Spotlight on the EU F-Gas Regulation Review: What It Led To

When this policy discussion was originally recorded, the review of EU Regulation 517/2014 was still underway. As of June 2026, that review has already concluded and the EU now operates under Regulation 2024/573. This post is best read as a snapshot of the debate that led into those changes.

Why the Kigali Amendment Isn’t Enough

A paper published in Nature Climate Change — Achieving Paris climate goals calls for increasing ambition of the Kigali Amendment — modelled HFC emissions through 2050 and concluded that the current Kigali phasedown trajectory is not consistent with a 1.5°C target. The orange band representing 1.5°C-compatible emissions sits well below the projected Kigali outcome.

“There is still a lot more to be done globally to address HFC emissions. The Kigali Amendment will need to be adjusted, and the impact of removing barriers to the uptake of natural refrigerants… really cannot be understated.”

For UK and EU engineers, the practical reality is that the review did in fact lead to tighter EU limits under 2024/573, while Great Britain continued on its own retained legal path.

IEC 60335-2-40 Edition 7: The Game-Changer for Hydrocarbons

The new edition of the safety standard for air conditioners, heat pumps, and dehumidifiers was put to final vote on 29 April, with publication expected in early June. The headline change is much larger allowable charges of A2L and A3 refrigerants — most importantly propane (R290).

Under the previous edition, a wall-mounted split system in a typical 20 m² living room was effectively limited to around 300 g of R290 — far short of the 450–500 g needed for an efficient split air conditioner. Edition 7 unlocks this by introducing four mitigation strategies:

1. Releasable charge — only refrigerant that can actually leak into the occupied space counts toward the charge limit. For a typical split system, around 80% of the refrigerant sits outdoors and can be excluded.
2. Airflow — circulation prevents leaked refrigerant from settling at floor level, where it would otherwise reach ignition concentration.
3. Enhanced tightness — additional construction requirements allow a lower assumed leak rate (the current standard assumes a quarter of the charge leaks per minute, which is unrealistic outside catastrophic damage).
4. Charge optimisation — lighter hydrocarbon mass means a smaller charge can deliver equivalent capacity.

The result:

• ~1 kg of R290 indoors for split systems
• ~5 kg of R290 outdoors for air-to-water heat pumps (already permitted since 2004 but increasingly mainstream)
• EN 378 already permits up to 1.5 kg of R290 indoors for systems in spaces with ordinary public access

“This new standard, I would argue, marks a transition away from the high-GWP HFCs.”

Edition 7 won’t be harmonised under EU law from day one — that typically takes two to three years. However, manufacturers can apply it immediately via a risk assessment / “other specification” route, the same mechanism already used to deploy IEC 60335-2-89 for up to 500 g of propane in commercial display cabinets.

This matters for City & Guilds 2079 Skill Group 9 (Other Refrigerants) and Skill Group 11 (System Selection) — expect more questions on hydrocarbon charge limits, mitigation measures, and the safety case for A3 systems.

What EIA Wants From the F-Gas Review

EIA’s position on the review focuses on five priorities:

• Accelerated phasedown aligned with 1.5°C
• Stronger placing-on-the-market bans, including a complete ban on R404A
• Lower GWP thresholds — the current 150 limit was set arbitrarily, and the 2,500 limit on stationary refrigeration equipment is now considered unambitious
• Polluter pays mechanisms — a quota allocation fee or auction
• End-of-life producer responsibility schemes for refrigerant recovery

Specific sectoral asks include:

• Single-split AC bans (now feasible thanks to IEC Edition 7)
• Chillers and condensing units
• Transport refrigeration (where producers say bans drive innovation)
• Heat pumps — avoiding lock-in of HFC technology as the heating sector electrifies
• Removing the primary-circuit exemption in commercial refrigeration so systems can move fully to CO₂
• Lowering the stationary equipment threshold from 2,500 GWP to 150 or lower, and removing low-temperature exemptions

“We need to be careful about where we go to next, and it’s really time to get off the chemical treadmill.”

The HFO Problem

HFOs are often presented as the obvious replacement for high-GWP HFCs, but EIA flags three concerns engineers should understand for the exam:

• TFA breakdown — R1234yf decomposes in the atmosphere to trifluoroacetic acid, a PFAS “forever chemical”
• Manufacturing footprint — some critics argue that lifecycle emissions remain too high to treat HFOs as a clean end-state
• Illegal trade risk — HFOs are significantly more expensive than HFCs, creating a strong incentive for technicians to “drop in” cheaper illegal HFC during servicing

This is directly relevant to Skill Group 1 (Basic Knowledge of Environmental Issues) and Skill Group 4 (Leakage Checks) — examiners increasingly expect candidates to articulate the trade-offs between A1 HFO blends and natural alternatives.

Tackling Climate Crime

Illegal HFC trade can materially undermine the quota system. The proposed solutions:

• Linking HFCs to the EU Single Window customs system (addresses front-door smuggling)
• Supply chain traceability and due diligence (addresses back-door smuggling)
• A QR-code tracking scheme similar to the one the US is rolling out under the AIM Act from 2025

For F-Gas certified engineers, this means tighter scrutiny of cylinder provenance, more documentation at point of sale, and stronger enforcement around servicing logs — all areas covered under Skill Group 2 (Refrigerant Handling) and Skill Group 10 (Records and Reporting).

How F-Gas Exam Prep Fits Into This

The F-Gas Regulation review and IEC 60335-2-40 Edition 7 are reshaping the syllabus underneath every City & Guilds 2079 candidate. The F-Gas Exam Prep app helps you stay ahead:

• 460+ exam questions mapped to all 11 skill groups plus Health & Safety, including the latest content on hydrocarbon charge limits, GWP thresholds, and quota systems
• Mock exams that mirror the real City & Guilds 2079 format, so you walk into your assessment knowing exactly what to expect
• AI voice challenges that quiz you out loud — perfect for revision while driving between jobs
• Detailed explanations for every answer, so you understand why the limit is 150 GWP, why releasable charge matters, and why some stakeholders question HFOs as a long-term answer

Available on iOS and Android — the most efficient way to get exam-ready while the regulatory landscape keeps moving.