PFAS and Refrigerants: What Should We Conclude?

PFAS and Refrigerants Context

Per- and polyfluoroalkyl substances (PFAS) form a family of synthetic chemical compounds often called “forever chemicals” due to their persistence in the environment and resistance to natural degradation.

Used since the 1950s, they are found in various products:

• Textiles
• Food packaging
• Firefighting foams
• Refrigerants

Refrigerants, such as hydrofluorocarbons (HFC) and hydrofluoroolefins (HFO), are essential in refrigeration and air conditioning systems. Some of these compounds belong to the PFAS category due to their chemical structure containing carbon-fluorine bonds.

Although not all are persistent or bioaccumulative, their degradation can produce concerning by-products, such as trifluoroacetic acid (TFA), detected in the environment and drinking water.

The REACH Regulatory Framework

The EU REACH regulation (Registration, Evaluation, Authorization and Restriction of Chemicals) aims to ensure a high level of protection for human health and the environment.

In February 2023, five European countries (Germany, Netherlands, Denmark, Sweden and Norway) proposed a comprehensive restriction covering more than 10,000 PFAS, including some HFC and HFO used as refrigerants.

This proposal is currently under evaluation, with a public consultation conducted until September 2023.

HFO Refrigerants: Controversial Alternatives

Hydrofluoroolefins (HFO) were developed as alternatives to HFCs to reduce their climate impact. These compounds feature:

• A very low Global Warming Potential (GWP) (often close to zero)
• Rapid degradation in the atmosphere
• Minimized impact on the ozone layer and climate

Main HFOs

R1234yf

• Primarily used in automotive air conditioning systems

R1234ze

• Used in commercial and industrial refrigeration
• Used in heat pumps

Comparison with HFCs and TFA Impact

A key difference between HFOs and HFCs lies in their contribution to TFA formation during atmospheric degradation.

Advantages of HFOs

1. Reduction of climate potential

• Their GWP is extremely low
• R1234yf: GWP = 4
• R1234ze: GWP = 1
• Comparison: R134a (HFC) = GWP 1430

2. Compatibility with existing technologies

• HFOs can be used with minimal modifications to existing infrastructure

Problems with HFOs

1. Degradation by-products

• HFOs can transform into TFA in the atmosphere
• TFA is a very persistent compound detected in the environment

2. REACH restriction risk

• As members of the PFAS family, HFOs are subject to strict evaluation
• Inclusion in the REACH restriction proposal

Impact of REACH Regulation on HFOs

The PFAS restriction proposal under the REACH regulation includes certain HFOs such as R1234yf and R1234ze.

Potential Consequences

Mandatory substitution

• Manufacturers must demonstrate the absence of technically and economically viable alternatives before using these HFOs

Strict monitoring requirements

• HFOs will face increased environmental monitoring obligations
• Prevention of impacts related to their degradation

Conclusion and Perspectives

HFOs represent significant progress in reducing the climate impact of refrigerants. However, their classification within the PFAS family and their inclusion in REACH restrictions pose major challenges for the industry.

To achieve balanced regulation, it is crucial to:

1. Differentiate types of PFAS

Based on:

• Their persistence in the environment
• Their bioaccumulation potential

2. Encourage research

On HFO alternatives to provide solutions that are:

• Innovative
• Sustainable

3. Find a balance

Between:

• Environmental protection
• Industrial competitiveness

By avoiding disproportionate restrictions that could harm the refrigeration and air conditioning sector.

Thus, regulation must find a balance between environmental requirements and the need to maintain effective technical solutions for the refrigeration and air conditioning sector.

Additional Resources

Discover our other articles on regulation:

• Key steps for compliance
• DESP regulation & The CTP
• DESP 2014/68/EU: GUIDE
• DESP – Directive 2014/68/EU: Compliance
• EN 378: Risk Analysis
• HFC Tax – Application from January 1, 2025
• PFAS – TFA, eternal pollutant and refrigerant

Watch our cDESP tool presentation video

Source: The DCRR team