Why retailers need to act now on changing rules for refrigerants in HVAC systems

This article is provided by BRC Associate Member, Mitsubishi Electric.

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The UK retail sector has an increasingly visible role in supporting the country’s transition to Net Zero. From energy-efficient lighting to sustainable fit-outs, retailers are rethinking how their buildings operate.

One area that deserves more attention is HVAC. The heating, ventilation and air conditioning systems found in most high street premises rely on chemical fluids called refrigerants to keep stores comfortable all year-round. But many of these refrigerants are now being phased down under tightening environmental regulations.

This phase out has been underway for some time. For example, refrigerants such as CFCs (chlorofluorocarbons) and hydrochlorofluorocarbons (HCFCs) were known to deplete the Earth’s ozone layer and were phased out by the mid-2010s.

Today, most refrigerants used in air conditioning fall into a category known as ‘F gases.’ These are man-made compounds, typically hydrofluorocarbons (HFCs). While they don’t damage the ozone layer, if released into the atmosphere they trap heat far more effectively than carbon dioxide, making them a significant contributor to global warming and climate change.

Because of this impact, the EU and UK are placing controls on how and where HFCs can be used through the F-Gas Regulations. The aim is to phase out their use altogether. In addition, the F-Gas Regulations also require regular servicing of refrigerant-using systems, including checks and record keeping of the refrigerants in use.

What’s changing?

The F-Gas Regulations are gradually limiting the amount of these gases allowed on the market. In 2025, the next phase of restrictions has already begun to bite - and they’re likely to affect anyone with older air conditioning systems.

As availability contracts, the most common higher-GWP refrigerants are becoming more expensive and harder to source. By 2027, several types of HVAC equipment, especially compact systems typically used in shops and salons, will no longer be available to buy if they contain certain refrigerants.

In simple terms: if you run a high street property with heating or cooling systems installed more than 10–15 years ago, now is the time to start reviewing what you have and find out whether it’s compliant with what’s coming.

Why this matters for retailers

According to government data, over 60% of non-domestic properties in England and Wales were built before 1939. That means many stores are working with ageing infrastructure, including heating and cooling systems that are well past their prime.

What’s more, many of the systems installed in the early 2000s use refrigerants that are being phased down under the F-Gas Regulations. These older systems may still operate for now, but they’re likely to become more difficult and expensive to service over the next few years. With refrigerant supply tightening and prices already showing signs of volatility, waiting until a system fails could be an expensive mistake.

The role of R32 and other lower-GWP options

There are modern refrigerant alternatives that not only meet the new rules but also offer improved efficiency. For example, systems that use R32 - a refrigerant with a significantly lower GWP than R410A - are widely available today and are often ideal for high street retrofit projects.

Some models are specifically designed to re-use the pipework and cabling from older systems, which means retailers can upgrade their HVAC without a full-scale refurbishment. This keeps installation costs down, reduces disruption to trading, and avoids the carbon cost of replacing perfectly good infrastructure.

Planning ahead also makes sense in the context of tightening energy efficiency standards. Government proposals suggest that by 2030, all non-domestic buildings may need to meet an EPC rating of B to remain lettable. HVAC upgrades can play a major role in improving a building’s performance - particularly when older systems account for a large share of total energy use.

A strategic opportunity for the sector

With pressures on costs, carbon, and compliance, HVAC might not always seem like a top priority in modern retail. But it’s a critical system that directly impacts customer comfort, operating costs, and environmental performance. For larger retailers managing multiple stores, it’s also a major opportunity to reduce emissions and demonstrate leadership in sustainability.

The F-Gas Regulation phase down process is the latest step in a decades-long shift away from environmentally harmful refrigerants, from the CFC bans of the 1990s to the HFC phase out in the 2010s. It signals that the environmental regulation of HVAC systems is only set to tighten.

By understanding what the F-Gas phase down means - and acting early - retailers can avoid reactive decisions, control long-term costs, and protect the value of their buildings. Most importantly, they can make sure their HVAC systems continue to serve their customers and staff efficiently and safely for years to come.

Further reading:

Mitsubishi Electric CPD Guide to F Gas Regulations and the Future of Refrigerants