Great Britain F-Gas Update Proposals Published

After two years of expectation, on 5th November 2025 the Department for Environment, Food and Rural Affairs (Defra) lit the blue touch paper and published a consultation on its proposal to update the Great Britain F-Gas Legislation.

What Does it Cover?

The current consultation only covers the HFC Phasedown, acknowledging the need to be compliant with the Kigali amendment of the Montreal Protocol and proposing to exceed what is required to assist with the UK’s commitment to achieve net zero emissions by 2050.

What are the proposed changes to the HFC Phasedown?

The preferred option proposed is a greatly accelerated phasedown going well beyond the current 2030 date. Defra considered several scenarios which are shown in the following table, with the proposed option being what is described as a “High ambition phasedown option” (Column 3) which will more double the current reduction by 2030 and lead to a 98.6% reduction (compared to 2015) by 2048.

Is this the final Regulation?

No, this is a proposal for consultation with industry. The consultation is open until 17th December 2025. Any individual, company or organisation can comment on the proposal. Defra are also using the opportunity to gather opinions on training and certification needs and are particularly interested in feedback to better understand potential scale of impacts on different sized businesses, which has been identified as an evidence gap. If you feel these proposals will have a significant impact on your business, please do not leave it to others, do participate in the consultation.

The preferred participation channel is via the following link, although email and postal comments will also be considered, provided they are received before the deadline. F gas Regulation in Great Britain: Reform of the HFC phasedown - Page 1 of 5 - Defra - Citizen Space

Is the phasedown proposal different to the EU F-Gas Regulation?

Yes, the phasedown proposal is different to the current EU 2024/573 regulation. The prosed GB phasedown is initially a little slower than the EU but from 2039 is more aggressive, although unlike the EU legislation, the GB proposal does not go to a total phaseout in 2050.

Are there any product bans within this proposal?

No, there are no product bans within this proposal. The placing on the market, maintenance and >2500 GWP restrictions introduced with the current GB legislation will remain valid, but this proposal does not consider any further use restrictions. This does not mean that there will not be any further restrictions in the future, although Defra have stated they believe the HFC phasedown has been the most effective measure to reduce the use of higher GWP refrigerants.

Is there a change to training and certification requirements?

No, there are no proposed changes to training and certification requirements. Defra have recognised that there is currently a gap in the training and certification requirements for non-fluorinated refrigerants and are consulting with industry with a view to future legislative changes. Industry Associations are lobbying Defra and suggesting to follow the training and certification requirements in the EU legislation but for now there is no change. Although training and certification are out of scope of this consultation, it is understood there is a question concerning this within the online consultation questionnaire.

How might these proposed changes effect availability of F-Gas refrigerants?

Exactly how these changes will affect the availability of particular refrigerants is almost impossible to predict, but it is difficult to see any scenario where the proposed 2027 cut would not have an impact, especially on those refrigerants with a GWP >1000.

The proposed phasedown is for HFCs only. HFO products such as R-1234yf, R-1234ze, R-1233zd, R-1336mzz(Z) are not included in the phasedown.

For new installations, choosing the lowest GWP refrigerant, most suitable for the application will be critical to navigating the accelerated phasedown, with the least disruption to operations.

What Low GWP alternatives are available?

There are many low GWP alternatives available but most either have a different safety classification or significantly different physical properties meaning they are likely to be for new equipment use only. A full list can be found on the Climalife UK website. Refrigerant_Pathway_420x594_EN_FINAL_BAT.pdf

Are there any changes to refrigerant recovery, recycling, reclamation or leak checking?

No, these are outside the scope of the current consultation. The requirements introduced with the current GB legislation remain valid, but this proposal does not consider any further requirements.

What happens next? Will there be another opportunity to comment?

After the consultation closes the responses will be considered by Defra and any changes to the current proposal that are deemed necessary will be made. It is not clear if a further publication will be made before the final legislation comes into force, but it is very unlikely there will be any further opportunity to influence the final regulation. It is critical that any comments are made before the December 17th deadline if you want them to be considered by Defra.

Although no timetable has been published for next steps, the fact that the proposal begins 1st January 2027 suggests that this will be progressed quickly.

Need more answers?

If you have any further questions or require assistance with refrigerant management please contact climalife.uk@climalife.dehon.com .