60% of their average annual production from 2011 to 2013. This rate will decline to 30 % by 2033, 20% by 2035, and to only 15% by 2036. For users of f-gases in practical terms, this means that HFCs will become increasingly scarce and prices will increase due to reduced supply and high demand. Operators of refrigeration and heating equipment will be under more pressure to switch to natural refrigerants and invest in systems designed for long-term compliance.
Why does the F-gas Regulation exist and what has it achieved?
The origins of the EU’s first F-gas Regulation (2006) can be traced back to the Kyoto Protocol (1997) under the UNFCCC, which was the first international agreement to identify HFCs as greenhouse gases and subject them to climate regulation. Although the Kyoto Protocol addressed HFCs, it lacked the tools and global consensus needed to reduce them effectively.
In response, an amendment to the Montreal Protocol, which was originally signed in 1987 and ratified by 197 countries, was introduced under the Kigali Amendment (2016). It leveraged the proven framework of the Montreal Protocol to tackle HFCs more efficiently and inclusively.
The hole in the ozone layer has significantly decreased since the late 1980s, following global action under the Montreal Protocol. This landmark agreement aimed to phase out ozone-depleting substances after scientists confirmed that man-made chemicals were damaging the ozone layer, a crucial part of the atmosphere that shields life on Earth from harmful ultraviolet (UV) radiation. Building on its success, the Kigali Amendment extended the Protocol’s scope to include the phase-down of HFCs, potent greenhouse gases that, while not ozone-depleting, contribute significantly to climate change. The Kigali Amendment is expected to prevent up to 0.4°C of global warming by 2100, making it one of the most impactful climate measures available.
The Montreal Protocol regulates the production and consumption of nearly 100 man-made chemicals linked to ozone destruction and depletion such as chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs). One widely used ozone-depleting substance was R22, an HCFC refrigerant, which was banned in the UK in 2015 and experienced a major phase-down in the years leading up to the ban. The overall usage of ozone-depleting substances (ODS) has been successfully minimised as a result of the Montreal Protocol and is continuing to trend downwards for the remaining few technologies with a reliance on ODP substances. Models created for 2065 projected that the hole is on the path to recovery but had the world not banned these gases through the Montreal Protocol, the ozone hole would have increased in size to have global coverage by 2040. This could be considered a worldwide ‘near miss’ event, which was only prevented by the actions of humanity – a notable case study for why the F-gas Regulation is now of utmost importance to the human race.
The above image published on earthobservatory.nasa.gov from a snapshot on May 21, 2009, shows computer predictions of what would have happened to the ozone layer over the mid-latitudes of the Western Hemisphere if CFCs had not been banned by the Montreal Protocol. Low Ozone Concentration corresponds to lower UV protection.
F-gas refrigerants and F-gases
F-gases are man-made fluorinated gases, such as HFCs and HFOs, and are often hundreds or even thousands of times more potent in terms of global warming effect than CO2.
The new F-gas Regulation 2024 also includes other F-gases commonly used in industrial manufacturing processes such as perfluorocarbons (PFCs), sulphur hexafluoride (SF6) and nitrogen trifluoride (NF3), and aims to reduce overall emissions across all manufactured gases. These gases are used as propellants in medical inhalers, aerosol spray cans, fire extinguishers, high-voltage switchgear, and as blowing agents for foams.
F-gases come in toxic and low toxic forms, and variable flammability (non-flammable, low flammability and high flammability).
It is important to note that the descriptors for toxicity and flammability are defined under specific controlled conditions. Under the Dangerous Substances and Explosive Atmospheres Regulations (DSEAR, 2002), no distinction is made between ‘low’ and ‘high’ flammability -both are simply classified as flammable. Furthermore, so-called ‘low-toxic’ refrigerants still carry their own oxygen deprivation level (ODL) and Acute Toxicity Exposure Level (ATEL) under ISO 817:2014 and are harmful to human health if concentrations surpass specific levels in an occupied space.
HFCs represent around 90% of F-gas emissions, and they are used as refrigerants in refrigerators, freezers, air conditioners, and heat pumps.
Since the updated F-gas Regulation covers all fluorinated gases, gas manufacturing quotas will be impacted as all industries will be in competition.
The graph below shows what would have happened without the introduction of the measures instituted by the F-gas Regulation over time, highlighting the volume of fluorinated gases in the atmosphere.
What does this mean for businesses using industrial F-gas refrigeration equipment?
F-gas Regulation Equipment Bans
The European F-gas Regulation sets stringent market prohibitions on systems containing refrigerants.
All self-contained refrigeration equipment using refrigerants above 150 GWP will be banned from 2025, and this ban will extend to all other equipment by 2030.
A ban on placing chiller equipment onto the market containing gases with a GWP equal to or higher than 750 comes into effect from 2027.
Recent trends in large industrial refrigeration systems of over 200 kW show a shift towards zero GWP refrigerants (ammonia) and very low GWP refrigerants such as CO2, hydrocarbons and HFOs (the fourth generation of fluorine-based gases), following the progressive bans on HCFCs, CFCs and HFCs.
Technological innovations such as the advent of low-charge ammonia cooling equipment, industrial CO2 refrigeration systems and more strict health and safety requirements have made the shift to natural solutions possible in sectors where HFCs were traditionally used. Overall, natural refrigerants offer a future-proof solution which will not be subject to future regulatory changes.
Ammonia remains the most widely used option due to its high efficiency, while carbon dioxide is seeing increasing adoption, particularly in cascade and transcritical systems. Hydrocarbons are used selectively, especially in chillers and specialised refrigeration setups where flammability risks can be effectively managed.
HFOs with a GWP of less than 3 are seen in industrial chillers as a low GWP alternative to HFCs.
F-gas Regulation Service Bans
As of January 2025, a ban on using virgin HFCs to service existing refrigeration equipment that uses a refrigerant with a GWP of 2,500 or more applies. By 2032, the restriction drops to refrigerants with more than 750 GWP.
Additionally, from 2030 onwards, a restriction on the service of equipment with refrigerants with a GWP of more than 2,500 for reclaimed/recycled refrigerants will apply.
F-gas Leak Detection
Under the updated F-gas Regulation, all stationary equipment containing fluorinated greenhouse gases must be leak-checked regularly, with the frequency depending on the type and amount of F-gas used.
For systems containing HFCs, leak checks are required every 12 months if the charge is under 50 tonnes CO₂ equivalent, and every 6 months if between 50 and 499 tonnes CO₂e. For systems with 500 tonnes CO₂e or more, checks must be carried out every 3 months. However, if a fixed leak detection system is installed, the frequency of checks can be halved, meaning inspections would only be required every 24, 12, or 6 months, respectively.
For systems using HFOs, similar rules apply but are based on kilograms rather than CO₂ equivalent. Leak checks are required every 3 months for systems with under 10kg, every 6 months for 10kg to 99kg, and every 3 months for 100kg or more—again, with the option to halve these frequencies if a detection system is installed.
Importantly, a leak detection system becomes mandatory when a system contains 500 tonnes CO₂e or more of HFCs, or 100kg or more of HFOs. For systems below these thresholds, installing one is optional but allows operators to reduce how often manual checks are needed.
Illegal trading
The EU F-gas Regulation introduces several new measures aimed at tackling illegal trading, improving traceability, and strengthening enforcement. A key development is the enhanced connection between the F-gas Portal and the EU Single Window Environment for Customs, enabling real-time verification of shipments against quota allocations and registrations—making it significantly harder to import F-gases illegally.
Market surveillance authorities have also been granted greater powers to enforce import and export bans, while Member States are now required to implement stricter penalties for non-compliance, including confiscation and seizure of illegal products.
Quota Tax
The Regulation introduces a mandatory quota price for placing HFCs on the market. From 2026, companies allocated HFC quota will be required to pay €3 per tonne of CO₂ equivalent. This marks a shift away from the previous system of free allocation and is intended to reduce speculative activity and improve the fairness of the system.
While €3 per tonne may seem modest, it introduces a new cost pressure on refrigerants -particularly those with a high global warming potential. For common HFCs such as R-134a, the added cost could equate to a price increase of around 10%, depending on market conditions. Combined with the ongoing phase-down of HFC availability, this new charge is likely to contribute to increased refrigerant prices and tighter market supply in the years ahead.
Recycling and Reclaiming
The Regulation requires that any refrigerant removed from a system during service must be recycled or reclaimed before it can be reused. Simply decanting and recharging the same gas is no longer permitted unless it has gone through a recognised processing system, including filtration, oil separation, and moisture removal.
Containers of reclaimed or recycled gas must be clearly labelled with either ‘100% Recycled’ or ‘100% Reclaimed’, along with a batch number and the details of the facility that carried out the processing. In addition, any operator handling more than 1 metric tonne or 100 tonnes CO₂ equivalent of reclaimed refrigerant annually must comply with new reporting obligations.
For users, these changes mean that routine maintenance involving refrigerant handling will need to be reviewed and likely adapted to ensure compliance, especially where high GWP refrigerants are still in use.
Increase in F-gas refrigerant prices
The European refrigerant market continued to show price volatility in Q4 2024, particularly for high GWP HFC refrigerants. Independent consultants Öko-Recherche, CiTEPA in cooperation with PROZON and CONAIF, carried out research on HFC pricing in the EU, in light of the HFC quota system put in place by the new F-gas Regulation 2024.
Data collected from producers and OEMs revealed important developments across the supply chain, indicating both price hikes and availability issues for certain refrigerants. This trend is expected to continue as HFCs quotas evolve downwards, with some suppliers reporting on the non-availability of R448A in Q4 2024.
The graphs below show:
Öko-Recherche. Compiled for the European Commission under Service Contract “Technical support for monitoring HFC price and phase-down evolution as a result of EU policies”. Service contract no. CLIMA.A2/SER/2020/0009MV. 6th report – Q4/2024. October 2024.
Market data for lower GWP alternatives also showed mixed results compared to Q3 2024:
These variations reflect ongoing shifts in demand as the industry transitions toward environmentally friendlier solutions.
Market Outlook
The regulatory changes impact a broad range of industries relying on industrial refrigeration and heat pump technology. Businesses still using HFCs and HFOs must prepare for:
How to ensure compliance and future-proof business operations
Businesses must take immediate steps to evaluate existing systems and develop a phased refrigerant transition plan. CO₂ transcritical, ammonia, and HFO-based systems offer long-term compliance and efficiency benefits.
With stricter leak detection thresholds in place, automated monitoring systems will be essential to minimise losses and maintain compliance. Preventative maintenance is now a regulatory requirement, and staff must be trained on proper refrigerant handling and system integrity.
By 2025, all personnel handling F-gases must complete updated certification programs covering natural refrigerants. Star Refrigeration provides specialised training to ensure teams can operate CO₂, ammonia, and hydrocarbon systems safely and effectively.
To mitigate risks associated with supply shortages, businesses should establish long term procurement agreements for reclaimed or alternative refrigerants. Investing in system upgrades ahead of major regulatory deadlines will ensure smoother transitions and cost savings.
Next steps
Historically, the F-gas Regulation has been widely regarded as an environmental success. The F-gas Regulation 2024/573 is reshaping the industrial refrigeration and heat pump landscape with a steeper phase-down to bring forward previous goals. The new regulation represents a 76% cut in HFC quotas by 2025. This then moves to a 95% cut in 2030. The ultimate goal is to progressively reduce F-gas quotas, with the aim of phasing out HFCs from the EU market by 2050.
The timeline for these cuts means that the market will be squeezed in terms of technology and refrigerant capabilities, likely leading to plant replacement or refrigerant retrofit programs to keep older equipment operational and compliant.
Many are now turning to natural alternatives, such as ammonia, CO2, and hydrocarbons, in order to future-proof their operations. There is also a push for HFOs, the new generation of man-made fluorine-based gases. However, these alternatives come with trade-offs. HFOs are mildly flammable, and many degrade into trifluoroacetic acid (TFA), a persistent byproduct that contributes to acid rain and may accumulate in groundwater, raising long-term environmental concerns. Currently, the EU is considering a sweeping restriction on PFAS under REACH, which could cover most fluorinated refrigerants. The proposal’s definition of PFAS is broad enough to include most HFC and HFO refrigerants, as well as some fluoropolymer components. Additionally, the UK government’s Environmental Audit Committee (EAC) has launched an enquiry into their future viability. It is therefore likely that future regulations could introduce limitations or bans on chemicals responsible for their production.
In the short-to-medium term, as F-gas quotas and overall volume reduce over time, the market competitiveness will steepen. Some industries will be able to afford higher premiums for F-gas usage, but others will be more negatively affected.
As we go further along the timeline, the cooling sector will have to navigate some potential challenges, including competition for quota with other high value markets such as the pharmaceutical and high-voltage electrical industries. Despite these challenges, and given the urgency of the climate crisis, the new F-gas Regulation phase-down is an obvious necessity to eliminate substances that contribute to global warming, and an essential step in the journey to Net Zero.
This article has been CPD certified by the International CPD Certification Service. To obtain your CPD Diploma, please email cpdcertificate@star-ref.co.uk.
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