Short answer
It is not law. The universal PFAS restriction proposal was submitted to the European Chemicals Agency (ECHA) on 13 January 2023 by authorities in the Netherlands, Germany, Denmark, Norway and Sweden. It is going through the REACH restriction procedure and by itself produces no legal effect on a refrigeration business.
- Where the dossier stands. In ECHA’s registry of restriction intentions, the status shown on 22 September 2026 is "Opinion development", and the last recorded update is 1 July 2026.
- What has already happened. The Committee for Risk Assessment (RAC) adopted its final opinion on 2 March 2026; the Committee for Socio-Economic Analysis (SEAC) agreed its draft opinion on 10 March 2026. The 60-day consultation on the SEAC draft opinion closed on 25 May 2026.
- What has not happened. On the day of reading, the registry fields "Compiled RAC and SEAC opinion", "Final background document" and "Adopted restriction/Commission communication" were empty.
- What comes next, according to ECHA. SEAC is expected to adopt its final opinion by the end of 2026; the opinions are then formally submitted to the European Commission, which will propose a restriction for discussion and vote in the REACH Committee, composed of EU Member States.
No date of entry into force, no final scope, no definitive list of derogations and no estimate of the outcome, because none of that is decided. No advice to change refrigerant because of the proposal either, and no prices or availability claims. The duties that apply today are those in Regulation (EU) 2024/573.
Where the dossier stood on 22 September 2026
The dates below are taken from the dossier record published by ECHA in the registry of restriction intentions and from the agency’s news release of 26 March 2026, both read on 22 September 2026.
| Step | Date published by ECHA |
|---|---|
| Intention to restrict | 15 July 2021 |
| Dossier submitted to ECHA | 13 January 2023 |
| Consultation on the Annex XV report | 22 March 2023 - 25 September 2023 |
| RAC final opinion | Adopted on 2 March 2026 |
| SEAC draft opinion | Agreed on 10 March 2026 |
| Consultation on the SEAC draft opinion | 26 March 2026 - 25 May 2026 |
| SEAC final opinion | Expected, according to ECHA, by the end of 2026 |
| Adopted restriction | Field empty on the day of reading |
Who submitted the dossier. The registry names Germany, Denmark, the Netherlands, Norway and Sweden as the submitters.
What the steps mean. ECHA’s page on the restriction process describes four phases: preparation and submission of a restriction proposal; consultations, including the consultation on the restriction report and the consultation on the SEAC draft opinion; opinion development, with advice from the Forum, the RAC opinion and the SEAC opinion; and finally decision and follow-up, that is the Commission decision on restriction, complying with it and enforcing it.
According to the agency’s news release, RAC, in its final opinion, and SEAC, in its draft opinion, support an EU-wide restriction, subject to specific derogations, on the manufacture, placing on the market and use of PFAS, and recommend that any restriction should be complemented by effective measures to minimise emissions.
The PFAS definition used in the proposal
The question "is my gas a PFAS?" has no general answer. It has an answer only against the definition used in the particular dossier. The ECHA registry reproduces it as follows:
Per- and polyfluoroalkyl substances (PFASs) defined as: any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it).
A substance that only contains the following structural elements is excluded from the scope of the proposed restriction: CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH3), methylene (-CH2-), an aromatic group, a carbonyl group (-C(O)-), -OR’’, -SR’’ or -NR’’R’’’, and where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-).
Two practical consequences, both confirmed by the ECHA documents:
- The definition does not map onto "fluorinated greenhouse gas". The SEAC sector evaluation states that Annexes I to III of Regulation (EU) 2024/573 do not contain all fluorinated gases covered by the PFAS definition and that, conversely, there are fluorinated gases regulated by that Regulation which are not considered PFAS — the document gives SF6, HFC-23 and HFC-152a as examples.
- The question is asked substance by substance. Footnote 6 of the same document notes that the gases listed were identified as used "on their own or in blends". For a commercial blend, the check is done on the components, using the composition in the safety data sheet. See how to read a safety data sheet.
Do not apply the definition from memory to a gas that does not appear in the ECHA documents. If the substance is not named there, the correct answer is "not verified".
Which refrigerants the ECHA documents name
SEAC’s sector evaluation on applications of fluorinated gases, dated 10 March 2026, lists in its refrigeration chapter the fluorinated gases identified as being used, or having been used, in refrigeration, on their own or in blends, on the basis of the Background Document and the comments received in the consultation on the Annex XV report.
| Substances listed by SEAC for refrigeration | Status shown in the document |
|---|---|
| PFC-14, PFC-3-1-10, PFC-4-1-12, PFC-5-1-14, PFC-c-318, PFC-116, PFC-218 | Listed without the exclusion note |
| HFC-125, HFC-134a, HFC-143a, HFC-227ea, HFC-245fa | Listed without the exclusion note |
| H(C)FO-1224yd, H(C)FO-1233zd(E), HFO-1234yf, HFO-1234ze(Z/E), HFO-1336mzz(E) | Listed without the exclusion note |
| HFE-227ea, HFE-245cb2, HFE-347mcc3 (HFE-7000) | Listed without the exclusion note |
| HFC-23, HFC-32, HFC-152a, HFC-161, HFO-1132a | Marked with the note "not covered by the PFAS definition used by the Dossier Submitter" |
In the same section the document adds that all of the substances listed appear in Annexes I to III of Regulation (EU) 2024/573, and that a number of other substances, whose use in refrigeration in the Union could not be verified, were disregarded from SEAC’s assessment for precisely that reason.
The table reproduces a substance list from a committee working document, not a legal list. It shows what SEAC identified as being used in the sector, and for which substances the committee expressly noted that they fall outside the PFAS definition used in the dossier. Do not extend the list by analogy, and do not infer the status of a commercial blend without checking its components.
For the status of the gases you actually use under the law in force, see the product pages, for example R-134a, R-32 and R-1234yf.
How the proposal relates to the F-gas Regulation
SEAC describes the relationship between the two regimes explicitly. According to the sector evaluation, the main legislation relating to the use of fluorinated gases is Regulation (EU) 2024/573, whose focus is mainly on the global warming potential of the substances in scope and on limiting the use and emissions of high-GWP fluorinated gases.
The committee states that it identified significant overlaps with the F-gas Regulation which were not specifically addressed by the Dossier Submitter, and that it adopted its own approach to take those overlaps into account and to identify regulatory gaps, that is substances and applications covered by neither measure.
The method described in the document has four steps: identify the substances used in a specific application; cross-reference them with Annexes I to III of the F-gas Regulation; identify the applicable prohibitions in the Regulation for that application; and ascertain whether the use of the identified substances is already addressed by a prohibition in the Regulation.
The committee concludes that a REACH restriction remains the most appropriate risk management measure to address the concerns identified by the Dossier Submitter, which are different from the F-gas Regulation, focused on global warming potential. In certain application-specific cases a restriction can be considered inappropriate for practical considerations, where a prohibition under the F-gas Regulation indirectly already addresses, partially or fully, the risks identified.
In other words, the two regimes answer different questions. The F-gas Regulation is about climate and works with GWP, charge thresholds and ban dates; the PFAS proposal is about environmental persistence and works with a structural definition. A service company cannot infer a gas’s status under one regime from its status under the other.
What the draft opinion says about refrigeration, air conditioning and servicing
The derogation section of SEAC’s sector evaluation is, as at the date of this page, a draft that went out to consultation. It is not a decision and has no legal effect. The relevant conclusions are reproduced exactly as they stand, without extension.
- Alignment with the F-gas Regulation. The committee recommends aligning the REACH restriction with the F-gas Regulation for applications already covered by a prohibition in that Regulation; in those cases a restriction is not considered appropriate, because a legislative framework already exists. The committee states that policy decisions on how to implement that alignment in practice are for the decision maker.
- Refrigeration. Beyond the need to align the REACH restriction and the F-gas Regulation, SEAC cannot conclude whether additional application-specific derogations are justified.
- Air conditioning and heat pumps. The draft considers that a 5-year derogation, following the general 18-month transition period, is likely justified for PFAS as refrigerants in industrial uses of self-contained heat pumps and split systems with a maximum rated capacity above 12 kW. Beyond that and beyond alignment with the F-gas Regulation, the committee cannot conclude whether additional derogations are justified.
- Maintenance and refilling. For refrigerants used to maintain and refill existing HVACR equipment, the committee notes that the F-gas Regulation already contains a provision regulating repair and servicing of existing equipment, and recommends that a derogation for maintenance and refilling under the proposed REACH restriction be aligned with the relevant provisions of that Regulation.
The 18-month and 5-year periods appear in SEAC’s draft opinion as published on 26 March 2026 and are counted from the possible entry into force of a restriction that does not yet exist. They are not calendar dates, they are not final and they create no obligation. SEAC’s final opinion had not been published at the date of this page.
What changes today for a refrigeration business
Legally, nothing. As long as no restriction has been adopted and published, a company’s duties remain entirely those of Regulation (EU) 2024/573 and of the national acts that complete it.
What is still worth doing, with no speculation attached:
- Know which gas is in each installation. The records under Article 7 and the label under Article 12 of the Regulation already give you that. See equipment records and the equipment label.
- Know the composition of the blends you use. The safety data sheet is the source, not memory.
- Follow the primary source. ECHA’s PFAS topic page and the dossier record in the registry of restriction intentions are maintained by the agency; anything else is at best a retelling.
- Take technical decisions on the criteria that already apply. The Annex IV bans, the Article 13 servicing bans and the safety classes are criteria in force. See the ban timetable, the servicing bans and the decision tree.
What is not worth doing: switching refrigerant "because PFAS is coming". The final scope is not settled, and a substitution made on an assumption may solve nothing — not least because some low-GWP alternatives are, according to the SEAC document, among the substances identified in the sector.
Checklist
Checks that can be made today without assuming anything about the outcome of the procedure.
- Confirm that this is a proposalOn 22 September 2026 the ECHA registry showed the status Opinion development, and the adopted restriction field was empty.
- Read the definition in the dossier record, not in summariesThe definition is structural and carries an exclusion clause; it decides what the proposal covers.
- Check substances component by componentThe footnote in the SEAC document states that the gases were identified on their own or in blends.
- Do not confuse the two regimesAnnexes I to III of Regulation (EU) 2024/573 and the PFAS definition do not coincide; SEAC gives examples of regulated gases that are not considered PFAS.
- Treat the periods in the draft opinion as hypothesesThe 18-month transition and the 5-year derogation appear in a draft that went out to consultation.
- Keep the equipment records currentArticle 7 of Regulation (EU) 2024/573; the gas data is useful in any scenario.
- Follow ECHA’s PFAS topic pageThat is the page the agency updates; its news releases carry dates.
- Do not take commercial decisions on a proposalThere is no final scope, no date of application and no adopted list of derogations.
Frequently asked questions
Are PFAS banned in the EU?
No. On 22 September 2026 the universal restriction proposal was in the opinion development phase according to the ECHA registry, and the adopted restriction field was empty. Separate, older restrictions exist for certain substances, but they are not the subject of this page.
Is R-32 a PFAS?
In SEAC’s sector evaluation of 10 March 2026, HFC-32 appears in the list of gases identified in refrigeration with the express note that it is not covered by the PFAS definition used by the Dossier Submitter. That is a finding in a committee document, not a legal decision.
What about R-410A or R-454B?
The ECHA documents cited here list substances, not commercial blends, and state that the gases were identified on their own or in blends. The status of a blend is assessed on its components, and the composition is read from the safety data sheet. This page assigns no status to any blend.
When does the restriction enter into force?
There is no date. According to ECHA’s news release of 26 March 2026, SEAC is expected to adopt its final opinion by the end of 2026; the opinions are then submitted to the European Commission, which will propose a restriction for discussion and vote in the REACH Committee, composed of EU Member States.
Is the five-year derogation for heat pumps certain?
No. It appears in SEAC’s draft opinion, for industrial uses of self-contained heat pumps and split systems with a maximum rated capacity above 12 kW, phrased as "likely justified" and counted from a general 18-month transition period after a possible entry into force. The final opinion had not been published at the date of this page.
What should I do now?
Legally, nothing new. The duties in force remain those of Regulation (EU) 2024/573: records, leak checks, recovery, certification, labelling, and the placing-on-the-market and servicing bans.
Official sources
All sources were read on 22 September 2026. The ECHA website refuses plain automated requests, so the pages and the PDF were opened in a browser; every address returned HTTP 200.
How current this page is, and the limits of our liability
This page describes a proposal for a restriction under REACH, not a rule in force. The position reported is the one published by ECHA on 22 September 2026. No claim is made about the outcome of the procedure, the final scope, the derogations or any date of application, because none of those is decided. Check the ECHA source before acting.
General information prepared by EgoLog from documents published by ECHA. It is not legal advice and it is not a compliance assessment for any substance or mixture.
The duties that apply to fluorinated refrigerants today are those in Regulation (EU) 2024/573 and the national acts implementing it. Work is carried out by persons certified under Article 10 of that Regulation.