The PFAS restriction proposal — what it could mean for HFO refrigerants
By DigiEntropy Engineering · 2026-02-08 · 8 min read
ECHA's proposed universal PFAS restriction under REACH could phase out HFOs and HFC/HFO blends starting in 2026-2028. If it lands as drafted, natural refrigerants become the only future-proof choice for long-life refrigeration systems.
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EU refrigeration engineers have been digesting the new F-Gas Regulation (EU) 2024/573 for two years. Most projects approved in 2025-2026 are pivoting to HFC/HFO blends — R448A, R449A, R454C, R455A — to land below the 150-GWP threshold for new commercial refrigeration over 12 kW.
There's a second regulatory thread coming that almost nobody in the industry has fully priced into their decision: the PFAS restriction.
10,000 - fluorinated chemicals in the PFAS class - nicknamed "forever chemicals"
PFAS — per- and polyfluoroalkyl substances — are a class of 10,000 fluorinated chemicals nicknamed "forever chemicals" because they don't break down in nature.
2023 - restriction filed - by five European countries
The restriction was filed by Germany, Netherlands, Denmark, Norway, and Sweden in January 2023.
2027-2028 - restriction landing - derogations expiring 2033-2040
The PFAS timeline (restriction landing 2027-2028, derogations expiring 2033-2040) collides with the design life of long-life systems specified today on HFO blends.
5-12 - year HFO derogation, most likely - for refrigeration uses
Most likely outcome: HFOs receive a 5-12 year derogation for refrigeration uses.
2034 - R454C derogation expires - in the 2025 supermarket example
2034: derogation expires, new R454C equipment can no longer be placed on market.
25-35% - R744 capital premium - over R454C centralised, on commissioning
The capital cost differential between R744 transcritical and R454C centralised is typically 25-35% on commissioning.
What PFAS is and why refrigerants are caught up in it
PFAS — per- and polyfluoroalkyl substances — are a class of 10,000 fluorinated chemicals nicknamed "forever chemicals" because they don't break down in nature. The EU's environmental concern is about specific PFAS substances (PFOA, PFOS, GenX) accumulating in groundwater, soil, and human bodies. The proposed restriction goes further than just those specific substances: it would restrict the entire PFAS class based on the fluorinated carbon backbone.
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