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UK could exempt heat pumps from PFAS regs

UK: A new report into the usage of PFAS chemicals in Great Britain has suggested that exemptions could be considered for refrigerants in heat pumps and refrigeration systems.

In what is said to be the most comprehensive British analysis of these chemicals ever, the new report from the Health and Safety Executive (HSE) has identified the most common and most harmful uses of PFAS and what measures could be put in place to control and manage them.

The HSE report makes a number of recommendations including to limit the use of PFAS-containing fire-fighting foams, as well as the use of PFAS in textiles, furniture, and cleaning products.

It does, however, suggest that exemptions could be considered for PFAS in “low risk uses” such as refrigerants in heat pumps and refrigeration systems, subject to the availability of alternatives.

The analysis is a regulatory management options analysis (RMOA), a preliminary step used within the UK REACH framework. It is not a legislative or legally binding document. It collates, combines and analyses information to understand the nature and extent of exposure to chemical substances. 

HSE, as the Agency for UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), will work with the Environment Agency and the appropriate authorities (Defra, Scotland and Wales) to consider the recommendations and how action on these recommendations will be set out in the forthcoming UK REACH Work Programme for 2023-24.

Dr Richard Daniels, director of HSE’s chemicals regulation division, said: “PFAS are a global issue of concern. We have looked at responses around the world, but it was vital we gathered the right information and evidence on how PFAS are used in Britain specifically.

“This has helped us work out where the right action could be taken to limit the use of PFAS and control exposures to people and the environment in this country.”


The report recognises evidence and data gaps in GB profile of PFAS and uncertainties about their hazardous properties. With knowledge of PFAS evolving rapidly, it accepts that up to date evidence needs to be gathered to support the REACH restrictions. 

It also recognises that TFA, a break-down product of some HFCs and HFOs, has been identified as a concern. TFA is not currently registered under UK REACH, so would need to be before a formal evaluation could take place.

The HSE report follows proposals to broaden the European REACH regulation published by the European Chemicals Agency last month. This seeks to ban a number of HFO and HFC refrigerants, many of which are currently seen as key to the F-gas phase down.

The EU REACH Regulation was brought into UK law on 1 January 2021 following the UK’s withdrawal from the European Union. Known as UK REACH, it currently retains the key principles of the EU REACH Regulation. The EU regulation continues to apply in Northern Ireland under the terms of the Northern Ireland Protocol.

The HSE report ban be found here.

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