Report on cost-effective F-gas emission reduction option for PFAS restriction

The European Partnership for Energy and the Environment (EPEE) commissioned Environmental Resources Management Ltd (ERM) to conduct a Socio-Economic Assessment (SEA) and Analysis of Alternatives (AoA) on the use of F-gas refrigerants in RACHP (refrigeration, air conditioning and heat pump) applications. The study evaluates the potential impacts of restricting per- and polyfluoroalkyl substances (PFAS) under REACH on the RACHP sector across four application groups: (1) comfort heating and cooling; (2) industrial processes for heating and cooling; (3) commercial and industrial refrigeration; and (4) transport refrigeration. 

The report evaluated and compared continued use of F-gases with Risk Mitigation Measures (RMM), a baseline with no restrictions and the two restriction options (full ban and full ban with derogations as set out in the updated restriction dossier published by ECHA in August 2025). The RMM option is introduced in the report as an alternative regulatory option. For the RMM, F-gases remain permitted subject to a projected maximum leak rate per equipment category and progressively higher end-of-life recovery rates. These are aligned with EPEE HFC Outlook model assumptions.  A cautious 5% whole-of-life cost increase is modelled for the leak rate reduction.  

The ERM study's central conclusion is that the RMM is the most proportionate regulatory option: it achieves a 39% reduction in PFAS emissions at €20/kg — compared to €92/kg under full ban — while avoiding severe economic and market disruption, over 43,000 direct job losses in 2030 and significant supply chain risks. The SEAC's draft opinion has already noted that a full ban appears likely disproportionate. The data show that full ban with derogations performs worse than the RMM on cost-effectiveness while delivering far lower emission reductions.  

Key finding: continued use under conditions (RMM) is the most proportionate restriction option 

The key headline findings are: 

• Cost-effectiveness under RMM is 4.6× better than full ban (€92) and 10× better than full ban with derogations (€198) 

• GVA (gross value added) impact under RMM is 8× lower than both full ban and full ban with derogations 

• The RMM avoids more PFAS emissions than full ban with derogations, at one tenth the economic cost 

• For comfort heating and cooling: the RMM emission reduction exceeds full ban, because RMMs apply to the existing installed base, not only new products placed on market from 2030 

• About 42,800 jobs preserved in 2030 under the RMM, compared to the full ban 

The reports key messages (extracts) are:  

Material economic impact. A full ban would deliver the largest emission reduction but at severe socio-economic cost. A full ban with derogations offers limited environmental benefit relative to its cost. The RMM option provides the best cost-effectiveness and system continuity and is the preferred option for stationary applications.  

Broader system dependencies and wider impacts. Downstream sectors face elevated operational and supply-chain risks if refrigerant availability is constrained without workable alternatives. Reduced refrigerant choice would weaken EU manufacturing competitiveness, slow heat-pump rollout, and risk backsliding on electrification and decarbonisation objectives, leading to a lock-in on fossil fuel-based technologies. 

No universal alternative refrigerant exists for RACHP applications. There is no single alternative refrigerant that can safely, efficiently and economically replace F-gases across all RACHP applications. Non-PFAS alternatives are constrained by flammability, toxicity, high pressure and performance limits. Safety — not refrigerant choice — is the dominant factor determining whether substitution is feasible for a given application.  

Transition timelines proposed are unrealistic. Substituting refrigerants requires long, application-specific development cycles — typically 5–12 years and longer for novel solutions — significantly exceeding the derogation periods proposed under the PFAS restriction for many applications.  

Proportionality, sequencing and coherence with F-gas policies are essential. A future PFAS regulation must reduce environmental risk without jeopardising EU climate, industrial and social goals. Building on the F-gas Regulation rather than overriding it is the only path that achieves both objectives. The RMM option demonstrates that this is possible. 

These are extracts of the report which has detailed sections on  

• Background and Regulatory Context 

• Study Methodology and Scenarios 

• Analysis of Alternatives (AoA)  

• Socio-Economic Assessment (SEA) 

The Executive Report of the ERM Socio-Economic Assessment on F-gas Uses in HVACR Applications Prepared in the framework of the SEAC Public Consultation on PFAS under REACH - May 2026, commissioned by EPEE is available here.