In the HVACR sector, meaningful change rarely arrives overnight. Instead, it accumulates through regulation, industrial strategy, and supply-chain decisions that quietly reshape market realities long before their full consequences become visible. Now that 2026 is underway, it is becoming increasingly clear that many of the constraints defining today’s operating environment were embedded years in advance.

Regulatory pressure on fluorinated gases, long signalled through EU climate policy, has now entered a more decisive phase. Refrigerant options are narrowing, quota volumes are tightening, and manufacturers are accelerating platform transitions. These forces are no longer abstract future risks. They are shaping procurement decisions, equipment availability, and service continuity across the entire HVACR value chain.

Rather than relying on projections or policy headlines, current market data offers a more precise picture of where the industry stands. It shows that 2026 is not the beginning of a refrigerant transition, but the point at which its structural consequences are becoming operational realities.

‍

Regulation Has Entered a More Constrained Phase

Recent monitoring of the EU F-gas framework confirms that regulatory mechanisms are now materially reshaping market behaviour. According to analysis from the European Topic Centre on Climate Change Mitigation, total HFC volumes placed on the EU market in 2024 remained well below the regulatory cap, while overall F-gas supply measured in CO₂-equivalent terms has fallen by approximately 45% compared with 2015 levels.

This reduction is not merely symbolic. It reflects tangible supply contraction driven by quota enforcement, import controls, and declining domestic production. In physical terms, EU HFC manufacturing output has fallen by more than 70% relative to historic baselines, underscoring the extent to which regulatory ambition is translating into industrial reality.

The most significant inflection point, however, lies ahead. Under Regulation (EU) 2024/573, permitted HFC quota volumes are scheduled to fall by roughly 50% in 2027. Unlike earlier phase-down steps, which allowed gradual market adaptation, this represents a step change in supply availability. The implications are substantial: markets will not simply adjust incrementally, but will confront a sharp tightening of permissible refrigerant volumes.

This places 2026 in a strategically critical position. Refrigerant platforms selected today, equipment designs approved this year, and supply agreements signed now will largely determine organisations’ exposure to the far more restrictive quota regime approaching in 2027 and beyond.

For segments of the HVACR market that continue to rely on high-GWP refrigerants, regulatory pressure is no longer a distant concern. It is approaching a clearly defined threshold that will materially affect product availability, servicing feasibility, and long-term operational continuity.

‍

Refrigerant Choice Is Becoming a Strategic Constraint

Market data illustrates how the industry is responding. Refrigeration, air conditioning, and heat pump applications (RACHP) remain the dominant users of F-gases by physical volume, accounting for approximately 71% of total EU supply in tonnes in 2024. However, when measured in CO₂-equivalent terms, their share falls to around 43%, highlighting the rapid substitution of high-GWP refrigerants with lower-impact alternatives.

This divergence between physical volume and climate impact is instructive. It demonstrates that the industry’s primary response to regulatory tightening has not been to reduce equipment deployment, but to transform refrigerant platforms.

In stationary RACHP equipment, imports increasingly favour lower-GWP refrigerants such as R32, CO₂, propane (R290), and emerging A2L blends. The progressive displacement of R410A and HFC-134a is now evident across residential, commercial, and light-industrial segments.

In practical terms, refrigerant selection has shifted from being a technical design choice to a strategic business constraint. It directly influences:

• Quota exposure for manufacturers and importers

• Long-term regulatory compliance

• Equipment market access

• Servicing economics over the system lifecycle

For OEMs, refrigerant choice increasingly determines whether product platforms remain viable beyond the next regulatory milestone. For contractors and asset owners, it dictates the availability and affordability of service refrigerants, shaping maintenance costs and operational risk profiles for years to come.

‍

Supply-Chain Data Reveals Where Adjustment Is Occurring

Trade and production statistics offer valuable insight into how the market is adapting.

EU production of fluorinated gases has declined sharply, with HFC output in 2024 approximately 72% lower than historic peak levels. Total F-gas supply peaked in 2014–2015 and has trended steadily downward since the introduction of the phase-down regime, including a further 11% reduction in physical supply between 2023 and 2024.

Import patterns reveal a more nuanced story. While bulk HFC imports have contracted significantly, imports of F-gases embedded within HVACR equipment have remained broadly stable in physical terms. In fact, total equipment imports measured in tonnes were marginally higher in 2024 than in 2023, even as their CO₂-equivalent footprint declined slightly.

This indicates that market contraction is not occurring at the level of equipment deployment. Instead, the adjustment is being absorbed upstream, through:

• Refrigerant platform changes

• Equipment redesign

• Component-level innovation

• Manufacturing optimisation

In other words, compliance risk and quota exposure are increasingly embedded into product architecture long before systems reach installers or end users.

This shift has profound implications. It means that regulatory alignment is now largely determined at the design and manufacturing stage. Downstream actors, including contractors and facility operators, inherit the consequences of upstream decisions over which they have limited direct influence.

‍

The Installed Base: A Structural Constraint on Transition Speed

Despite accelerating adoption of low-GWP refrigerants in new equipment, the global installed base remains heavily reliant on legacy gases.

Commercial chillers, VRF systems, rooftop units, and large refrigeration plants typically operate for 15 to 30 years. As a result, millions of systems across Europe and beyond will continue to require R410A, R404A, R134a, and other high-GWP refrigerants well into the 2030s.

This creates a structural tension:

• Regulators are compressing supply to meet climate targets.

• Installed systems require long-term servicing support.

The result is rising scarcity, price volatility, and heightened compliance risk in service refrigerant markets. Contractors increasingly report procurement challenges, unpredictable lead times, and escalating costs, particularly during peak seasonal demand.

For asset owners, this translates directly into higher operating expenditure and growing uncertainty around service continuity. In mission-critical environments such as data centres, healthcare facilities, food logistics hubs, and industrial production sites, refrigerant availability is becoming a material operational risk.

‍

Commercial and Operational Implications for Market Participants

Manufacturers and OEMs

For manufacturers, the regulatory environment is compressing product development timelines and narrowing technology choices. Platform decisions made in 2026 will determine market viability well into the next decade.

Failing to align product strategies with regulatory trajectories risks stranded investments, shortened product lifecycles, and loss of market access.

Contractors and Service Providers

Service companies are increasingly caught between regulatory compliance obligations and client expectations of uninterrupted system operation. Managing refrigerant availability, ensuring technician safety, and maintaining legal conformity now require more sophisticated procurement and inventory strategies.

System Owners and Investors

For asset owners, refrigerant exposure is emerging as a strategic risk variable alongside energy efficiency and carbon emissions. Equipment selection, retrofit timing, and service contracting models must now factor in:

• Long-term refrigerant availability

• Regulatory exposure

• Residual asset value

• Total cost of ownership

In investment-grade portfolios, refrigerant compliance is becoming a due-diligence parameter that can materially influence asset valuations.

Why 2026 Is a Strategic Decision Window

The convergence of regulatory tightening, supply contraction, and installed base realities makes 2026 a pivotal year for strategic planning.

Decisions taken now will determine:

• Exposure to 2027 quota compression

• Vulnerability to refrigerant price volatility

• Long-term service continuity

• Compliance risk across multiple jurisdictions

Waiting for regulatory deadlines to arrive will significantly limit available options. Proactive strategy development, by contrast, allows organisations to sequence equipment transitions, optimise procurement models, and stabilise refrigerant supply well ahead of market shocks.

‍

How AFS Cooling Supports Clients Through the Refrigerant Transition

AFS Cooling supports organisations across the HVACR value chain by integrating regulatory insight, quota management expertise, and secure refrigerant sourcing into a single strategic framework.

Strategic Refrigerant Advisory

AFS Cooling provides data-driven advisory services that enable clients to:

• Assess regulatory exposure across portfolios

• Model refrigerant transition pathways

• Align procurement strategies with regulatory timelines

• Anticipate future quota constraints

This allows businesses to replace reactive decision-making with structured transition planning.

Secure and Compliant Supply Solutions

Through established partnerships with leading producers and quota holders, AFS Cooling delivers:

• Legally compliant refrigerant sourcing

• Stable long-term supply arrangements

• Reduced exposure to spot-market volatility

• Assurance against counterfeit and non-compliant products

Quota Strategy and Market Intelligence

AFS Cooling supports clients in navigating quota systems, import controls, and regulatory reporting requirements, ensuring:

• Full compliance across EU and international jurisdictions

• Optimised quota utilisation

• Reduced administrative and legal risk

Transition Risk Mitigation

By integrating procurement planning, regulatory intelligence, and market monitoring, AFS Cooling helps clients:

• Maintain service continuity

• Stabilise cost structures

• Reduce compliance exposure

• Protect asset value

‍

Conclusion: Strategic Adaptation Is Now a Competitive Necessity

The HVACR sector is no longer operating in a transitional grey zone. Regulatory direction is clear, supply-chain adjustment is underway, and refrigerant scarcity is becoming operationally visible.

2026 represents a narrowing window in which organisations can still influence their exposure to the next phase of regulatory tightening. Those that treat refrigerant strategy as a core business function will be better positioned to manage risk, control costs, and preserve operational resilience.

Those that delay will find their choices increasingly constrained by quota ceilings, market volatility, and regulatory enforcement.

In this environment, proactive refrigerant strategy is no longer optional. It is becoming a defining component of competitive advantage.