The F-gas Regulation is part of the EU’s environmental policy aim of protecting the environment by reducing emissions of fluorinated greenhouse gases. The latest revision of the F-gas regulation entered into force in March 2024.

Phase down

The maximum quantity of HFCs available to be allocated as quotas for producers and importers from 2025 to 2050, in percentage terms with respect to the 2015 base-value, is represented in the following graph:

Maximum amount of HFC refrigerants, in percentage with respect to the baseline, allowed to be placed on the EU market in the period 2025-2050

It should be highlighted that the quota is applied only to HFC refrigerants, thus HFOs are not included. A mixture is considered to be an HFC if it contains an HFC refrigerant even if the proportion is small.
It should also be noted that the quota system has been extended to MDIs (metered dose inhalers) from January 2025, which means that a part of the quota will not be available for the RACHP sector.

Bans on placing on the market

The new F-gas regulation introduces new bans on the use of refrigerants for specific applications. One important introduction is that, in some cases, the use of any fluorinated refrigerant will be prohibited. Other bans are based on the extent to which the refrigerant contributes to global warming, in terms of GWP, as in the previous version of the F-gas. All these restrictions impact ACHPs, refrigeration units and chillers. The table below also shows the restrictions on the use of fluorinated refrigerants for these applications:

Refrigerants that will be allowed in different RACHP applications starting from 2025 according to the new F-gas regulation

*except when required to meet safety requirements
**when safety requirements would not allow using fluorinated greenhouse gases with GWP of 150 or less, the GWP limit is 750

In addition to these bans, a GWP limit of 1000 on fluorinated gases will be set for the export of stationary RACHP equipment. It came into force on 12 March 2025. 

The use of fluorinated refrigerants in the US is regulated by The American Innovation & Manufacturing Act (AIM Act), signed in December 2020. According to this act, the US Environmental Protection Agency (EPA) has the authority to regulate HFCs in three ways: phasing down production and consumption, facilitating the transition to next-generation technologies through sector-based restrictions, and regulating refrigerant management.

Phase down of HFCs

In line with the Kigali Amendment to the Montreal Protocol, the objective of the AIM Act is to phase out the production and consumption of HFCs in the US by 85% before 2035. As shown in the following graph, the allowance limits have been reduced from 90 to 60% in 2024, the biggest reduction so far. The next step will be in 2029 (30%), followed by further reductions in 2034 (20%) and 2036 (15%).

HFC phase down schedule in the period 2020-2040 according to the AIM Act

Regulatory Actions for Technology Transitions

The final rule “Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons under Subsection (i) of the American Innovation and Manufacturing Act of 2020” was signed on 5 October 2023. This rule restricts the use of high GWP HFCs in new aerosol, foam, and RACHP products and equipment. In most applications, the EPA has set a maximum GWP limit on HFCs or HFC blends that can be used, whereas in a few applications, the EPA has listed the specific HFCs or HFC blends that are restricted. It should be noted that the restrictions affect the sale, distribution, and export of products three years after the manufacture/import restriction dates.

The following table shows the GWP limits and the year of banning for the manufacture, import and installation of ACHPs, refrigeration units and chillers.

Restricted products in the USA for RACHP according to the GWP values of the refrigerants contained in such products

Note that the interim final rule provides one additional year for the installation of new residential and light commercial ACHP systems when using components that were manufactured or imported before 2025. It should be also highlighted that residential ice makers are not included in the household refrigerator and freezer subsector and are not subject to the restrictions indicated in the previous table.

The following table shows specific HFCs or HFC blends that are restricted by the AIM Act:

Refrigerant banned in the USA for refrigeration applications in the next years

Manufacturers must ensure that, in addition to meeting the restrictions set under the AIM Act Technology Transition Rule, they also comply with the EPA’s Significant New Alternatives Policy (SNAP) regulations. The SNAP program reviews substitutes on the basis of the environmental and health risks, including factors such as ODP and GWP, toxicity, flammability, and exposure potential within a comparative risk framework of different industrial sectors, including refrigeration and AC.

Finally, it should be highlighted that there are some states, such as California, New York and Washington that go beyond the SNAP rulings and impose stricter GWP limits in some applications.

This regulation addresses issues throughout the lifecycle of fluorocarbons. It classifies refrigerants according to their GWP and specifies the date these are banned for each application:

Other requirements that HVAC/R equipment should comply are enumerated in the following:

• indications and label to designated products (showing “non-F-gas using” or degree of achievements to the target GWP value, target year and target GWP value, GWP value of the refrigerant used in the products), with the purpose of promoting designated products using low-GWP or natural refrigerant;
• regular leak checks, call service to arrange repairs before refilling as soon as leakages are found, record maintenance, and disclose to maintenance operators, etc;
• calculation of the annual F-gas leakage amounts. If that amount exceeds 1,000 tonnes of CO₂ equivalent, users, as a company, need to report it to the relevant competent ministries, with information on the offices and factories from which the leakage was detected. The Ministry of the Environment (MOE) and the Ministry of Economy, Trade and Industry (METI) will notify the relevant municipal and prefectural governors on the results and the names of the companies, etc., and will publish them.

An accelerated phase-out schedule for HCFCs is planned. The steps are: reduction of 10% by 2015, reduction of 35% by 2020, reduction of 67.5% by 2025, reduction of 100% by 2030, allowance of 2.5% of baseline (2013 annual CO₂ - eq.) for the period 2030-2040, and complete phase out by 2040. The following table shows the recommended refrigerants that can substitute R-22 for each application according to Chinese authorities:

Recommended refrigerants in China for typical RACHP applications

Canada proposal indicates refrigerants that are banned from 2020 onwards for each application according to the value of GWP:

Regulations Amending the Ozone-depleting Substances and Halocarbon Alternatives Regulations in Canada

Australia’s HFC phase-down started in January 2018. The HFC phase-down in Australia means a gradual reduction in the maximum amount of HFCs permitted to be imported into Australia, as reduced imports lead directly to reduced emissions.

The HFC phase-down is being implemented through the “Ozone Protection and Synthetic Greenhouse Gas Management Act” and associated regulations through a quota system for imports of HFCs as bulk gas.

It should be noted that the HFC phase-down covers only imports of bulk gas such as in cylinders. This means that refrigerants imported in pre-charged equipment such as ACs or refrigerators are not included, because they are accounted for in the country of manufacture. Moreover, existing equipment that has already been imported into Australia is not affected by the phase-down.

As regards specific HFC prohibitions, the import and manufacture of small AC equipment using refrigerant with a GWP over 750 is prohibited in Australia from July 2024, including equipment that is imported without refrigerant. The ban will apply to equipment with up to a 2.6 kg refrigerant charge (per the compliance/rating plate), where it is intended for use in cooling, heating, or both heating and cooling, a stationary space, primarily for human comfort. However, similar AC equipment that is ducted, for mobile applications such as caravans and boats, or to systems for use in electrical enclosures and computer rooms are not included.