F-gas rules and the HFC phase-down: what UK cold storage operators must know in 2026

For a cold storage operator, F-gas is no longer a compliance footnote handled by the refrigeration contractor. The GB F-gas Regulation and the HFC phase-down are reshaping the economics of refrigeration, making some refrigerants scarce and expensive while pushing the whole sector toward natural alternatives. This guide sets out, in plain terms, what the rules require in 2026, what is changing, and how to plan a plant strategy that stays compliant and controls cost.

What the F-gas rules require

The GB F-gas Regulation (the retained version of the EU regulation) governs the fluorinated gases used as refrigerants. For a cold store operator it imposes several practical obligations:

• Company certification for installation and service. Any company installing or servicing the refrigerant circuit must hold F-gas company certification. In Great Britain this is delivered through registration with a body such as REFCOM, and individual engineers must hold the relevant qualification. This is a legal requirement, so it is not something to compromise on when choosing an installer.
• Leak checking. Systems above set refrigerant charge thresholds must be leak-checked at defined intervals, with the frequency rising for larger charges. Leaks are both an environmental breach and a running-cost and reliability problem.
• Record-keeping. Operators must keep records of the refrigerant type and quantity, leak checks, and any refrigerant added or recovered. These records are what demonstrate compliance if you are inspected.
• Recovery. Refrigerant must be recovered by qualified personnel at end of life, not vented.

The full official guidance sits on the government’s F-gas pages, and a competent installer sets up your record-keeping and leak-check schedule at handover.

What the phase-down is doing

The heart of the change is the quota. The GB F-gas system caps the total quantity of HFCs that can be placed on the market, measured in CO2-equivalent tonnes, and that cap steps down over time toward an 80 per cent reduction by 2036 against the 2015 baseline. Because the cap is measured in CO2-equivalent, the highest-GWP gases are squeezed hardest: a kilogram of a very high-GWP refrigerant consumes far more of the quota than a kilogram of a low-GWP one.

The practical effects an operator sees are:

• R410A is excluded from most new equipment. New plant is no longer designed around it.
• R404A, one of the highest-GWP gases in common cold-store use, is being squeezed hardest. Its price has risen and its availability is tightening, which shows up as more expensive service visits and recharges.
• Supply risk after a leak. If a system on a high-GWP HFC loses a significant charge, sourcing enough gas to recharge it becomes harder and dearer.

None of this bans your existing plant overnight. What it does is make continuing to rely on high-GWP HFC plant progressively more expensive and more risky, which changes the replacement calculation.

What this costs an operator on legacy HFC plant

If you run R404A or R410A plant today, the phase-down affects you in three ways:

1. Rising service and recharge costs as the gas becomes scarcer. This is already visible and will continue.
2. The likelihood of an early replacement before the plant’s mechanical end of life, driven by refrigerant cost and availability rather than by the plant wearing out.
3. The efficiency gap. Legacy HFC plant is typically well below the efficiency of modern natural-refrigerant systems, and on a bill that is 70 to 80 per cent refrigeration, that gap is real money. We quantify this in our guide to cold storage running costs.

The worst outcome is drift: an unplanned failure of scarce R404A plant, forcing an emergency recharge or a rushed replacement at a bad time. Planning ahead avoids that.

The compliant, efficient answer: natural refrigerants

New cold storage should be designed on refrigerants that sit outside the phase-down entirely, so the plant can run to its full mechanical life without a refrigerant-driven forced replacement:

• Transcritical CO2 (R744) for most chilled and frozen cold stores. GWP of 1, efficient in the UK climate, and proven at scale. It has been shown to cut energy against R404A by around 19 per cent. This is the default for most new stores, and our comparison of CO2 versus HFC refrigeration covers the detail.
• R290 (propane) for smaller packaged plant, such as walk-in cold rooms and self-contained units. Very low GWP and efficient, with a charge-size limit driven by flammability.
• Ammonia (R717) for the largest industrial stores, where it is the efficiency leader and the additional safety engineering is justified.

Choosing one of these at specification or replacement removes the phase-down risk from the equation for the life of the plant.

Is there any grant to help?

There is no dedicated grant for replacing HFC plant. It is worth being accurate about this: the Industrial Energy Transformation Fund (IETF), which historically funded refrigeration and cold-chain efficiency projects, is closed to new applications following the 2025 Spending Review, and no further competition windows are planned; previously awarded projects remain funded. Do not budget on the assumption that IETF money is available for a new cold-store project in 2026, and check gov.uk before relying on any scheme.

What does help is the tax treatment. Refrigeration plant and cold room panels qualify as plant and machinery, so a business can claim 100 per cent first-year relief under the Annual Investment Allowance on up to £1m of qualifying capex, and companies can use Full Expensing on new main-rate plant above that. That relief softens the cost of moving off HFC plant, and it is set out on our grants and funding page.

A practical plan for 2026

• Know what you are running. Identify the refrigerant in each system and its charge, and make sure your F-gas records and leak-check schedule are in order.
• Watch the highest-GWP plant. R404A systems are the priority for replacement planning, because they are squeezed hardest and cost the most to service.
• Plan replacement before it is forced. Budget to move to CO2, R290 or ammonia on a timeline you control, aligned with mechanical end of life where possible, and claim the new plant under capital allowances.
• Specify natural refrigerants on anything new. Do not install a legacy HFC in a new store; it is a dead end.
• Use a certified installer. Only an F-gas certified company can legally install and service the circuit, and a good one sets up your compliance records at handover.

A final point worth making: none of this requires panic, but it does reward planning. Operators who audit their refrigerants now, prioritise their highest-GWP plant, and set a replacement timeline they control will move off HFCs at a manageable pace and cost. Those who wait until a scarce-gas failure forces their hand will pay more, and at a worse time.

The bottom line

The F-gas phase-down is not a distant regulatory change, it is already raising the cost of legacy HFC refrigeration and pushing the sector to natural refrigerants. For UK cold store operators in 2026, the sensible strategy is to keep your F-gas records and leak checks in order, plan the move off high-GWP HFC plant on your own timeline rather than waiting for a failure, and specify CO2, R290 or ammonia on anything new. To review your plant against the phase-down and plan a compliant, efficient upgrade, request a quote.