The refrigeration industry is no stranger to change. From compressor technology to energy efficiency, from refrigerant selection to system design, we’re constantly adapting to meet regulatory, environmental and efficiency demands. But one thing we need more than anything—especially when it comes to long-term investment, innovation and the move towards Net Zero—is clarity.
Currently, the UK’s position on F-Gas regulation offers anything but.
While the EU forges ahead with more aggressive 2024 updates to F-Gas legislation and we stand still under our own version of the 2014 rules, the UK industry finds itself in limbo. We’re caught between two regulatory regimes, trying to make the right choices for our customers, our business, and our planet—without knowing what framework we’ll be judged against in just a few years’ time.
That sounds like a problem, and it is. But it’s also an opportunity. If we act now with intelligence and flexibility, we can shape a UK refrigeration policy that’s more than just a copycat of European legislation—we can potentially make it better and reach the finishing line at the same time.
Steve Shipp, Managing Director, Ultra Refrigeration
Where We Are: Two Paths, One Destination?
The EU’s updated F-Gas regulation, effective from 2024, takes a bold stance. It sets a 95% reduction in HFC use by 2030 and introduces bans on equipment using refrigerants above 150 GWP for many applications. Meanwhile, the UK remains on a slower trajectory—having ratified the Kigali Amendment to the Montreal Protocol we’re aiming for an 85% reduction by 2036, with no clear roadmap to bridge the gap.
If the UK is still committed to the same end goal as the EU, then by not acting now we’re simply kicking the can down the road. And, of course, the later we act the shorter the timescale we’ll leave ourselves for implementation, bringing much greater upheaval for businesses like ours and our clients.
Northern Ireland: A Dilemma
Brexit’s legacy continues to cause headaches for UK manufacturers and distributors of F-Gas equipment because the Northern Ireland Protocol binds Northern Ireland to EU F-Gas regulations rather than UK regs. This creates a confusing, two-state situation for businesses operating throughout the UK, including Northern Ireland; do you manufacture something different just for Northern Ireland, or do you make sure everything you make in the UK complies to EU Regulations in case it ends up there?
This is an added and unwelcome complexity for UK manufacturers who must now navigate two sets of standards, increasing red tape and potentially discouraging domestic production. And, in fact, these waters have been further muddied by the exemptions from EU F-Gas regulations granted to refrigerated transport equipment in Northern Ireland; a practical approach given the necessity of actually moving perishable goods across the Irish Sea.
The Cost of Confusion
The truth is, because the UK has chosen to postpone the issue until later, most contractors and clients aren’t talking about F-Gas at all. It’s the elephant in the room. People know it’s there, but it’s not front of mind—until they have to replace a system or make a capital investment.
Then the UK’s lack of clear direction or timetable for implementation becomes a problem. It’s difficult to advise customers when the rules may change dramatically halfway through the expected life of a new installation. This uncertainty discourages innovation and pushes businesses to stick with what’s safe—even when it’s suboptimal.
We’ve seen examples of European manufacturers getting ahead of the game, while UK firms delay decisions. That creates a competitive disadvantage for domestic companies and leaves us vulnerable to the risk of outdated systems being dumped into the UK market, simply because they’re no longer legal to sell in the EU.
A Smarter Path Forward: Tiered GWP Limits
Here’s where we believe the UK can take a lead. Rather than mirroring the EU’s blanket ban on refrigerants above the arbitrarily set 150 GWP, we should consider a tiered approach—one that takes into account the application, the operating temperature, and the real-world performance of refrigerants.
For example, a 150 GWP limit may be perfectly reasonable for medium-temperature supermarket systems or chilled storage, where low-GWP alternatives are viable and efficient. But try applying that same standard to ultra-low temperature or blast freezing applications, and you quickly run into problems. Some of the best-performing refrigerants for these jobs all have a GWP of over 150 (but sometimes not by much, e.g. R454A at 238), and the compliant alternatives are either inefficient, impractical, or not yet scalable.
A tiered system would allow higher GWP limits in niche, technically demanding applications, while still pushing the bulk of the market towards greener solutions. It acknowledges the complexity of system design and respects the engineering that goes into selecting the right refrigerant for the right job. And we’ve already seen the EU granting exemptions that allow some equipment to use higher GWP refrigerants in some of these niche circumstances.
This is not a cop-out. It’s a more sophisticated approach that could be built into future legislation with minimal compromise to environmental goals.
More Focus on Efficiency
A system’s GWP rating matters very little if the refrigerant never leaks. The biggest impact on our journey to Net Zero often lies in energy efficiency, especially over a system’s lifetime. For example, CO₂ may have a GWP of 1, but in certain applications, especially transcritical applications without heat recovery, it performs so inefficiently that its total carbon footprint—once you factor in the electricity needed to run it—can outweigh that of higher-GWP systems.
If we’re serious about environmental targets, we need to look at both direct and indirect emissions. That means choosing refrigerants not only based on GWP, but also on how much energy they use and how reliably they perform. For some installations, flammable refrigerants like A2Ls are a great fit. For others, particularly at scale or in sensitive environments, we need to keep our options open.
A more intelligent, tiered approach to F-gas regulation should take application and temperature range into account. For ultra-low temperatures, we should be allowed a higher GWP limit. The number of those systems being built is just a fraction of the market compared to supermarket refrigeration or air conditioning. This flexibility would support both innovation and environmental goals without limiting us to inefficient (but supposedly ‘greener’) solutions.
We’re Ready. Are You?
At Ultra, we haven’t waited for UK legislation to make up its mind—we’re already on board with A2L-ready equipment, we’ve revised our design procedures, and we’ve trained our engineers to handle low-GWP refrigerants safely and efficiently. That proactive approach means we’re ready to meet EU standards today, whether or not the UK decides to align with them.
But not every business is in that position, and not every client is ready to invest. Until we know what the UK’s long-term stance is, many companies will continue to sit on their hands—and who can blame them? After all, it’s the safest, cheapest and easiest option.
However, if we want to avoid a last-minute scramble in 2027 or 2028, the time for clarity from government is now. And if we don’t take immediate collective action, the UK risks falling behind—the longer we take to get on board, the less experience we will have. Would clients rather use a company that’s worked with A2Ls for several years or one that’s just getting started?
A Question of Innovation
The current regulatory vacuum also limits innovation. When you don’t know which standards you’ll be designing to, it’s difficult to commit to R&D or to justify the higher upfront costs of advanced, future-proofed systems.
That’s a shame, because innovation is what keeps our industry moving forward. Whether it’s integrating heat recovery, experimenting with hybrid systems, or improving energy performance through smarter control strategies, innovation thrives in a well-defined environment with a clear vision of the future direction of travel.
Final Thoughts: Let’s Take the Lead
The UK refrigeration industry doesn’t need to be told what to do—we just need to know what rules we’re playing by. If we accept that our environmental goals are ultimately aligned with the EU’s, then dragging our feet doesn’t buy us time—it just shortens the window to act and adds cost and confusion in the process.
But rather than simply adopting the EU’s rules wholesale, we have the chance to design something better: legislation that is scientifically grounded, application-specific, and supportive of both innovation and efficiency.
A tiered GWP approach would strike that balance.
It’s time for government to step up, consult the industry, and give us the framework we need to do what we do best—build smarter, cleaner, and more efficient refrigeration systems for the future.
If you would like to discuss aspects of your existing refrigeration equipment, or want to talk about a new project, please get in touch by emailing us today at info@ultraref.co.uk or calling us on +44 (0) 330 2232404.
