PFAS study for ITRE Committee of the EU Parliament recommends F-gases exclusion from the scope of the UPFAS restriction
The study ‘The Per- and polyfluoroalkyl substances (PFAS) and their role as enablers in the competitiveness of European industry’ was requested by the ITRE Committee of the EU Parliament and prepared by RPA Ltd. The study 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.
The study recommends permanent or long-term derogations for critical sectors, extending transition periods for green technologies, and excluding F-gases from the restriction. Further research and an innovation fund to develop alternatives are recommended. Overall, a balanced approach that protects the environment while preserving industrial and technological strength is proposed.
One of the sector-specific recommendations is to exclude F-gases from the scope of the UPFAS restriction and instead focus 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 study comments that the example of F-gases used as refrigerants in heat pumps also indicates the level of nuance required. Consultation with industry for this study identified issues such as increased costs due to the need for higher pressure systems in an already challenging market situation. This leads to a different conclusion from that reached under the previous impact assessment by the European Commission for the revision of the F-gas regulation and indicates the need for careful consideration when concluding on substitution potential for an application, sector, or strategic sector. For green energy and clean technology, substitution potential is therefore expected to be varied, and impacts may be significant for interconnected supply chains within the sector. Further research is needed on specific applications due to divergent findings, including for F-gases used in heat pumps.
The study summarises that in the green energy and clean technology strategic sector, alternatives for F-gas refrigerants in heat pumps face technical, economic and safety constraints. The study explains that industry consultation suggests low substitution potential for F-gases in heat pumps. The revision of the F-Gas Regulation (EU-2024/573) identified natural refrigerants for systems under 12 kW, but substitution is limited by performance, application requirements and safety factors. Alternatives such as ammonia, propane, or CO₂ require higher operating pressures, reducing and necessitating redesigns that increase size and cost. This makes substitution more feasible in industrial applications than residential. Reduced efficiency also means alternatives may not be technically feasible in all climate zones based on differences in average ambient temperatures. Heat pumps are 3–5 times more expensive than boilers, and added costs reduce viability. Propane also raises safety concerns due to flammability. Overall, substitution is currently feasible only for specific applications given economic, technical, and safety constraints of alternatives.
A summary of the study requested by ITRE Committee is available The Per- and polyfluoroalkyl substances
The complete report issued in December 2025 prepared by RPA Ltd is available PFAS and their role as enablers in the competitiveness of European industry