Dear subscriber,

In this EFCTC June 2026 newsletter, we highlight key developments in fluorinated gas regulation and environmental protection. First we report on the outcome of the ECHA Consultation on the SEAC draft opinion on PFAS restriction, which ran from 26 March to 25 May 2026. ECHA has published a summary of the consultation outcome. More than 3200 organisations and 250 individuals submitted 3511 comments during the 60-day consultation on the draft opinion of ECHA’s Committee for Socio-Economic Analysis (SEAC).   

We present extensive excerpts from two reports that discuss cost effective approaches to reduce F-gas emissions for RACHP (refrigeration, air conditioning and heat pump) applications and separately for lifecycle refrigerant emissions from mobile air-conditioning. The European Partnership for Energy and the Environment (EPEE) commissioned a Socio-Economic Assessment (SEA) and Analysis of Alternatives (AoA) on the use of F-gas refrigerants in RACHP.  The report evaluated and compared continued use of F-gases with Risk Mitigation Measures (RMM) 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). 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. The key finding of the report is that continued use under conditions (RMM) is the most proportionate restriction option. 

A comprehensive, detailed and thorough technical report ‘How to reduce lifecycle refrigerant emissions from mobile air-conditioning in the EU’ analyses and quantifies emissions of refrigerant throughout the mobile air-conditioning (MAC) lifecycle from refrigerant supply through to end-of-life recovery. The work was initiated to support the authorities working on the PFAS restriction proposal (Dossier Submitters, ECHA and Commission), who are exploring additional measures to reduce refrigerant emissions as an alternative risk management option. Regulatory measures to reduce emissions are proposed for entry into force from 2030 and their cumulative emissions reductions estimated. The report concludes that the overall emissions are reduced on an annual basis (2050) by 60% versus the 2021 baseline.  

We provide an illegal trade update. Recent developments since our November 2025 report show increased action against illegal refrigerant trade. Member states have introduced new policies and initiatives to combat illicit imports and dismantle criminal distribution networks. Industry associations continue advocating for enhanced enforcement, with authorities reporting substantial seizures of illegally traded refrigerants. 

Finally, we discuss a recent paper by S. Reimann et al. “Continuing industrial emissions are delaying the recovery of the stratospheric ozone layer”, which discusses several scenarios for emissions of ozone depleting substances used as feedstocks. The authors use the scenarios to estimate the effect on the recovery of the ozone layer and conclude that the elevated emission scenario could delay the recovery of the mid-latitude stratospheric ozone layer by 7 (6 – 11) years from 2066 to 2073. The zero and low emission rate scenarios result in ozone layer recovery in 2065 and 2066 respectively. EFCTC provides explanatory notes including the EU the emission rate from feedstock uses was 0.03% of the reported make-up in 2024. 

Do you want to learn more about EFCTC and fluorocarbons? More information is on the fluorocarbons.org website. 

 
Thank you for your continued interest in EFCTC. 

ECHA Consultation on the SEAC draft opinion on PFAS restriction – outcome 

The Socio-Economic Analysis Committee (SEAC) examines the broader economic and societal consequences of the proposed restriction, going far beyond a simple cost tally. Its work includes estimating the financial burden on industry, such as reformulation of products, substitution of substances, investment in new technologies and systems, and ongoing compliance costs. In parallel, SEAC assesses the anticipated benefits, including lower healthcare expenditures linked to reduced exposure, improvements in environmental quality, and longer-term gains for public health and ecosystems. 

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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. 

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How to reduce lifecycle refrigerant emissions from mobile air-conditioning in the EU 

A comprehensive, detailed and thorough technical report [1] analyses and quantifies emissions of refrigerant throughout the mobile air-conditioning (MAC) lifecycle from refrigerant supply through to end-of-life recovery.  Regulatory measures to reduce emissions are proposed for entry into force from 2030 and their cumulative emissions reductions estimated. The report concludes that the overall emissions are reduced on an annual basis (2050) by 60% versus the 2021 baseline.  

Click "read more" to read the full article 

Illegal Trade Round-up  

In this round-up: Since the last round-up in November 2025, there are new policies and initiatives by member states to deter and detect illegal trade and disrupt the criminal gang networks responsible for much of the imports. Industry trade association are calling for greater enforcement, and significant quantities of refrigerant have been seized.  

Globally, UNEP-OzonAction organised Montreal Protocol Dialogue on Action against Illegal Trade brought together global and regional enforcement entities working on enforcement. In an article Enforcement for Climate Action: Why Customs Matters More Than Ever UNEP-OzonAction commented that ‘Yet the enforcement landscape is becoming more complex.

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Emissions of ozone depleting substances used as feedstocks: scenarios   

A recent paper by S. Reimann et al. “Continuing industrial emissions are delaying the recovery of the stratospheric ozone layer” [1] reports a scenario where the emission rates of ozone depleting substances used as feedstock continues as business as usual (BAU) until 2100, without any improvement in emission rates which occur during the production and use of feedstocks. This is compared to low emission rate (LOW) and zero emission rate (ZERO) scenarios.  All the scenarios initially use BAU trends (growth or decrease depending on the feedstock) with feedstock use out to 2100 based on the authors considered likely trends.  The authors then use the scenarios (BAU, LOW and ZERO) to estimate the effect on the recovery of the ozone layer and conclude that the elevated emission scenario (BAU) could delay the recovery of the mid-latitude stratospheric ozone layer by 7 (6 – 11) years from 2066 to 2073. The ZERO and LOW emission rate scenarios result in ozone layer recovery in 2065 and 2066 respectively. 

Click "read more" to read the full article