Proposal for regulation of PFAS and TFA

In July 2021, a "Registration of Intent" (RoI) for the EU Chemicals Regulation 1907/2006 REACH was filed. This RoI is followed by a Dossier, a report documenting the harms of the chemicals targeted, on many fluorinated hydrocarbons. The Dossier has been delivered in January 2023 and published on 2023-02-07. From 2023-03-23, persons, companies and associations have some months time to deliver their statements. Possible rules and regulations in REACH could become valid from 2025.

The Dossier was delivered by 5 national European chemical agencies. In the definition it includes all substances with fully fluorinated carbon groups, meaning middle groups CF2 and end groups CF3. The abbreviation PFAS stands for "per- and polyfluoroalkyl substances". In total it is about 4000 .. 15000 chemicals.

These chemicals are either persistent in nature themselves, meaning very durable, or their breakdown products are persistent in nature. For the non commercially available or not existing substances, similar behaviour is assumed. One of the breakdown products of many refrigerants is trifluoro acid or trifluoro acetic acid (TFA). This substance is washed out of the atmosphere by rain if it is formed from gases at relevant altitudes. It is very stable in the environment and can influence metabolic processes in organisms.

For refrigeration, use bans for the mentioned chemicals can create difficulties in several areas:

Listing these chemicals as substances of high concern in REACH can lead to ban of many uses, and even to significant limitations for applications or to high handling safety measures and qualification demands for the users. As the main target, the writers of the Dossier name bans.

The additional regulation of refrigerants under REACH can limit the possibilities of the refrigeration industry to fulfil the demands of the F-Gas Regulation significantly.


Substance Information - ECHA (

Registry of restriction intentions until outcome - ECHA (

Proposals of the Dossier 2023-01

The published Dossier contains a watermark with the text „pre-publication – do not cite“. This text is, however, the only publicly available one. Thus, here it is assumed, that the main targets of the Dossier authors are contained.

The proposal is to ban up to 15000 substances, with the main reason, that the substances themselves or their breakdown products are highly persistent in nature.
For about 1500 substances analysed more in detail, risks to environment or human health are documented in entries for REACH 1907/2006/EC or CLP 1272/2008/EC, defining them as substances of concern. For many others similar behaviour is estimated based on analogies in the molecular structure. For many materials, where danger to human health is excluded based on extensive testing, like R134a being a permitted asthma spray propellant or PTFE (Teflon) being released for food contact and for cookware coating, the only reason left for a ban could be the persistence. The large scale ban is accompanied by a few timely not limited excemptions and a series of timely limited excemptions – derogations. The timely limited derogations of 5 or 12 years add on the 1.5 years delay between publication of the decision and activation of the rules, resulting in 6.5 and 13.5 years in the table below.
When using derogations, a managemant plan and a specific documentation for every use site has to be established and checked or updated yearly.

For refrigerants the following derogations are proposed:

Time span



6.5 years

cooling <-50°C

13.5 years

laboratory equipment

13.5 years

refrigerated centrifuges

because no solution for flammable refrigerants in case of a break of the centrifuge is known

13.5 years

maintenance and refill of HVACR systems

This is shorter than the life span of many systems.


HVACR, where national safety standards do not allow alternatives

corresponds to a text in the F-Gas Regulation revision proposal

6.5 years

mobile air conditioning in combination with combustion engine

6.5 years

transport refrigeration except marine

13.5 years

refrigerants in military vehicles

only maybe, as no real reasons for exceptions are available

Fluorinated refrigerants that are not intended to be banned as PFAS would e.g. be

R152a and R1132a are in safety class A2, R1132(E) in B2 and thus easily ignitable. R23 is only available for temperatures <-50°C according to the F-Gas Regulation and uses too much quota because of the high global warming potential. R32 also has too high GWP for long term use in large amounts.

For fluorinated plastics for use in machine parts and refrigeration systems, no exceptions or derogations are considered. Several of these materials are in use in refrigeration systems and their components. Gaskets and seals, like O-rings made of FKM, FPM or PTFE would not be permitted to be used from 1.5 years after decision and publication.

As a limit value for prohibited substances, it shall be documented that


Registry of restriction intentions until outcome - ECHA (

Media briefing: proposal to restrict PFAS chemicals in the EU - YouTube