Upcoming REACH restriction of PFAS and impact on the HVAC&R industry

The wide PFAS definition used in the Registry of Intentions under REACH resulted in unprecedented coverage of a huge group of very different substances. The analysis of impacted substances and their use in the HVACR industry (and in all other industries) requires a major effort – from understanding the use of these substances in the whole supply chain to analyzing the potential impact on the manufacturing processes.

Finding alternative substances will be very time-consuming, if feasible at all. The properties of most of the substances are the main reason for using them. Known alternatives are lacking in performance and will endanger the longevity and reliability of HVACR products. The HVACR industry has the additional challenge of meeting the F-gas phase down targets of the current F-gas regulation The expected phase down in the review of the current regulation will even be much tighter – and relies heavily on low GWP blends which are based on HFOs. But those HFOs will be covered, too, within the restriction dossier for PFAS under REACH, due to the rather high decomposition of some HFOs into TFAs, when emitted into the atmosphere.

TFA is considered as a persistent substance and therefore included in the PBT definition (persistent, bio-accumulative, toxic). The unfortunate timing between the 2 legal acts leads to a conundrum for the HVACR industry – even if a tighter F-gas phase down in a reviewed F-gas regulation appears to be feasible – the later possible restrictions of some HFOs will render this judgement obsolete. And the end-result could be a serious disturbance of the billions of existing HVACR applications in Europe that provide critical services to society!