Seven German refrigeration, air conditioning and heat pump industry associations have jointly urged members of the German Bundestag and federal ministries to consider the technical and economic consequences of a broad PFAS ban. In a letter coordinated by VDKF, the organizations called for regulations that distinguish between PFAS applications based on their actual emissions and environmental risks.
The initiative comes amid the European Chemicals Agency’s (ECHA) ongoing PFAS restriction process. The proposal under discussion includes extensive restrictions on PFAS substances, but no final decision has been made. The assessment procedures must be completed before the European Commission decides on a regulatory proposal.
The associations support reducing harmful PFAS emissions but emphasize that fluorinated refrigerants (F-gases) are already regulated under the EU F-gas Regulation. Existing requirements include personnel certification, leak inspections, refrigerant recovery, bans on placing certain equipment on the market, and the gradual phase-down or phase-out of fluorinated refrigerants. According to the associations, the industry has made substantial investments in compliance, while F-gas emissions have continued to decline.
The organizations are requesting exemptions where technically suitable alternatives are unavailable, safety requirements prevent the use of alternative refrigerants, or disproportionate economic consequences could arise. They also advocate prioritizing leak-tight systems, qualified personnel, regular inspections and enforcement of existing requirements over blanket restrictions.
The associations warn that restrictions without adequate exemptions or transition periods could affect heat pumps, data centers, industrial refrigeration, food cooling and other commercial and industrial applications. The letter was signed by BTGA, BVKMW, FGK, the German air handling equipment manufacturers’ association, TGA-Repräsentanz Berlin, VDKF and VDMA Allgemeine Lufttechnik.
“Preventing PFAS emissions is our common goal,” the associations stated in their joint conclusion. “At the same time, applications of refrigeration, air conditioning and heat pump technology that are essential to society and the economy must not be jeopardized. What is therefore needed is differentiated and practical regulation rather than blanket bans.”
