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Accelerating Clean Cooling & Heating

Delivering Today on EU F-gas, REPowerEU and PFAS Restriction with Natural Refrigerant Heat Pumps

This report highlights the transition towards natural refrigerants that the European heat pumps industry is undertaking to support the objective of climate neutrality, simultaneously reducing dependency from highly climate altering and persistent fluorinated refrigerants.

Accordion Content

Heat pumps are a key technology to support the climate alignment of global heating and cooling systems. Heat pumps can deliver both cooling and heating effects, and multiple technologies are available according to different installations’ settings and buildings.

To provide heating and cooling, heat pumps rely on refrigerants – substances that deliver heat and cold where needed, generally either directly or by changing the temperature of a secondary fluid. In Europe, primarily two kinds of air-source heat pumps are being deployed. The first, air-to-water systems, have mostly been installed containing the refrigerant HFC-410a, a fluorinated greenhouse gas with a global warming potential thousands of times higher than that of carbon dioxide. The second, air-to-air systems, are rapidly being switched to HFC-32, a refrigerant that traps hundreds of times more heat than carbon dioxide.

The recently released summary of the 6th Assessment Report of the International Panel on Climate Change (IPCC) clearly states that “human activities, principally through emissions of greenhouse gases, have unequivocally caused global warming.” Fluorinated greenhouse gases are exclusively man-made substances that are emitted to the atmosphere during production, while leaking during operation of systems or at the end of life of the equipment in which they are contained. The UN Secretary-General António Guterres stated at the release of the summary: “Our world needs climate action on all fronts — everything, everywhere, all at once.” By allowing the continuous use of fluorinated greenhouse gases with global warming potential, we would fail to deliver European climate leadership, especially considering the solid industrial ecosystems of European companies that can deliver without relying on these problematic fluorinated substances.

Heat pumps are based on the vapour compression technology applied to the refrigerant. This technology does not require fluorinated greenhouse gases, from a technical perspective. The proof of this is the availability of natural refrigerants such as hydrocarbons, carbon dioxide and ammonia across the spectrum of capacities and technologies included in heat pumps, as well as in most other applications used to mechanically control temperatures.

Policymakers designing the speedy rollout of heat pumps under REPowerEU, consisting of millions of units to be installed, must take into account the refrigerant used to avoid additional burdens on the climate and the environment caused by fluorinated greenhouse gases. In fact, not only some widely used fluorinated greenhouse gases have high global warming potential, but are also labelled per- and polyfluoroalkyl substances, known as “forever chemicals” due to their persistent chemical structure. Fluorinated refrigerants can therefore be a concern from the perspectives of climate, environment and health. The report also finds that little production of these substances is taking place in Europe, whereas imports, both legal and illegal, are substantial.

Avoiding locking-in fluorinated greenhouse gases and PFAS in the deployment of heat pumps under REPowerEU is therefore an imperative. Not only are these fluorinated substances commonly more expensive than natural refrigerants, but they also do not ensure better energy performance. Heat pumps with natural refrigerants are available on the market today from multiple manufacturers across Europe without substantive cost increases over their fluorinated counterparts. This is especially the case for air-to-water heat pumps, which count for a significant part of the units sold across European countries each year.

Industry is evidently setting its focus on these natural working fluids, avoiding burdensome changes in refrigerants and system components under the ever-lowering of the global warming potential of these substances. Most companies interviewed find natural refrigerant heat pumps to be a solid investment from the perspective of the revision of the EU F-gas Regulation. Driven by clear regulatory measures on fluorinated substances, interviewed industry stakeholders have reported their committal to scale up production to meet the targets set by policy. Small and medium companies are leapfrogging to natural refrigerants in heat pumps to avoid continuous refrigerant changes, and market leaders are converting their sales portfolio to fully natural by 2027. Companies specialised in other heating applications are also crowding into the heat pump space, seeing the market opportunity in providing systems with natural refrigerants.

Most companies want to avoid the uncertainty related to fluorinated refrigerants that are PFAS by directly investing in natural refrigerants, providing customers with systems that have no ozone depletion potential, negligible effect on global warming and no PFAS or PFAS-forming substances.

Finally, most of the companies interviewed report the feasibility of converting production lines from fluorinated refrigerants to natural refrigerants in roughly three years, with few concerned about the aspect of flammability, arguing a training upgrade to the EU F-gas certification could be achieved in two days.

The objective of this research is to provide the most accurate information possible related to the ongoing transition of the European heat pump industry from using fluorinated refrigerants to natural refrigerants. Consideration is given to both the ambition shown by the European Commission in its proposal for the revision of the EU F-gas Regulation and the objectives of the grand-strategy of REPowerEU to decarbonise European heating systems.

The report seeks to identify drivers and barriers impacting stakeholders in the EU’s residential natural refrigerant heat pump sector, framed within the context of decarbonising Europe’s heating sector and transitioning towards electrification. No consideration is given to hydrogen as a heating mean in this report. Regulations in terms of bans on fluorinated greenhouse gases are considered a main driver to this aim, and focus is therefore placed specifically on the EU F-gas Regulation. The unfolding per- and polyfluoroalkyl substances (PFAS) Restriction Intention is also treated in this report as a driver to speed up original equipment manufacturers’ transition towards manufacturing heat pumps working with natural refrigerants. The scope of this research covers heat pumps for space heating and domestic- and sanitary- water heating applications. Combined units are included tangentially in the analysis. It excludes, however, air-to- air and hybrid systems and reversible models. Nevertheless, the most salient progress industry has announced on air-to- air technology are reported for sake of completeness.

The study focuses on heat pumps with a rated capacity of less than 12 kW as this segment is assumed to be relevant for the residential sector. It is also the cut-off point for heat pumps covered under Commission Regulation (EU) No 206/2012 of 6 March 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regards to Ecodesign requirements for air conditioners and comfort fans. It is the report’s goal to demonstrate how the climate objectives set by the European Commission can be achieved without locking in marketed appliances with fluorinated refrigerants. It does this by primarily reporting announcements by market players opting to provide heat pump charged with natural refrigerants to the market. ATMOsphere undertook an EU-targeted research effort to investigate both the current and future demand for key natural refrigeration technologies in the EU region (27 countries). To fully understand and analyse these markets, the ATMOsphere team used a combination of qualitative, quantitative, primary and secondary research methods.

Then, via the expansive global ATMOsphere network, global industry experts tested and expanded upon the concepts.

The following methods were used:


While preparing this in-depth presentation of the current and future market, ATMOsphere leveraged a combination of external reports and academic, industry and media publications, together with its own articles and reports, to build an understanding of the market and where it is heading and to inform the questions for the subsequent manufacturer interviews. ATMOsphere is powered by a database of natural refrigerant and clean cooling and heating information, diligently collected over the years by its analysts and journalists.


The comprehensive desk research was followed and enriched by extensive outreach to relevant original equipment manufacturers and industry stakeholders for primary research. A series of one-on-one interviews was planned to gather information on additional qualitative and quantitative results. Relying on ATMOsphere’s database and EHPA’s member section, an initial email outreach and briefing on the objective of this project was sent to manufacturers already producing heat pumps with natural refrigerants or announcing their future placing on the market. In cases where no answers were received from relevant representatives of stakeholders of the EU heat pump industry, an email was sent to the official company’s email address as found on their main website. A second-step of selection identified a target of 29 heat pump OEMs that were invited to take part in a conversation with ATMOsphere experts via a structured interview or alternatively submitting inputs through a fill-in survey. Additional testimonials and information from stakeholders were gathered at conferences and trade fairs, as ISH 2023 in Frankfurt.

ATMOsphere (formally shecco) is a global and independent market accelerator on a mission to clean up cooling and heating. Its Intelligence Department collaborates with industry stakeholders, policymakers, NGOs and academia to accelerate knowledge on clean cooling and heating in the global RACHP sector.

The Project Team would like to thank industry representatives for their inputs throughout the work conducted on this report. The Project Team is also thankful for civil society’s inputs feeding into this report

Read the full report here