Q.01

How are hydrofluorocarbons regulated?

Most major jurisdictions regulate HFCs as greenhouse gases rather than ozone-depleting substances, under the Kigali Amendment to the Montreal Protocol. The legal tools are much the same everywhere: a quota or allowance system that steps down bulk production and import, measured in CO₂-equivalent and set against a historical baseline, plus GWP-based bans on products and equipment. Most regimes add leak, servicing, labelling and trade controls on top.

Approach: I searched the Montreal Protocol controlled-substance list, the EU F-gas Regulation (EU) 2024/573, Canada's CEPA regulations, Australia's Ozone Protection and Synthetic Greenhouse Gas Management Act, Japan's Fluorocarbons Emission Control Act and the Swiss ChemRRV. The US AIM Act rules (40 CFR Part 84) and the GB regime are not in the datasets, so I took them from eCFR and GOV.UK. I did not open the Kigali step-down schedule in the treaty text itself.

International: Montreal Protocol, Kigali Amendment (Annex F)

  • HFCs were added by the Kigali Amendment as Annex F. They are controlled "for their 100-year global warming potential, not for ozone depletion" [1].
  • The list has 18 HFCs. Group I has 17, for example HFC-134a (GWP 1 430) [1], HFC-32 (675) [2], HFC-125 (3 500) [3] and HFC-143a (4 470) [4].
  • Group II is HFC-23 alone, with a GWP of 14 800 [5].

EU: F-gas Regulation (EU) 2024/573

It repealed Regulation (EU) No 517/2014. Quota allocated under the old Regulation remains valid [6].

Phase-down

  • Market quota: producers and importers may place HFCs on the market only within quota allocated by the Commission [7].
  • Exemptions from quota: HFCs imported for destruction, used as feedstock, supplied directly for export, used in military equipment, or used for semiconductor etching or CVD-chamber cleaning [7].
  • EU-wide caps (Annex VII): 42 874 410 t CO₂e for 2025–2026, falling to 9 132 097 t for 2030–2032 and to 0 from 2050 [8].
  • Production rights (Annex V): set as a share of each producer's 2011–2013 average output: 60% for 2025–2028, 30% from 2029, 20% for 2034–2035 and 15% from 2036 [9].
  • Pre-charged equipment: refrigeration, air-conditioning and heat-pump equipment, and metered dose inhalers from 1 January 2025, may only be placed on the market if the HFCs they contain are covered by quota.
    • This needs a declaration of conformity and, in some cases, an independent audit.
    • Importers established outside the EU must appoint an only representative.
    • These rules do not apply to undertakings placing less than 10 t CO₂e a year in such products [10].

Product and equipment bans (Article 11, Annex IV)

  • The bans are dated and set by GWP. Examples: self-contained commercial refrigerators with HFCs of GWP 150 or more, from 1 January 2022; split air-to-air systems up to 12 kW with gases of GWP 150 or more, from 1 January 2029; technical aerosols with any F-gas, from 1 January 2030 [11].
  • Non-refillable containers are prohibited [12].
  • Only EU-established undertakings, or those that have appointed an EU only representative, may place bulk F-gases on the market [12].

Servicing bans (Article 13)

  • Gases with GWP of 2 500 or more may not be used to service any refrigeration equipment from 1 January 2025, or air-conditioning and heat pumps from 1 January 2026.
  • Reclaimed or recycled gas is allowed until 2030 for refrigeration and until 2032 for air-conditioning and heat pumps.
  • From 1 January 2032, gases with GWP of 750 or more may not be used to service stationary refrigeration other than chillers [13].

Containment, labelling and trade

  • Leak checks are required on equipment holding 5 t CO₂e or more. Frequency rises with charge: every 12 months below 50 t, every 6 months at 50–500 t, and every 3 months at 500 t or more [14].
  • Labelling: the label must show the gas, its quantity by weight and in CO₂e, and its GWP [15].
  • Imports and exports need a licence through the F-gas Portal. From 12 March 2025, exports of certain equipment using gases with GWP of 1 000 or more are banned [16].

United States: AIM Act, 40 CFR Part 84 (EPA)

  • Phasedown (§ 84.7): US production and consumption are capped as a percentage of baseline: 90% for 2022–2023, 60% for 2024–2028, 30% for 2029–2033, 20% for 2034–2035 and 15% from 2036 (eCFR § 84.7).
    • The consumption baseline is 302,538,316 metric tons of exchange value equivalent.
    • The phasedown is administered through allowances.
  • Technology transitions (§ 84.54): dated, GWP-based bans on manufacturing or importing products, followed three years later by bans on selling and distributing them, plus bans on installing systems (eCFR § 84.54). Examples:
    • household refrigerators with GWP of 150 or more, from 1 January 2025;
    • residential self-contained air-conditioning with GWP of 700 or more, from 1 January 2025;
    • light-duty vehicle air-conditioning with GWP of 150 or more, from Model Year 2025;
    • most aerosols with GWP of 150 or more, from 2025, with all remaining exceptions except defense sprays ending in 2028.
  • Other parts: Subpart C covers leak repair, reclamation and disposable cylinders. Violations are enforced under Clean Air Act section 113 (eCFR Part 84).

Canada: Ozone-depleting Substances and Halocarbon Alternatives Regulations (SOR/2016-137)

  • Import permits: importing an HFC listed in Table 4 of Schedule 1 is prohibited without a permit [17].
  • Consumption allowances step down from base consumption: 90% for 2019–2023, 60% from 2024, 30% from 2029, 20% from 2034 and 15% from 2036 [18].
  • Product bans (Schedule 1.1): importing or manufacturing listed products whose refrigerant exceeds the set GWP limit is prohibited [19][20]. Examples are chillers above GWP 750 from 2025 and residential stand-alone refrigeration above GWP 150 from 2025 [21].
  • Vehicle air-conditioning above GWP 150 is banned from model year 2021 [19].

Australia: Ozone Protection and Synthetic Greenhouse Gas Management Act 1989

  • Licence and quota: HFC manufacture or import requires a synthetic greenhouse gas (SGG) licence and an allocated HFC quota [22][23].
  • Industry limit: total quota is capped by an HFC industry limit set by regulations, which must be consistent with Australia's international obligations [24].
  • Penalties: breaching a licence condition carries up to 500 penalty units for the fault-based offence [25].
  • Trade with non-Parties: the requirement to trade HFCs only with Montreal Protocol Parties starts when the Kigali Article 4 changes enter into force for Australia, which cannot be before 1 January 2033 [25].

Great Britain

GOV.UK says you "must get quota to produce or import bulk" HFCs. The target is a 79% cut by 2030 from average use in 2009–2012. Quota is not needed for re-export only, exempt uses, or gas recovered from equipment already on the GB market (GOV.UK). The page does not name the governing legislation, and I did not open the GB legal text.

Japan: Fluorocarbons Emission Control Act

  • The Act aims to curb emissions of fluorocarbons (フロン類, "furon-rui") that deplete the ozone layer or seriously affect global warming [26].
  • Article 2 defines these as the CFCs and HCFCs that are "specified substances" under Japan's Ozone Layer Protection Act, plus the substances in Article 2(3)(iv) of the Act on Promotion of Global Warming Countermeasures [27]. Article 2 does not name HFCs as such.
  • It controls fluorocarbons in commercial air-conditioning and refrigeration equipment and in car air-conditioning. Filling and recovery businesses must be registered; reclamation and destruction businesses must be licensed [27].

Switzerland: ChemRRV (SR 814.81)

  • Scope: Annex 1.5 treats Annex F HFCs as "in der Luft stabile Stoffe" (substances stable in air) [28].
  • General ban: placing on the market preparations and articles containing them is prohibited [29].
  • Refrigerants (Annex 2.10): dated bans by equipment type, capacity and GWP. Examples: building air-conditioning above 400 kW or using a refrigerant with GWP above 2100, and self-contained commercial refrigeration with GWP of 150 or more [30]. Exceptions are set out separately in Annex 2.10, item 2.2.

Sources:

Q.02

Which refrigerants are affected?

Nineteen saturated HFC refrigerants are covered. The core set is the 18 HFCs in Annex F of the Montreal Protocol (Kigali Amendment). Canada's Table 4 lists the same 18, and Switzerland's ChemRRV refers directly to Annex F. The EU F-gas Regulation adds a 19th, HFC-161. Blends that contain any of these are also caught. In the EU, the newer unsaturated refrigerants (HFOs) are F-gases too, but they are outside the HFC quota.

Approach: I checked the Montreal Protocol Annex F list, Annexes I, II and VI of the EU F-gas Regulation (EU) 2024/573, Table 4 of Schedule 1 to Canada's SOR/2016-137 and Annex 1.5 of the Swiss ChemRRV. None of these lists name common trade blends such as R-404A, so I give no blend compositions or GWPs.

The controlled HFCs (100-year GWP)

HFCFormulaGWPAnnex FEU Annex ICanada Table 4
HFC-23CHF₃14 800Group II [5]✓✓
HFC-32CH₂F₂675✓ [2]✓✓
HFC-41CH₃F92✓ [31]✓✓
HFC-125CHF₂CF₃3 500✓ [3]✓✓
HFC-134CHF₂CHF₂1 100✓ [32]✓✓
HFC-134aCH₂FCF₃1 430✓ [1]✓✓
HFC-143CH₂FCHF₂353✓ [33]✓✓
HFC-143aCH₃CF₃4 470✓ [4]✓✓
HFC-152CH₂FCH₂F53✓ [34]✓✓
HFC-152aCH₃CHF₂124✓ [35]✓✓
HFC-161CH₃CH₂F12not listed✓ (EU only)not listed
HFC-227eaCF₃CHFCF₃3 220✓ [36]✓✓
HFC-236cbCH₂FCF₂CF₃1 340✓ [37]✓✓
HFC-236eaCHF₂CHFCF₃1 370✓ [38]✓✓
HFC-236faCF₃CH₂CF₃9 810✓ [39]✓✓
HFC-245caCH₂FCF₂CHF₂693✓ [40]✓✓
HFC-245faCHF₂CH₂CF₃1 030✓ [41]✓✓
HFC-365mfcCF₃CH₂CF₂CH₃794✓ [42]✓✓
HFC-43-10meeCF₃CHFCHFCF₂CF₃1 640✓ [43]✓✓
  • EU: Annex I, Section 1 lists the 19 HFCs with the same GWPs as above [44].
  • Canada: Table 4 lists the same 18 HFCs as Annex F, with identical GWPs [45].

Blends

  • EU definition: "hydrofluorocarbons" means the Annex I Section 1 substances "or mixtures containing any of those substances" [46]. Any HFC-based blend is therefore under the quota and the other HFC rules.
  • Blend GWP: calculated as a weight-fraction average under Annex VI. Some non-fluorinated components count with their own fixed values, for example propane (R-290) at 0,02 and ammonia (R-717) at 0. Substances not listed default to 0 [47].
  • Why it matters: the equipment and servicing bans (GWP 150, 750, 2 500 and so on) apply to the blend's calculated GWP, not to the GWP of each component.

Low-GWP alternatives that are still F-gases (EU)

  • Annex II, Section 1 lists unsaturated HFCs and HCFCs (HFOs), including:
    • HFC-1234yf (GWP 0,501)
    • HFC-1234ze (1,37)
    • HFC-1336mzz(E) (17,9) and HFC-1336mzz(Z) (2,08)
    • HCFC-1233zd (3,88)
    • HCFC-1224yd (0,06) [48]
  • Not under quota: the quota and the pre-charged equipment rule cover only Annex I Section 1 substances [10]. HFOs are outside both.
  • Still labelled: Annex II gases fall under the labelling rules for foams, reclaimed gas and advertising at GWP 150 or more [15].

Switzerland

  • Scope: ChemRRV Annex 1.5 covers the Annex F HFCs, and also other fluorinated organic compounds that are stable in air. "Stable in air" means a vapour pressure of at least 0,1 mbar at 20 °C or a boiling point of no more than 240 °C, plus an atmospheric lifetime of at least 2 years [28].
  • Imports and exports: importing the Annex F HFCs requires a FOEN (BAFU) import permit [49]. Exporting more than 20 kg gross weight requires an export permit [50].
Q.03

What rules apply in the US and UK?

In the US, refrigerant HFCs fall under EPA's AIM Act rules in 40 CFR Part 84. These set an allowance-based production and consumption phasedown, dated GWP bans on making and installing equipment, and, since 1 January 2026, leak repair, leak detection and reclaimed-refrigerant rules. In Great Britain the governing law is the assimilated F-gas Regulation, Regulation (EU) No 517/2014 as it applies in GB. It works through a CO₂e quota phasedown, product bans, a servicing ban on GWP above 2,500 and leak checks. Northern Ireland applies the EU F-gas Regulation (EU) 2024/573 instead.

Approach: The datasets I can search don't hold the US federal refrigerant rules or the GB F-gas law, so I read the current text on eCFR and the GOV.UK and Defra pages. The only related dataset record was California's consumer-product GWP limits. I couldn't open the GB legal text on legislation.gov.uk, so the GB section rests on GOV.UK guidance and Defra's November 2025 consultation. I also did not open the older EPA refrigerant rules in 40 CFR Part 82 (Section 608 and SNAP).

United States: AIM Act, 40 CFR Part 84

Phasedown (§ 84.7) (eCFR § 84.7)

  • Production and consumption are capped as a share of baseline: 90% for 2022–2023, 60% for 2024–2028, 30% for 2029–2033, 20% for 2034–2035 and 15% from 2036.
  • The baselines are 382,535,439 MTEVe for production and 302,538,316 MTEVe for consumption (metric tons of exchange value equivalent).
  • Allowances issued from 2036 may not exceed 45,380,747 MTEVe of consumption.

Bans on making and importing products, and on installing systems (§ 84.54) (eCFR § 84.54)

Each ban covers a pure HFC or a blend at or above the stated GWP.

Manufacture and import of products (§ 84.54(a)):

  • From 1 Jan 2025:
    • GWP 700 or more: self-contained residential and light-commercial air-conditioning and heat pumps, residential dehumidifiers, and comfort-cooling and ice-rink chillers.
    • GWP 150 or more: household fridges and freezers, stand-alone retail food refrigeration and vending machines.
  • From 1 Jan 2026: industrial process refrigeration other than chillers. The limit is GWP 150 or more for charges of 200 lb or more, and GWP 300 or more for smaller charges, where the refrigerant enters the evaporator above −30 °C.
  • From 27 Jul 2026: intermodal reefer containers with a box temperature of −35 °C or higher, at GWP 700 or more.
  • From 1 Jan 2027: self-contained data-centre cooling at GWP 700 or more.
  • By named refrigerant: some subsectors ban listed refrigerants instead of a GWP level. For example, R-404A and R-507A are banned in road and marine transport refrigeration from 2025.
  • Sale and distribution: banned three years after each manufacture or import date (§ 84.54(b)).

Installation of systems (§ 84.54(c)):

  • Residential and light-commercial air-conditioning and heat pumps, GWP 700 or more: from 1 Jan 2025, or 1 Jan 2026 for variable refrigerant flow (VRF) systems. Systems whose components were made or imported before those dates may still be installed.
  • Supermarket systems: GWP 1,400 or more from 1 Jan 2027.
  • Cold storage warehouses: GWP 700 or more from 27 Jul 2026.
  • Remote condensing units: GWP 1,400 or more from 27 Jul 2026.
  • Tighter limits from 1 Jan 2032 for supermarkets, cold storage and remote condensing units: GWP 150 or more for charges of 200 lb or more; GWP 300 or more below 200 lb or on the high-temperature side of a cascade system.
  • What counts as installation: this includes expanding the capacity of an existing supermarket system by more than 15%, and replacing 75% or more of the evaporators plus all compressor racks and condensers (§ 84.54(e)).
  • Recent amendment: § 84.54 was last amended at 91 FR 31329 (26 May 2026).

Refrigerant management (Subpart C, in force from 1 Jan 2026) (eCFR Part 84 Subpart C)

  • Leak repair (§ 84.106):
    • Applies to appliances holding 15 lb or more of an HFC, or of a substitute with GWP above 53. Residential and light-commercial air-conditioning and heat pumps are excluded.
    • Leak-rate triggers are 20% for commercial refrigeration, 30% for industrial process refrigeration, and 10% for comfort cooling and other appliances.
    • Leaks "must" be repaired within 30 days (120 days if an industrial process shutdown is needed), with initial and follow-up verification tests.
    • An appliance leaking 125% or more of its full charge in a calendar year must be reported to EPA.
  • Automatic leak detection (§ 84.108):
    • Required for commercial or industrial process refrigeration with a charge of 1,500 lb or more.
    • New systems need it at installation (or within 30 days) from 1 Jan 2026. Systems installed from 2017 to 2025 need it by 1 Jan 2027.
  • Reclaim (§ 84.112):
    • From 1 Jan 2026, refrigerant sold as "reclaimed" may contain no more than 15% virgin HFC by weight, and containers must carry a label saying so.
    • From 1 Jan 2029, servicing of supermarket systems, refrigerated transport and automatic commercial ice makers "must be done with reclaimed refrigerant."
  • Disposable cylinders (§ 84.116): from 1 Jan 2028, used cylinders must be sent for heel removal, or evacuated to 15 in-Hg by a certified technician.
  • Enforcement: violations are subject to penalties under Clean Air Act section 113 (§ 84.120).

California (state level, not refrigerants) California's Consumer Products Regulation, Table 94509(n)(1), bans any compound with GWP 150 or more in listed consumer products. These include pressurized gas dusters (effective 31 Dec 2010) [51], dry shampoo (1 Jan 2023) [52] and crawling bug insecticide aerosols (1 Jan 2030) [53]. This touches HFC propellants such as HFC-134a, not refrigeration equipment. I found no California refrigerant rule in the datasets.

Great Britain: assimilated Regulation (EU) No 517/2014

Legal basis

  • GB F-gases are regulated through assimilated law, including Regulation (EU) No 517/2014 "with technical amendments" (Defra consultation, p. 7).
  • The Environment Agency runs the GB system. SEPA and Natural Resources Wales also handle compliance and enforcement (p. 8).
  • Under the Windsor Framework, Northern Ireland applies the EU Regulation (EU) 2024/573 (p. 10).

Phase-down and quota (Articles 14–18, Annex V)

  • Current schedule: HFCs placed on the GB market are capped at 31% of baseline for 2024–2026, 24% for 2027–2029 and 21% from 2030 onward. That is a 79% cut by 2030 (consultation pp. 7, 15–16).
  • Baseline years differ by source: the consultation gives the baseline as the 2015–2019 average. GOV.UK's quota page says 2009–2012. I couldn't open the legal text to settle which is right.
  • Who needs quota: producers or importers of bulk HFCs. New entrants must apply at 100 t CO₂e or more a year. Re-exports, exempt uses and gas recovered from equipment already on the GB market are exempt (GOV.UK quota guidance).
  • Pre-charged equipment: since 1 January 2017, HFCs in pre-charged refrigeration, air-conditioning and heat-pump equipment must be covered by quota authorisations (Article 14(1)). Metered dose inhalers are exempt from the phase-down under Article 15(2) (consultation pp. 7, 12).
  • Pending reform: Defra consulted from 5 Nov to 17 Dec 2025 on a faster phase-down from 1 January 2027. It would cut the cap to 16.2% for 2027–2029 and to 1.4% for 2048–2050, a 98.6% reduction. No government response has been published (Defra consultation page).

Bans on new products and equipment (GOV.UK, updated 27 Aug 2026)

  • Domestic fridges and freezers: GWP above 150.
  • Commercial hermetically sealed equipment: GWP above 150.
  • Stationary refrigeration: GWP above 2,500, except systems cooling below −50 °C.
  • Multipack centralised commercial systems of 40 kW or more: GWP above 150, with a cascade exception below GWP 1,500.
  • Movable air-conditioning: GWP above 150.
  • Single split air-conditioning with less than 3 kg of refrigerant: GWP above 750, from 2025.
  • Exemptions: the Environment Agency can grant one for up to 4 years where no alternative is available, or alternatives would be unsafe, technically unworkable or disproportionately costly.
  • Note: an older GOV.UK ban page was withdrawn on 21 Aug 2019 and replaced by this one.

Servicing ban (GOV.UK)

  • Virgin F-gas with GWP above 2,500 may not be used to refill refrigeration systems holding 40 t CO₂e or more.
  • Reclaimed or recycled gas is allowed "until 2030 only".
  • Military equipment and systems cooling below −50 °C are exempt.

Leak checks (GOV.UK)

  • Frequency: every 12 months for 5–50 t CO₂e, every 6 months for 50–500 t, and every 3 months for 500 t or more.
  • Installing automatic leak detection doubles the interval between checks.
  • Automatic leak detection is mandatory at 500 t CO₂e or more.

Main differences between the US and GB

  • How charge is measured: US leak rules are triggered by charge weight in pounds (15 lb and 1,500 lb). GB rules use tonnes of CO₂e (5, 50 and 500 t).
  • US-only rules with no GB equivalent in the guidance I read: installation bans on whole systems, a reclaimed-only servicing requirement for some subsectors from 2029, and the cylinder heel rules.
  • GB-only rule: a general servicing ban on GWP above 2,500.

Sources:

Q.04