F-Gas Phasedown Delay Brings Breathing Space – But Not a Reprieve

For much of the past three years, the UK refrigeration, air conditioning, and heat pump (RACHP) industry has been operating in a state of anticipation. Since the Department for Environment, Food and Rural Affairs (DEFRA) published its review of the F-Gas Regulation (EU 517/2014) in December 2022, businesses across the supply chain have been waiting to understand what the next phase of Great Britain's hydrofluorocarbon (HFC) phasedown strategy would look like.

While the European Union moved swiftly, publishing its proposals in 2023 and formally adopting the new F-Gas Regulation (EU 2024/573) in March 2024, the picture in Great Britain remained unclear. Northern Ireland, under existing arrangements, continues to follow EU F-Gas legislation, but stakeholders in England, Scotland and Wales were left waiting for a domestic policy direction.

That wait finally ended on 5th November 2025 when DEFRA launched a consultation on a revised GB HFC phasedown. However, the consultation raised almost as many questions as it answered. Industry was given just six weeks to review and respond to proposals that would have fundamentally altered the availability of refrigerants across the market.

Wider issues

The headline proposal was significant. DEFRA suggested reducing the HFC quota from 31% of baseline levels to 16.2% from 1 January 2027. In practical terms, this represented a 47.7% reduction in refrigerant availability almost overnight. Notably, the consultation focused solely on the phasedown mechanism itself and did not address wider issues that many businesses had expected to see, including additional product bans, servicing restrictions, or changes to training and certification requirements.

For manufacturers, contractors, wholesalers and end users alike, such a sharp reduction raised concerns about supply chain resilience, refrigerant pricing, retrofit demand and the industry's ability to transition at the required pace. While the long-term objective of reducing reliance on higher global warming potential (GWP) refrigerants is broadly accepted across the sector, the proposed timeline prompted questions about whether the market could realistically absorb such a dramatic shift without unintended consequences.

Following consultation with its members, FETA argued for a more measured approach. The federation proposed a gentler reduction in quota levels during the 2027 and 2030 milestones, allowing industry additional time to adapt while still delivering meaningful emissions reductions. The recommendation was designed to align more closely with DEFRA's longer-term trajectory while avoiding a sudden supply shock in the late 2020s.

Surprise

When DEFRA finally published its response on 15th May this year, the outcome surprised many observers. Rather than proceeding with the proposed accelerated phasedown, the department concluded that further work was required before any final decisions could be made. To provide certainty to industry, DEFRA announced that no additional changes would be introduced from January 2027 and committed to outlining its next steps later in the year.

At first glance, the announcement appears to be positive news. Businesses have gained valuable time to prepare for future changes, review refrigerant strategies and continue investing in lower-GWP technologies. In a market already managing skills shortages, increasing heat pump deployment and evolving sustainability requirements, additional breathing space will be welcomed by many. However, there is a danger that the announcement could be interpreted as a pause in the transition. It is not.

DEFRA has been clear that the existing GB F-Gas Regulation remains fully in force. Under current legislation, the HFC quota will still fall from 31% of baseline levels to 24% from 1 January 2027. Although less severe than the consultation proposal, this still represents a 22.6% reduction in refrigerant availability and will create its own set of challenges for the market.

Preparation rather than complacency

The message for industry is therefore one of preparation rather than complacency. Contractors and end users should continue prioritising lower-GWP refrigerants where technically and economically feasible. Equipment manufacturers must maintain investment in future-proof product portfolios, while wholesalers and service providers will need to manage the implications of tighter refrigerant availability and changing customer demand.

Perhaps most importantly, stakeholders should remember that F-Gas legislation extends far beyond quota allocations. Existing product bans and placing-on-the-market restrictions remain in force and will continue to shape technology choices across the RACHP sector.

The delayed phasedown decision may have postponed a major regulatory change, but the direction of travel remains unchanged. The transition away from higher-GWP refrigerants is continuing, and businesses that use this period to plan, invest and adapt will be best placed to navigate whatever policy framework emerges next.

FETA has been very active with political lobbying for the past 18 months and has succeeded in getting a number of written questions tabled in both Houses of Parliament. These concerned when the consultation was going to be published, which was causing industry a great deal of uncertainty. Subsequent to the consultation we have been pushing for more detail and timelines. FETA will continue working with government and industry to ensure the transition is both environmentally effective and practically achievable.