EU study recommends excluding refrigerants from PFAS restrictions
20th December 2025
EUROPE: The European parliament’s Policy Department for Transformation, Innovation and Health has recommended that F-gases should be excluded from future PFAS restrictions, and focus regulatory controls through the existing F-gas regulation.
The study, produced at the request of the Industry, Research and Energy Committee (ITRE), examines how PFAS support EU industrial competitiveness and the potential impact of a full or partial restriction.
Focusing on six key fluoropolymers and F-gases used in aerospace, defence, green energy, and semiconductor sectors, it finds that substitution is often unfeasible, particularly in aerospace, defence and semiconductors. Substantial economic losses and job impacts are predicted under both above restriction options, with risks to EU’s global competitiveness.
To report recommends excluding F-gases from the scope of the UPFAS restriction and instead focusing all regulatory control of F-gases into the existing F-gas regulation.
“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.
The study is in response to proposals from five European member states – Germany, the Netherlands, Norway, Sweden and Denmark – to restrict PFAS substances under the European REACH regulations. The proposal would see bans on single component gases R125, R134a, R143a and the HFOs R1234yf and R1234ze(E), which would affects virtually all new and current lower GWP HFC/HFO refrigerant blends. The most significant refrigerant falling outside the PFAS definition is R32.
The new ITRE report recognises heat pumps as a key green technology to achieve the ambitious targets set out in the European Green Deal and Fit-for-55 programme, and that, while alternatives using non-fluorinated gases are available, they are still a developing technology and not a universal replacement solution at present. In addition, it considers that cost and performance implications for potential alternatives may limit substitution potential.
“Overall, substitution is not currently feasible given economic, technical, and safety constraints,” the report states. It recommends excluding F-gases completely from the scope of a universal PFAS restriction and instead focus all regulatory control of all F-gases into the existing F-gas regulation.
“The current F-gas Regulation covers many F-gases and many of their uses on an individual regulatory basis and there is already a mechanism built into this regulation to ensure updates and revisions to reflect current technologies and alternatives within Europe,” the report says.
It maintains that the existing F-gas regulation would allow for a more “nuanced approach” to regulating and phasing down the use of F-gases, while fostering the development of alternatives in a more gradual way.
This, the study suggests, would be far less disruptive to European industry, while still ensuring Europe retains the ability and capacity to innovate in green technologies.






