Europe’s 2026 summer brought prolonged heat and high heat stress in parts of the continent. Copernicus reported that at least 60% of western Europe experienced temperatures above 30°C on 17 days during the summer, compared with 11 days in 2003 and seven in 2025. These observations describe the weather; they do not, by themselves, show how much refrigerant or cooling equipment was sold. They do, however, give operators a reason to review how their cooling systems are maintained and supplied before the next peak season.

For commercial and industrial operators, seasonal preparation starts with the equipment already installed. Cooling systems must be ready to operate when required, and service teams need access to the correct refrigerant and documentation. At the same time, the EU HFC quota system is moving into a substantially lower phase-down period in 2027. Planning should therefore connect operational needs with the regulatory requirements that apply to the gas and equipment.

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Start with the installed equipment

A refrigerant plan begins with an accurate system inventory. Operators should know which sites have refrigeration, air-conditioning or heat-pump equipment, what refrigerant each unit uses and how much the system contains. Maintenance and service records can help identify recurring issues and the refrigerants required for scheduled work.

This information supports several practical decisions. It helps the operator distinguish equipment using HFCs from systems using other refrigerants, identify units that may need repair or replacement, and provide suppliers with clearer requirements. A record of the refrigerant type and charge also helps when checking quota coverage or assessing product restrictions.

The Commission’s F-gas Regulation applies to specified fluorinated gases and to products and equipment containing them or whose functioning relies on them. The HFC quota system applies to the placing on the EU market of the HFCs listed in the Regulation. It does not mean every refrigerant, every cooling system or every end user is treated in the same way.

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Review service requirements before the season

Seasonal readiness includes planned maintenance, leak checks where required, and a process for handling repairs. Operators should check that maintenance providers have the information they need about the equipment and refrigerant, and that records are kept for work completed.

The aim is to know what service may be required and what supply arrangements support it. This is different from predicting that a particular heatwave will cause a shortage or a price increase. Those outcomes cannot be established from weather records alone.

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A useful review includes:

• checking equipment lists against maintenance records;

• confirming the refrigerant and charge for each relevant system;

• identifying scheduled servicing and known repair requirements;

• recording which systems use HFCs covered by EU quota rules;

• agreeing how refrigerant will be sourced and what documentation will be provided.

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Where equipment is imported or refrigerant is placed on the EU market, obligations may apply to the importer, producer or other undertaking in the supply chain. The Commission’s guidance identifies quota coverage requirements for bulk HFCs and separate rules for equipment containing HFCs. The relevant responsibility depends on the transaction and the party’s role.

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Understand the 2027 quota step

The EU HFC phase-down schedule changes on 1 January 2027. Regulation (EU) 2024/573 sets the maximum quantity for 2027–2029 at 21,665,691 tonnes of CO₂ equivalent (CO₂e), compared with 42,874,410 tonnes of CO₂e for 2025–2026. The Commission allocates quota to eligible producers and importers through the F-gas system. Regulation (EU) 2024/573

The maximum is measured in CO₂e, not simply in tonnes of gas. Different HFCs have different GWP values, so their quantities contribute differently to the quota total. For procurement teams, this makes it important to record the refrigerant type and required amount rather than estimating need using an undifferentiated total mass.

The quota step is a regulatory limit on the quantity of covered HFCs that may be placed on the EU market. It does not set the price an individual buyer will pay, guarantee a shortage of a particular refrigerant or allocate quota directly to every operator. It also does not introduce a ban on servicing existing chillers. Buyers should distinguish those points when assessing supplier offers and planning service.

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Map the supply chain

Before the season begins, operators should confirm who supplies the refrigerant and who is responsible for the relevant compliance steps. A business that buys refrigerant from an EU supplier has a different role from one importing bulk HFCs itself. Importing pre-charged equipment can also involve separate obligations.

The Commission’s F-gas Portal is used for HFC quota management, import and export requirements and reporting. It contains information on quotas and authorisations, and relevant transactions must be recorded through the portal. The Commission also states that portal registration does not guarantee that private contractual commitments will be fulfilled. Buyers should therefore conduct due diligence on both compliance documentation and commercial terms.

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For operators, useful supplier checks include:

• what refrigerant is being offered and in what quantity;

• whether the supplier can provide the relevant compliance documentation;

• which undertaking is responsible for quota coverage or equipment authorisation;

• how delivery timing and any conditions are stated in the contract;

• what the supplier’s process is for communicating changes to an order.

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These checks do not guarantee supply or set market prices. They clarify responsibilities and reduce the risk of discovering, during urgent service work, that the product or documentation does not match the requirement.

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Separate refrigerant supply, servicing rules and equipment restrictions

HFC quota limits, servicing restrictions and equipment restrictions are separate regulatory controls. The quota system limits the quantity of covered HFCs placed on the EU market, measured in CO₂e. Article 13 governs specified uses of fluorinated gases, including maintenance and servicing. Article 11 and Annex IV govern restrictions on placing particular products and equipment on the market.

Article 13 does not introduce a chiller-specific servicing ban on 1 January 2027. The chiller restrictions taking effect on that date concern placing specified stationary chillers on the market under Article 11 and Annex IV. They do not create a blanket prohibition on operating or servicing existing chillers. Regulation (EU) 2024/573

For seasonal planning, operators should assess existing equipment against the servicing rules applicable to its refrigerant and use. When purchasing replacement equipment, they should separately check the relevant Annex IV requirements, including capacity, refrigerant GWP and applicable exceptions.

The 2027 HFC quota reduction adds a separate procurement consideration. It lowers the overall CO₂e allowance for covered HFCs entering the EU market, but does not itself prohibit servicing existing chillers or establish how much a particular refrigerant will cost.

Keeping these distinctions clear helps operators plan maintenance, refrigerant procurement and equipment replacement against the correct requirements. A buyer should not assume that quota availability proves a new unit complies with product restrictions, or that a restriction on placing new equipment on the market requires an existing unit to be taken out of service.

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Prepare a seasonal procurement file

A short, current procurement file can make seasonal planning more reliable. It should bring together the site and equipment inventory, refrigerant requirements, service schedule, supplier details and compliance records.

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For each purchase or planned service, record:

1. Equipment details: site, unit type, model and refrigerant.

2. Quantity required: expected refrigerant charge or service quantity, with units clearly stated.

3. Supply route: supplier, importer and destination market.

4. Compliance evidence: quota coverage, equipment authorisation or other documentation where applicable.

5. Timing and contract terms: requested delivery date and the supplier’s confirmed terms.

6. Service records: maintenance, repairs and refrigerant additions or recovery.

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A file like this gives procurement, facilities and compliance teams the same reference point. It also allows an operator to compare a new requirement with previous consumption and service records without assuming that one season will match another.

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Use weather information carefully

Weather information can help operators review preparedness, but it should not be used as a substitute for actual system and procurement data. Copernicus’s 2026 summer findings document heat conditions across Europe; they do not measure refrigerant sales, equipment purchases or the availability of HFCs. Copernicus

For planning, operators can use weather scenarios to review operating procedures and maintenance readiness. Procurement decisions should be based on the installed base, recorded service requirements, supplier confirmation and applicable quota rules. This keeps the distinction clear between a documented climate observation and a commercial forecast.

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Prepare before cooling is needed

Peak-season preparation is most effective when it starts with verified information: which systems are installed, what refrigerants they use, what service they require and how the supply chain will meet those requirements. The 2027 EU quota reduction adds a regulatory milestone for covered HFCs, while restrictions on placing specified new chillers on the market create separate checks for equipment purchases. Neither should be confused with a chiller-specific servicing ban beginning in 2027.

AFS Cooling supports businesses with refrigerant procurement, quota management, compliance and documentation. To review your refrigerant requirements ahead of the next cooling season, contact AFS Cooling.