A facilities manager rang me in June, pleased with himself. He had read that the government had dropped the F-Gas changes and wanted to know whether that meant he could leave the R404A pack at his distribution site alone for another five years. It was a fair reading of the headlines. It was also completely the wrong conclusion, and it is going to be an expensive one for a lot of businesses.
What DEFRA did in May was postpone making the phase-down steeper. It did not cancel the phase-down that is already in law. The step that lands on 1 January 2027 is still coming, and as I write this it is under four months away.
What was actually decided
In November 2025, DEFRA opened a consultation on reforming the GB HFC phase-down. Among the proposals was one to "Adjust the existing percentage phasedown schedule from 1 January 2027" and add further steps out to 2050. The consultation closed on 17 December 2025.
In May 2026, DEFRA confirmed it would not legislate in 2026 to change those steps, having concluded that more work was needed on the design. Trade press reported the decision at the time, noting that under the existing legislation "the GB market is still facing a reduction in 2026 quota of 22.6% on 1 January 2027", with a further 12.5% reduction in 2030.
Read that sentence again, because it is the whole point of this article. The reform was delayed. The cut was not. Somewhere between a fifth and a quarter of the quota comes out of the GB market on New Year's Day, and nothing that happened in May changed it.
What a quota cut does, and what it does not do
This is where most of the confusion sits, so it is worth being precise.
The phase-down does not ban a refrigerant, and it does not make your existing system illegal. It limits the quantity of HFCs, measured in CO₂ equivalent, that can be placed on the GB market. Producers and importers hold quota. When the quota falls, the total tonnage of new gas available falls with it.
Because quota is denominated in CO₂ equivalent rather than in kilograms, the squeeze does not land evenly. A tonne of quota buys you a great deal of a low-GWP gas and very little of a high-GWP one. That is deliberate: it is the mechanism that pushes the market off the worst gases first.
The practical consequences are three:
- Price. High-GWP refrigerants consume disproportionate quota, so they get expensive first and fastest. Anyone who lived through the 2017 and 2018 R404A price spike has seen this film before.
- Availability. Not a shortage of gas in the abstract, but wholesalers rationing what they hold and prioritising contract customers. If you need forty kilos in August you may be told what you can have rather than asked what you want.
- Repair economics. A leak on a high-GWP system stops being a routine commercial refrigeration repair and becomes a replacement conversation, because the gas to refill it costs more than it did the last time.
Which of your plant is exposed
Exposure tracks global warming potential, and GWP is a published figure rather than a matter of opinion. The HFC figures below are from the GOV.UK list of F gases, which is what the regulation itself works from. R290 and R744 are not F gases and do not appear on that list, so they carry no quota and are shown here only for comparison.
| Refrigerant | GWP | Typically found in | Quota exposure |
|---|---|---|---|
| R404A | 3,922 | Older commercial packs, cold rooms, cabinets | Highest. Already scarce and costly |
| R410A | 2,088 | Air conditioning, some refrigeration | High. See the R410A phase-out |
| R134a | 1,430 | Cabinets, bottle coolers, chillers | Moderate to high |
| Lower-GWP HFC/HFO blends | Several hundred to ~1,400 | Retrofits and newer plant | Lower, but still inside the quota system |
| R290 (propane) | Very low, not an F gas | Integral cabinets, small packs | Outside the HFC quota |
| R744 (CO₂) | The reference gas, not an F gas | Retail packs, larger systems | Outside the HFC quota |
Note the arithmetic in the R404A row. At a GWP of 3,922, a single 10kg charge is nearly 40 tonnes of CO₂ equivalent. GOV.UK uses exactly that example: 10kg of R404A works out at "0.01 tonnes × 3,922 GWP = 39.2 tonnes CO2 equivalent". That is why a modest-looking system on an old gas eats quota, and why it is the first thing wholesalers start rationing.
The alternatives are not all equivalent either. R290 is an excellent refrigerant and it is flammable, which changes charge limits, plant room requirements and who is allowed to work on it. CO₂ runs at pressures that need different components and a differently trained engineer, and we have written about where it fits in CO₂ (R744) refrigeration systems. Neither is a drop-in.
The duties do not move, whatever happens to quota
Two things get conflated: the phase-down, which is about supply, and the F-Gas operator duties, which apply now and are unaffected by any of this. Worth separating them, because only one has enforcement behind it today.
The point that matters for the decisions in this article is that the duty is set by CO₂ equivalent, not by the physical size of the plant. A compact system on R404A can carry a heavier obligation than a much larger one on a low-GWP gas, purely because of the multiplication. GOV.UK sets the leak check frequency by charge: at least once every 12 months from 5 to less than 50 tonnes CO₂e, every 6 months from 50 to less than 500, and every 3 months at 500 or more, with automatic leak detection doubling each interval and becoming mandatory at 500 tonnes.
One carve-out is worth knowing because it catches people out in both directions. The same guidance states there is "no maximum period of time between leak checks on: hermetically sealed refrigeration and air conditioning systems unless they contain F gas equivalent to 10 tonnes of carbon dioxide". So a sealed cabinet is often outside the checking regime altogether, and a sealed system above that threshold is firmly inside it.
We have covered the full picture, including the record-keeping duties and who counts as the operator on a leased estate, in our guide to the UK F-Gas regulations and in F-Gas compliance across multi-site estates. Rather than repeat it here, the short version is that the duty sits with you as the operator, not with your contractor, and the estates that fail an inspection have usually done the checks. Their paperwork just lives in six different contractors' systems.
Working out your own exposure
You do not need a consultant for this. You need one line per system and three columns.
- Refrigerant type. Off the nameplate, or off your last service report. Do not assume, because systems get retrofitted and nameplates do not always get updated.
- Charge in kilograms. Also off the nameplate or the commissioning record.
- GWP, from the GOV.UK list of F gases.
Then: kilograms divided by 1,000, multiplied by GWP, gives tonnes of CO₂ equivalent. That single number tells you your leak check interval, whether you need automatic leak detection, whether you are inside the record-keeping regime, and roughly how hard the 2027 step is going to hit that particular system.
Do it across every site and two things usually fall out of the spreadsheet. First, a handful of systems you had not thought about turn out to be the ones carrying the compliance burden. Second, the sites you assumed were fine because they are newest are sometimes on R410A, which is squarely in the firing line.
What to do between now and January
Four months is enough time to make good decisions and not enough time to make them slowly.
- Inventory the refrigerants across the estate. Everything else depends on this and most operators do not have it in one place. If you do nothing else on this list, do this one.
- Identify the high-GWP systems that are also old. Anything on R404A that is already unreliable is not going to get cheaper to run. Plan its replacement rather than waiting for the leak that forces the decision in the middle of a heatwave.
- Fix known leaks now. A system that has been topped up twice this year is a system that will need gas at exactly the moment gas is hardest to get. This is also, plainly, the law.
- Check your leak check intervals are actually being met. Not booked. Met, with records you can produce.
- Do not panic-retrofit. A retrofit onto a lower-GWP blend is sometimes the right answer and sometimes throws good money at a system that needs replacing. It depends on the age of the plant, the compressor, the oil and the controls. Get it assessed rather than assumed.
- Build the phase-down into your capital plan. If you are replacing plant in 2027 or 2028 anyway, choosing the refrigerant now is free. Choosing it after a breakdown is not.
The honest position is that nobody knows exactly what will happen to prices in January. What we do know is what happened in 2017, when R404A went up several times over inside a year, and what the law says is going to happen to quota. Planning against those two facts is not alarmism. It is just arithmetic.
Frequently asked questions
Did the UK cancel the F-Gas phase-down in 2026?
No. DEFRA decided in May 2026 not to legislate that year to change the phase-down steps. The reform was postponed, but the phase-down already written into GB law continues, including the step that takes effect on 1 January 2027.
Is R404A banned?
It is not banned to keep running an existing R404A system, and there is no requirement to rip it out. What is happening is that the quota system makes new high-GWP gas progressively scarcer and more expensive, so keeping such a system gassed becomes the problem rather than owning it.
How do I calculate the CO₂ equivalent of my refrigerant charge?
Divide the charge in kilograms by 1,000 to get tonnes, then multiply by the refrigerant's global warming potential. GOV.UK's worked example is 10kg of R404A: 0.01 tonnes multiplied by a GWP of 3,922 gives 39.2 tonnes CO₂ equivalent.
How often do my systems need leak checking?
It depends on CO₂ equivalent charge, not physical size. From 5 to 50 tonnes it is at least every 12 months, 50 to 500 tonnes at least every 6 months, and 500 tonnes or more at least every 3 months. Fitting automatic leak detection halves the frequency in each band, and is mandatory at 500 tonnes and above.
Who is responsible for F-Gas records, me or my contractor?
You are, as the operator of the equipment. Your contractor produces the information and their certificate number goes into the record, but the duty to hold five years of records sits with you.
Should I retrofit to a lower-GWP refrigerant or replace the system?
It depends on the age and condition of the plant. A retrofit on a sound system with years of life left can be sensible. On a system that is already unreliable it usually just delays the replacement while adding cost. The test is whether you would be happy owning that plant for another eight years on any refrigerant.
Where to start
The businesses that came through the R404A squeeze well were not the ones with the newest equipment. They were the ones who knew what gas was in what system before the price moved, so when a decision had to be made they made it in an office rather than on a Saturday with a broken cold room and a wholesaler who could not help.
If you do not currently have a single list of the refrigerants across your sites, that is the job for this month. Talk to us about your refrigeration plant and we will work through what you have, what the 2027 step means for each of it, and which systems are worth retrofitting rather than replacing.
About the author: Ali Elm runs Be Cool Refrigeration & Air Conditioning, a family-run London firm that has been installing, servicing and repairing commercial refrigeration and air conditioning since 2004. His F-Gas certified team has delivered more than 2,000 projects across London and the South East.
Last updated: 2 September 2026
Written by
Ali Elm
Ali is the Head of Operations at Be Cool Refrigeration with over a decade of hands-on experience in HVAC and commercial refrigeration. He oversees every installation, repair, and maintenance project, making sure the work meets the highest standards. Ali holds full F-Gas certification and has worked across residential, commercial, and industrial refrigeration systems throughout London and the South East. When he is not on site, he writes these guides to help business owners and homeowners understand their cooling systems better.