New F-gas proposal published

New F-gas proposal published

The proposed new F-gas regulation[1] was published in April. This proposes to update the current regulation which were implemented in 2006 and updated in 2015. The proposed new regulation is designed to strengthen the previous measures and introduce new measures.

In particular the proposal is intended to enhance the ambition of the regulation by a tighter quota system for HFCs which will reduce the HFCs placed on the market by 98% by 2050 (compared to 2015, based on MtCO2e). It will also improve enforcement and implementation and apply harsher penalties for non-compliance. Monitoring will be more comprehensive with enhanced reporting and verification procedures. The proposed regulation also includes HFOs (alongside HFCs) for prevention of emissions, leak checks, record keeping, recovery and labelling.

The proposed new regulation has received mixed support from trade organisations. The fact that it includes a ban on split system AC and heat pumps under 12 kW containing refrigerants with a GWP of over 150 by 1 January 2027 has been negatively received by many manufacturers. They claim this gives little time to change to an alternative refrigerant and may even delay the uptake of heat pumps. It is also proposed that on the same date there will be a ban on split systems of a rated capacity of more than 12 kW containing refrigerants with GWP of 750 or more. Both these requirements contain the clause 'except when required to meet safety standards'. It is rather unclear on how this should be applied and is a major question that needs clarification.

Regarding commercial, professional and domestic refrigeration, there are changes associated with the use of all fluorinated greenhouse gases and links to refrigerants listed in Annex 1 of the proposed regulation. Specifically:







Refrigerators and freezers for commercial use (self-contained equipment)

- that contain other fluorinated greenhouse gases with GWP of 150 or more

1 January 2024

Now includes ‘other fluorinated greenhouse gases’


Any self-contained refrigeration equipment

- that contains fluorinated greenhouse gases with GWP of 150 or more

1 January 2025

New clause


Stationary refrigeration equipment

- that contains, or whose functioning relies upon, fluorinated greenhouse gases with GWP of 2,500 or more except equipment intended for application designed to cool products to temperatures below – 50 °C

1 January 2024

Now includes ‘other fluorinated greenhouse gases’


Multipack centralized refrigeration systems for commercial use

- with a rated capacity of 40 kW or more that contain, or whose functioning relies upon, fluorinated greenhouse gases listed in Annex I with GWP of 150 or more, except in the primary refrigerant circuit of cascade systems where fluorinated greenhouse gases with a GWP of less than 1,500 may be used

1 January 2022

Link to Annex 1 added


Although the UK is no longer part of the EU, the existing F-gas regulation is applied in the UK as the Fluorinated Greenhouse Gases Regulations 2015. The UK is expected to prepare an update to these regulations later this year. It is not clear whether the UK will mirror the European F-gas regulation. Previously the UK Government has stated that it is committed to match any changes introduced by the European Commission. However, some reports suggest that the UK could expand the UK regulation to all greenhouse gas refrigerants rather than just F-gases.

The proposed regulation may present some new future challenges for the industry. It should also not be forgotten that recent changes in January 2022 to refrigerators and freezers for commercial use (hermetically sealed equipment) were applied. These require that such equipment containing HFCs must have a GWP of less than 150. We reported in our December 2021 newsletter ( that many systems that were apparently hermetically sealed were available on the market containing R134a (GWP of 1,430), R452A (GWP of 2,140) and R404A (GWP of 3,922) and that manufacturers had a challenge to convert equipment to low GWP alternatives in time for the January 2022 deadline. A current assessment shows that much of this equipment is still available on the market for apparent sale. Therefore, the industry faces not only future challenges but in many cases still needs to act on the current regulation to convert equipment to lower GWP alternatives as well.

If you would like further information on the latest F-gas proposals or advice on how to convert equipment to lower GWP alternatives, please contact Judith Evans at RD&T (

[1] Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014

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