The heating, ventilation, air conditioning, and refrigeration sector is facing a profound regulatory transition under the European Chemicals Agency. Whilst the industry has focused heavily on the phase-down of hydrofluorocarbons under the revised EU F-Gas Regulation, a parallel regulatory framework is emerging under the Registration, Evaluation, Authorisation and Restriction of Chemicals framework.

The proposed universal restriction on per- and polyfluoroalkyl substances (PFAS), jointly submitted by Denmark, Germany, the Netherlands, Norway, and Sweden, threatens to restrict the manufacture, sale, and use of most synthetic refrigerants across the European Economic Area. As scientific committees finalise their evaluations in mid-2026, commercial operators must understand how these developments will shape the future availability of synthetic and natural refrigerants.

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Defining the Chemical Scope and the TFA Vector

The scope of the universal restriction proposal relies on a structural chemical definition. A substance is classified as a PFAS if it contains at least one fully fluorinated methyl or methylene carbon atom. This broad definition captures not only legacy HFCs but also the latest generation of synthetic hydrofluoroolefins (HFOs), such as R-1234yf.

Although HFOs possess an ultra-low Global Warming Potential and do not directly damage the climate, they degrade in the atmosphere to produce trifluoroacetic acid TFA is a highly mobile, persistent PFAS that accumulates in water bodies, soil, and plants, causing long-term environmental concerns and drawing intense scrutiny from European regulators.

However, the structural definition of PFAS means that certain synthetic F-gases are completely exempt from the REACH proposal. Substances that do not contain a perfluorinated methyl or methylene group are excluded from the ban. Most notably, this includes R-32 (difluoromethane) and R-152a (1,1-difluoroethane), both of which are prominent components of the AFS Cooling product portfolio.

Because R-32 does not degrade into TFA, it is positioned to remain a viable, PFAS-exempt synthetic option for air conditioning and heat pump systems, free from the threat of a REACH ban.

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RAC and SEAC: Scientific Opinions and Sector Feedback

The regulatory process reached a critical milestone in early 2026 with the publication of the final scientific opinions from ECHA’s key committees. The Risk Assessment Committee (RAC) adopted its final scientific opinion on 2 March 2026, strongly endorsing a broad, comprehensive restriction on PFAS.

RAC rejected industry calls to exclude volatile F-gases and fluoropolymers from the ban, arguing that the extreme persistence of these compounds in the environment justifies a precautionary approach. The committee concluded that emissions generated during the manufacturing and waste life-cycle stages of these substances present an unmanageable risk to human health and ecosystems.

In contrast, the Socio-Economic Analysis Committee (SEAC) agreed on a draft opinion on 26 March 2026, which attempted to balance environmental protection with industrial and economic realities. SEAC supports a broad ban in principle but recommends targeted, use-specific derogations where the immediate socio-economic costs of a ban outweigh the environmental benefits.

To gather evidence, SEAC launched a 60-day public consultation that concluded on 25 May 2026, attracting 3,511 comments from over 3,200 organisations. Over 6 percent of the feedback was focused directly on fluorinated gas applications, with manufacturers warning of severe operational disruptions and supply chain bottlenecks if synthetic HFOs are banned without adequate transition periods.

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Deciphering the Proposed HVAC-R Derogations

Based on the latest SEAC draft opinions, several time-limited and safety-related derogations are being considered to prevent immediate equipment shortages across the cooling sector :

• Low-Temperature Refrigeration: A time-limited derogation of 6.5 years post-entry-into-force (EiF) has been proposed for applications operating.

• Laboratory and Diagnostic Equipment: Systems such as refrigerated centrifuges and laboratory test equipment would receive a 13.5-year derogation post-EiF.

• Maintenance of Existing Systems: To protect massive capital investments, SEAC supports a 13.5-year derogation post-EiF for refilling and maintaining existing HVAC-R systems, provided they were installed before the restriction took effect and no viable, non-PFAS "drop-in" alternative is available.

• Building Code and Safety Restrictions: SEAC recommends a time-unlimited derogation for buildings and facilities where local safety standards or building codes completely prohibit the use of flammable natural alternatives.

While these derogations offer short-term relief, they represent a temporary delay rather than a permanent solution. Once the derogation periods expire, stationary systems relying on PFAS-classified HFOs like R-1234yf will face strict phase-outs, forcing a long-term shift toward alternative technologies.

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Strategic Migration with AFS Cooling

With SEAC scheduled to finalize its opinion by the end of 2026, and the European Commission expected to draft formal legislation for a vote by Member States in 2027, the commercial window for strategic planning is narrowing. Businesses must evaluate their cooling infrastructure today to avoid future regulatory and chemical obsolescence.

AFS Cooling assists businesses in navigating this complex regulatory landscape by offering a diversified portfolio of both synthetic and natural refrigerants. For applications where synthetic options remain highly desirable, AFS Cooling secures robust supplies of PFAS-exempt gases like R-32, ensuring compliance with both the F-Gas phase-down and the upcoming REACH restrictions.

Simultaneously, AFS Cooling is a key partner in the transition to natural refrigerants, which are completely exempt from the PFAS definition. By procuring high-quality natural gases such as propane (R-290), carbon dioxide (R-744), and ammonia (R-717), AFS Cooling helps businesses future-proof their operations.

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Partnering with AFS Cooling provides operators with the market intelligence, quota management, and procurement strategies needed to build resilient, compliant, and sustainable cooling networks.