The IOR is preparing feedback on the EU F Gas regulation consultation, responses are due 17^th December.  

Are you an installer, manufacturer, end user or does your business offer service and maintenance for RACHP equipment? You need to respond to the DEFRA GB HFC phase down consultation because it is likely to have a major effect on your future business:

1. It means that the options for servicing of most existing equipment will be restricted in future – for example 46% of cold stores still operating on HFCs (according to the CCF Cold Chain Report 2026) – as retrofit solutions are not and will not be available.
2. It will affect your customers’ need to plan for investment in new equipment using different refrigerants in future, particularly for existing equipment that could be considered prematurely obsolete as a result.
3. For manufacturers it will affect your future product lines to adapt for different refrigerants.
4. As employers it means you will need to increase your investment in training to ensure your staff can work safely - even though it is not currently mandatory.

The outcomes will be used to shape future legislation for our sector. Take part in this consultation to make the views of the RACHP industry heard. 

The consultation is available at https://consult.defra.gov.uk/fluorinated-gases-and-ozone-depleting-substances-policy-team/f-gas-regulation-in-great-britain/  and will close on 17 December 2025.

The IOR draft response

Executive Summary – Question 7

The proposed HFC phasedown will rapidly increase the use of A2L, A3 and CO₂ refrigerants, but the UK will lack revised mandatory training, competence standards and updated qualifications needed to support this transition. Unlike the EU where Implementing Regulation (EU) 2024/2215 provides a structured, mandatory training matrix, the UK will have no updated equivalent framework for technicians, designers or installers. Without action, the phasedown risks inconsistent certification, a growing skills gap, unsafe or non-compliant installations, and reduced industry capacity and confidence. An updated mandatory national training matrix, aligned competence standards, and updated qualifications are essential to ensure safety, compliance and successful delivery of the phasedown.

The refrigeration industry plays a vital and often overlooked role in the resilience of the UK’s food supply chain. Safe and reliable operation of refrigeration systems is essential for food production, storage, and national distribution. The proposed rapid transition to A2L, A3 and CO₂ systems, without a revised mandated competence framework, creates significant risks not only for technicians and businesses but for the wider food system. Ensuring training and competence is therefore critical national infrastructure policy, not solely an industry matter.

Response:

The proposed HFC phasedown will have a significant impact on skills, competence, training infrastructure, compliance, and safety across the RACHP sector. At present, these impacts are not addressed in the consultation, and without regulatory intervention they pose a material risk to both industry capability and safe deployment of lower-GWP refrigerants.

1. Lack of a revised mandated training and competence framework in the UK covering low-GWP and alternative refrigerants

Unlike the EU F-gas revision, which introduces a structured, mandatory training matrix for technicians covering low-GWP refrigerants (including A2L, A3, CO₂ and ammonia), the UK currently has:

• No mandated training or certification requirements for flammable, high-pressure or toxic refrigerants (A2L, A3, CO₂ and ammonia).
• No national training matrix defining minimum competence standards.
• Significant inconsistency in training provision and assessment.
• Awarding bodies (e.g. C&G) delivering qualifications that are out of date, incomplete, and not aligned with the refrigerant transition.

The EU F-gas revision is supported by Implementing Regulation (EU) 2024/2215, which establishes a mandatory, structured training and certification framework (A1, A2, B, C, D, E) for technicians working with A2L, A3 and CO₂ systems. The UK has no equivalent training matrix or mandated competence requirements, despite accelerating the transition to these refrigerants. This risks inconsistent training, safety issues, and non-compliant system design and installation as alternative refrigerant use increases.

The lack of a mandated competence framework puts the UK at a disadvantage and is likely to create a skills deficit precisely when competence will matter most.

Prior to the proposed F Gas reform, several sectors took constructive steps to prepare for the transition to lower-GWP refrigerants, despite the absence of a mandated UK competence framework. Contractors supporting medium and large retail supermarket operations have invested heavily in technician training for handling CO₂ and A2L systems, while the small commercial sector has engaged with available technician training for handling A3 refrigerants. These systems are predominantly used in integral equipment such as plug-in appliances and display cabinets, which are factory built within controlled manufacturing environments, resulting in a standardised product being installed on site.

Training programmes have drawn on a combination of national awarding-body CPD qualifications and courses developed by specialist training providers. Although voluntary and varied in depth and technical content, these initiatives demonstrate a strong industry commitment to developing the skills needed for safe practice. They also highlight the need for a structured, nationally aligned competence framework to ensure consistent competence across the wider industry.

2. Inconsistent certification and the risk of unaligned schemes

Without a revised mandated standard or matrix, awarding bodies will develop their own interpretations of the skills required for HCs, A2Ls, A3s, CO₂ and ammonia. This will result in:

• Divergence between certification schemes.
• Reduced industry confidence in the competence of certificated technicians.
• Inconsistent safety outcomes across the sector.
• Potential for certification that does not meet insurer, equipment manufacturer or regulatory expectations.

Regulatory reform is essential to avoid a fragmented and ineffective skills framework.

3. Increased safety and compliance risks as A2L, A3 and CO₂ adoption increases

The revised phasedown will quite rightly push industry to adoption of flammable and high-pressure refrigerants. However, many designers, installers and technicians currently lack structured training in:

• PE(S)R compliance and system categorisation
• Relevant knowledge of EN and EN ISO standards
• Hazardous Area Classification and mitigation design
• Flammability and ignition risk management (A2L/A3)
• High-pressure system design and installation (CO₂)

This creates a clear risk of poorly designed or installed systems, potentially leading to unsafe installations, non-compliance with legal duties, and unsafe retro filling practices.

4. Impact on designers and installers, not just technicians

The consultation currently considers the phasedown primarily from the perspective of refrigerant supply. However, the greatest risk lies with:

• Design engineers specifying systems without knowledge of compliance requirements
• Contractors installing A2L/A3/CO₂ systems without understanding regulatory requirements
• SMEs with limited exposure to these refrigerants may inadvertently breach PE(S)R or standards requirements.

Training requirements for designers and installers must be considered separately from technician level competence.

5. Implications for innovation, investment and supply chain readiness

A lack of regulatory clarity around competence will:

• Reduce confidence for businesses investing in alternative refrigerant technologies
• Slow the safe adoption of low-GWP refrigerants
• Reduce competitiveness relative to the EU, where competence requirements are clearly defined
• Increase the risk of installation or maintenance errors, undermining performance and reducing confidence in low-GWP systems

Innovation depends on a competent workforce; the phasedown must therefore be accompanied by a clear skills strategy.

In addition, the safe and reliable adoption of new refrigerants depends on consistent communication, clearly defined qualification standards, and independent verification of competence. Without these supporting measures, businesses risk investing in technologies that cannot be safely or effectively installed or maintained, undermining confidence in lower-GWP systems and reducing overall system reliability and resilience across the sector.

6. The need for a UK training and competence roadmap

To support the proposed phasedown, the UK should adopt an approach aligning with EU practice by:

• Developing a mandatory UK training matrix covering A2L, A3 and CO₂ for technicians.
• Introduce mandatory training for designers and installers (not just hands-on technicians).
• Updating existing F-gas qualifications to incorporate alternative refrigerants and safety requirements.
• Aligning awarding bodies to a consistent, regulated competence standard.
• Providing a clear implementation timeline so that training infrastructure can scale appropriately.

Conclusion

The proposed HFC phasedown will accelerate the move to A2L, A3 and CO₂ refrigerants, but the UK still lacks the mandatory competence framework needed to support this shift. While the EU has introduced a clear, structured training matrix, the UK will have no equivalent updated requirements. Without similar measures, the transition risks creating gaps in safety, compliance, skills, innovation, and overall industry confidence. Establishing defined training and competence standards should therefore be developed alongside the phasedown.

Stakeholders are concerned that, without explicit inclusion in the revised legislation, training and competence requirements may be treated as peripheral to the core phasedown objectives. However, the safe, timely, and successful implementation of the phasedown fundamentally depends on a workforce that is properly trained and demonstrably competent. Neglecting mandatory training would jeopardise phasedown targets, increase safety and compliance risks, and undermine wider Net Zero ambitions. Establishing a structured, mandated competence framework is therefore essential to achieving DEFRA’s intended outcomes.

Question 10 

We remain concerned that awareness of this consultation is very low among micro and small contractors, many of whom may be disproportionately affected by the proposed phasedown. Compliance with the Pressure Equipment (Safety) Regulations 2016 (PE(S)R) is already inconsistent across the RACHP sector, and the accelerated shift towards alternatives to F-Gases increases the use of Group 1 refrigerants. This results in a greater number of systems falling into Category 2 or above under PE(S)R, triggering mandatory involvement of Authorised Bodies as well as Recognised Third Party approval of brazing procedures and operator qualifications. These requirements introduce additional administrative burden and cost, which smaller contractors often lack the experience or resources to manage effectively.

Until appropriate training, competence development, and project management capability are strengthened within this part of the sector, achieving full compliance will remain challenging. Moreover, Authorised Bodies are frequently reluctant to engage with RACHP businesses due to limited understanding of the sector’s regulatory context, leading to an adversarial dynamic in which they must effectively provide training rather than assess compliance. These barriers collectively highlight the need for clearer guidance, improved awareness, and targeted support for small and micro businesses to ensure that they can meet their regulatory obligations under the proposed phasedown.