Proposed stay of execution for refrigerant in PFAS ban

Fluorinated refrigerants including R-1234yf should be carved out of the European Union’s proposed universal PFAS restriction and instead regulated under the existing F-gas Regulation, according to a major study commissioned by the European Parliament’s Committee on Industry, Research and Energy (ITRE).

The report, which examined how per- and polyfluoroalkyl substances support EU industrial competitiveness, concluded that “substitution is not currently feasible given economic, technical, and safety constraints” for fluorinated gases used in refrigeration and air conditioning.

It recommended that all regulatory control of F-gases be consolidated into the existing F-gas Regulation rather than captured under a blanket PFAS ban.

“This will allow fostering the development of alternatives where possible in a more gradual way while still ensuring Europe retains the capacity to innovate in green technologies,” the report states.

For the Australasian automotive air conditioning sector, the recommendation represents a potential reprieve from the most disruptive regulatory scenarios.

Because Europe sets the pace in automotive standards and given the interconnected nature of global supply chains, a carve-out for refrigerants under EU rules would likely influence how jurisdictions including Australia and New Zealand approach PFAS regulation in the years ahead.

Regulatory milestone

The recommendation comes as the EU’s PFAS restriction proposal reaches a critical juncture. On 3 March 2026, the European Chemicals Agency’s Risk Assessment Committee adopted its opinion on the proposed restriction, concluding an extensive evaluation of PFAS hazards, volumes, emissions and the likely effectiveness of a ban.

The Committee for Socio-Economic Analysis is expected to agree its draft opinion soon, triggering a 60-day public consultation before adopting its final opinion by the end of 2026.

Two regulatory pathways remain under assessment: a full ban with an 18-month transition period, or a ban with longer time-limited exceptions including sector-specific carve-outs.

Under the updated proposal, sectors exposed to a complete ban would potentially face restrictions from 2027, with time-limited carve-outs of five or 12 years running to 2032 or 2039 respectively. 

That said, if final submissions are not received until late 2026, these timelines may be delayed, and  whether the EC adopts the ITRE study’s recommendation to exclude F-gases remains to be seen.

After meetings in Washington DC with the Air-Conditioning, Heating, and Refrigeration Institute, the Alliance, and the Sustainable PFAS Action Network, Refrigerants Australia executive director Greg Picker told SightGlass he had observed growing awareness among EU and US regulators of both the complexity and cost of blanket bans, as well as recognition that not all PFAS present the same risks.

What’s at stake

The PFAS restriction proposal, introduced in January 2023, targets more than 10,000 substances under the EU’s REACH regulation. If adopted in full without exemptions, it would result in a near-total ban on hydrofluorocarbons, hydrofluoroolefins, and certain fluoropolymers widely used in refrigeration and air conditioning systems – including seals, gaskets, and other critical components embedded deep within vehicle architectures.

For the mobile air conditioning sector specifically, refrigerants including R-134a and R-1234yf fall within the scope of the proposed restriction, potentially affecting most lower-GWP HFC and HFO blends under consideration for retrofitting R-134a systems with a non-flammable lower-GWP and non-flammable alternative as HFC quotas squeeze supply and prices rise.

The ITRE study focused on six fluoropolymers, which account for 93 per cent of fluoropolymer use in Europe. Its findings highlight the complexity of substitution across aerospace, defence, green energy, and semiconductor sectors, where alternatives are either limited or require long development cycles.

From a socio-economic perspective, the projected costs of a full PFAS ban across European industries are substantial: $A939.9 billion in the first year and $A121.6 billion annually thereafter.

Around 39,000 businesses and 2.9 million employees could be affected, of which around 90 per cent are in small and medium enterprises.

The TFA question

The push to restrict R-1234yf stems from concerns about trifluoroacetic acid,  formed when the refrigerant degrades in the atmosphere. A 2021 University of Bristol study reported that switching from R-134a to R-1234yf caused a 33-fold increase in the global burden of TFA, from 65 tonnes annually to 2200 tonnes from equivalent emissions. 

Surface TFA concentrations showed even more dramatic regional increases – up to 250-fold across Europe. The German Environment Agency has projected a three- to four-fold increase in TFA load from refrigerant emissions to as much as 50,000 tonnes across Europe by 2050.

 By that point, R-1234yf alone is expected to cause TFA inputs from precipitation of 2.5 kilograms per square kilometre per year for Europe and up to four kilograms for Germany – a tenfold increase from current levels.

However, the United Nations Environment Program and the US Environmental Protection Agency note that TFA salts, although highly persistent, do not bioaccumulate and exhibit low toxicity at concentrations expected from current R-1234yf use. 

This contested science underlies the regulatory debate about whether R-1234yf warrants inclusion in a universal PFAS ban or can be managed through existing F-gas controls.

Industry not waiting

Regardless of how the regulatory debate resolves, the automotive industry is already engineering alternatives. In an interview with Automotive IQ, Valeo heat pump module director Rody El Chammas explained that the sector is preparing for a potential PFAS ban without waiting for final rulings.

“The PFAS ban is already impacting our industry for more than two years now, since [then] we are actively engaging [in] development activities to evaluate new refrigerants and develop both R-744 and R-290 heat pump systems, to be aligned with the forecasted PFAS ban regulation in Europe.”

The Volkswagen Group has deployed R-744 (carbon dioxide) heat pump systems across its MEB electric vehicle platform since 2020, with models including the ID.3, ID.4, Audi Q4 e-tron, and Škoda Enyaq now on European roads. VW has committed to converting all BEVs to R-744 by 2030.

ZF demonstrated an R-290 (propane) concept EV thermal management system in 2023 with broader deployment planned for 2026, and Ford submitted an application to have R-290 approved as an automotive refrigerant in the United States in 2025.

Chinese auto-makers are similarly active. Dongfeng is working with the United Nations Industrial Development Organisation on an R-744 pilot project ahead of China’s July 2029 deadline banning refrigerants with GWP greater than 150 in new passenger vehicles.

Li Auto’s next-generation thermal management system runs R-744 and R-290 simultaneously.

Mr El Chammas explained Valeo’s pragmatic position: “We don’t expect a single refrigerant solution adopted by all OEM and for worldwide applications,” he said.

“At least in the next three years, the three refrigerants will coexist: R-1234yf will still be the considered refrigerant until PFAS ban; R-744 already in serial and under consideration by other players of the industry and R-290 will follow later.”

Technical realities

For workshops and technicians, the shift to natural refrigerants presents distinct challenges regardless of regulatory outcomes.

R-744 benefits from a GWP of 1, zero ozone depletion potential and non-flammability, with exceptional cold-climate performance down to -30ºC. 

However, it is unsuitable for hot climates and the systems operate at pressures roughly four times higher than conventional refrigerants, requiring R-744-specific compressors, TX valves and recovery equipment rated for pressures far exceeding current workshop infrastructure.

Technicians must also understand carbon dioxide’s unique three-state behaviour, including the risk of dry ice formation at -78ºC during rapid pressure release.

European industry analysis suggests per-vehicle costs could rise by approximately $A500 when transitioning from R-1234yf to R-744.

R-290 operates at pressures similar to R134a, simplifying some system design aspects, but its A3 highly flammable classification presents a step change in risk management compared to A2L mildly flammable refrigerants like R-1234yf.

Mr El Chammas explained that R-290 “presents safety concerns due to high flammability and therefore requires dual indirect architecture, with ultra-compact HEX technology” – meaning propane never directly contacts passenger compartment air.

Both refrigerants can match R-1234yf system performance for cabin and battery cooling and heating, according to Valeo’s assessments, with R-744 offering particular advantages in heat pump mode.

Australasian outlook

The ITRE study’s recommendation to exclude refrigerants from the universal PFAS restriction offers Australian workshops and suppliers some breathing room, but the broader transition to natural refrigerants appears increasingly inevitable.

Vehicles sold locally predominantly use R-1234yf, and the market has limited exposure to R-744 systems given it is compromised in hot climates.

When natural refrigerant vehicles do arrive in greater numbers – whether driven by PFAS restrictions, China’s 2029 GWP cap, or manufacturer platform consolidation – the local industry will need to develop relevant service capabilities relatively quickly.

Over the next decade, workshops may need to manage legacy R134a vehicles, R-1234yf platforms, R-290 systems and, potentially, dual-loop systems using both R-744 and R-290 as well as emerging blends.

Each refrigerant demands dedicated recovery and charging equipment, specialised training and distinct service procedures.

VASA members working with refrigerant handling already understand the safety requirements around A2L mildly flammable refrigerants. R-290’s A3 classification and R-744’s extreme operating pressures both demand updated training frameworks and potentially revised licensing structures.

Research firm IDTechEx predicts electric vehicles will require more than 14 million kilograms of next-generation refrigerants by 2036. 

Component sourcing, technician capability, and service infrastructure all need attention, and workshops that align training, equipment, and investment decisions early will be better placed as the regulatory picture settles.

With engineering programs advancing on multiple fronts, the question for Australian workshops is no longer whether change is coming, but how best to prepare for a multi-refrigerant future.