For the agricultural sector, this means significant changes—particularly for cooling systems used in milk production. Since F-gases are used in both direct and indirect cooling systems in milk cooling tanks, the regulation is an important factor to consider in future investment decisions.
From 1 January 2025, several new restrictions will be introduced. Milk cooling tanks using refrigerants with a GWP above 150 may no longer be commissioned in new installations if the refrigeration unit is pre-charged and delivered connected to the tank in a direct expansion system. The relocation of used milk cooling tanks is also considered a new installation and is therefore subject to the same rules.
From 1 January 2027, refrigeration units with a GWP above 150 and a capacity of up to 12 kW will also be prohibited in indirect cooling systems.
The same year will see the first major reduction of HFC quotas on the European market. The EU consists of 27 Member States, and the size of the market determines the allocated quota. The total quota issued in 2027 will amount to approximately 20 million tonnes of CO₂ equivalents. While this may sound substantial, it roughly corresponds to the estimated annual leakage from existing systems in just one year. Under the F-gas regulation, significant price increases for HFC gases are also expected as a policy measure to accelerate the phase-out.
From 1 January 2030, the rules will also apply to separate refrigeration units installed and connected to the milk cooling tank on site in direct expansion systems. At the same time, the repair and refilling of refrigeration systems using refrigerants with a GWP above 150 will be prohibited. This means that if a component fails and the system needs to be emptied or refilled, this will no longer be permitted.
From 1 January 2032, a general ban will apply to all refrigeration systems using refrigerants with a GWP above 150, regardless of whether the system is still operational or technically functional.
In practice, this means that continuing to operate older milk cooling tanks using HFC refrigerants may become both technically and economically risky—especially after 2027, when quota reductions take full effect.
Our recommendation is therefore to begin planning now for future-proof solutions using low-GWP refrigerants in order to avoid operational disruptions and unexpected costs in the future.
If you have any questions about future-proof solutions or the F-gas regulation, please feel free to contact us for advice and support.
