Material Insights · Understanding the Material World

Fluorochemicals and refrigerants: Regulation

How the Kigali deal is phasing down HFCs worldwide

What this tab covers How it is regulated and what could disrupt supply: hazard classification, rules in the EU, US and India, anti-dumping duties and other trade measures, and supply-risk notes.

Hazards

ClassificationUN numberKey risks
gases under pressure; R32 and HFOs flammable gas cat 1B (A2L); asphyxiant in confined spacesUN3252 (R32), UN3159 (R134a), UN1018 (R22)Climate impact from leaks; frostbite and asphyxiation; decomposition to HF in fires.

Main rules

WhereRuleEffect
GlobalMontreal Protocol and Kigali Amendment (2016)HCFC phase-out and HFC phase-down by about 80-85% by the late 2040s
EUF-gas Regulation (EU) 2024/573; MAC Directive; proposed universal PFAS restrictionHFC phase-out by 2050; possible limits on HFOs
USAIM Act (2020) and EPA Technology Transitions rule85% HFC cut by 2036; GWP limits for new equipment
ChinaHFC production and consumption quotas from 2024 (MEE)caps supply; HFC-23 destruction required

India

RuleEffect
Ozone Depleting Substances (Regulation and Control) Rules 2000 (HCFCs and, as amended, HFC production limits); MoEFCC office memorandum of 1 April 2026: no environmental clearance for new or expanded HFC capacity for controlled uses unless it starts production by 31 December 2027; freeze at the 2024-2026 baseline from 1 January 2028quota allocation will set winners
India Cooling Action Plan (2019)targets lower refrigerant demand and better servicing
MSIHC Rules 1989; PESO rules for gas cylindersplant and cylinder safety

Trade measures

  • EU and US enforcement against illegal HFC imports
  • Past DGTR anti-dumping actions on some refrigerants from China (indicative; check DGTR)

Supply risk

High concentration: China holds over 80% of world HFC quotas and about 60% of fluorspar mining. Fluorspar is on EU, US and Indian critical minerals lists (fluorspar tile).