Refrigerant Policies and Management in Australia Stepping Up the Phase-Down


In January 2022 Australia passed another milestone in the phasing down of HFC refrigerants in line with the Kigali Amendment to the Montreal Protocol. As Australia’s peak body for professionals working in the HVAC&R sector, AIRAH felt the time was right to review the country’s progress and highlight the challenges we are facing.

AIRAH’s primary aim is to develop the competence and skills of industry engineering professionals and technicians so that they can better meet the public’s safety, energy usage, comfort, and emission concerns. AIRAH encourages world’s best practice within the industry through continuing professional development, education programs, and a wide range of technical tools and resources. AIRAH is the only body in Australia solely focussed on representing HVAC&R professionals.

Although the HVAC&R sector might not attract mainstream media coverage for its environmental achievements, our contribution to protecting the Earth’s atmosphere is significant. The HFC phase-down is a case in point. It builds on the collective success of taking ozone-destroying substances out of the supply chain and will reduce greenhouse gas emissions. If successful across the world, it could avoid up to a 0.5°C increase in global temperatures by the end of the century.

HFC (hydrofluorocarbon) refrigerants are being phased down globally due to their high global warming potential (GWP), with the Kigali Amendment to the Montreal Protocol specifying the targets and dates for achieving significant reductions. Australia co-chaired the international negotiations, which set a target of 85 per cent reduction in HFC use by 2036 for developed nations.

Australia and the HFC phase-down

Australia started its phase-down on January 1, 2018. We have implemented it as a staged trajectory of reducing import quotas, which gave us a more rapid and consistent initial trajectory than some other signatory nations.

Australia’s HFC import limit is set in law and is controlled through a licensing and quota system. Since the HFC phase-down started in 2018, annual imports have been within the limits set in the legislation.

Progress is monitored through six-monthly reports by HFC importers. Aggregated import data is made publicly available at the federal government’s website.

Australia reports its annual imports to the Ozone Secretariat in the United Nations Environment Program where aggregated data is publicly available. HFC import data feeds into the National Greenhouse Gas Inventory and greenhouse gas emissions projections. The Cold Hard Facts series of reports also provides detailed analysis of the bank and emissions of refrigerants.

The phase-down is an important part of Australia’s emissions reduction commitment under the Paris Agreement, as well as the Montreal Protocol on Substances that Deplete the Ozone Layer.

Progress so far

According to Patrick McInerney, Director Ozone and Climate Protection Section at the Department of Climate Change, Energy, the Environment and Water, the program has faced no significant challenges to date. He notes that Australian industry is used to the gradual phase-out/down of these types of chemicals, and has demonstrated it can manage the reducing availability while transitioning to alternatives.

Indeed, Australia had already begun to move away from high-GWP HFCs well before the phase-down started.

For instance, domestic refrigerators in Australia have virtually stopped using HFCs, the vast majority of smaller split system air conditioners have moved away from R410a, and many supermarkets are transitioning their refrigeration systems away from high-GWP refrigerants.

Another important feature of Australia’s HFC phase-down is the reduction path. Refrigerants Australia Executive Director Dr Greg Picker points out that most other signatory nations to the Kigali Amendment have chosen three substantial tranches of reductions in high-GWP refrigerant use. Australia started with 80 per cent below the baseline as the initial target, and then every 10 years “tightens the tap” with an 8–10 per cent reduction.

Picker says that in other countries, the industry gets used to the status quo between phase-downs, then experiences significant disruption when the next step down is implemented.

One of the key resources in Australia for monitoring the HVAC&R sector, especially the refrigerant bank, is the Cold Hard Facts series of reports, produced by The Expert Group for the Australian government.

Peter Brodribb, M.AIRAH, is the Managing Director of the Expert Group, and says that while Australia is on track in its HFC phase-down, there could be a clash point when the Australian trajectory intersects with the Montreal Protocol trajectory in around 2029.

By then Australia will be on an equal path with Montreal, which has a phase-down limit of 3,244 megatonnes of CO2 for Australia within the agreement, while our national settings should have us at 3,200MtCO2.

Challenges and barriers

While in many respects Australia’s phase-down is going well, some challenges remain in specific practices and applications.

Consumption of R404a remains stubbornly high, with more than 850 tonnes of consumption per annum.

The Cold Hard Facts report shows the amount consumed within the industry, whereas the Montreal Protocol defines consumption based on import quantities. So, Australia may look on track by the protocol measure, but domestic supply and demand is holding the country back when it comes to R404A.

This refrigerant is used primarily in the cold chain for food and commercial refrigeration applications, including coldrooms, food retail display cases and some supermarkets.

According to the Managing Director of the Expert Group, Peter Brodribb, M.AIRAH, the main driver for the continued use of R404A is price, as there is a significant part of the food retail and cold chain sector that is very cost-conscious. But the cost to the global atmosphere of R404A is significant. It has a GWP of 3,922, which is the highest of any refrigerant commonly used in the economy.

It can be substituted with HFC/HFO blends R449A or R448A, which have GWPs of less than 1,400 –almost two thirds less – and most plant and technology currently in use can be retrofitted with these lower-GWP, class 1A refrigerants that are non-toxic, non-flammable and use the same oils. The difference is cost.

Currently less than 5 per cent of this type of equipment is using the new lower-GWP blends, but most of it technically could be.

As well as the HFC/HFO alternatives mentioned above, R404a can be swapped out for CO2, as large supermarket chains Woolworths and Coles have done.

It is expensive initially, and it can be more challenging to get equipment serviced due to fewer technicians having the specialised training. Because CO2 is a high-pressure solution, there may also be more breakdowns.

Another hurdle is that in high summer temperatures, CO2 equipment may not deliver an optimal level of energy efficiency, so some asset owners are using HFC/HFOs instead of the R404a in scenarios where high temperatures can be expected and energy efficiency is a top priority. It is also worth noting that CO2 technology has advanced over the past years, leading to better solutions in high ambients.

Other applications are further along in Australia. Small split systems are now making the transition to R32, and this constitutes the majority of equipment being imported. A further policy measure of imposing a ban on splits with higher GWPs could be helpful to prevent more R410A going into the refrigerant bank by stopping the tail end of products with that high-GWP refrigerant.

Auto air conditioning is another a sector that is lagging compared to other industrialised economies. Based on 2020 analysis, about 85 per cent of new cars in Australia still use the high-GWP refrigerant R134a. Major auto manufacturers are now making moves to switch, so a rapid switch could occur in about 2025.

Managing demand

Future consumption is driven by the bank of product, so it is important to limit what goes into the bank.

That could mean prohibitions on new cold chain equipment using R404A, the R134A used in auto air conditioning, and R410A in smaller stationary air conditioning.

There are parts of the industry where the phase-down is going extremely well. For example, the growing use of natural refrigerants as opposed to synthetics, including the transition to hydrocarbons in small-scale units using less than 494g of refrigerant.

As noted above, the transition to hydrocarbons in domestic refrigeration is now at around 99 per cent. Commercial refrigeration penetration such as drink fridges is at around 50 per cent low-GWP equipment. And in food retail applications, including independent supermarkets, the transfer to CO2 trans-critical technology is going well.

Several factors play into the demand for high-GWP refrigerants. One is the pressure rating and flammability rating for some equipment is not suitable for retrofitting alternatives.

Stakeholders have also underlined the need to ensure the amount of high-GWP product still allowed in the market should be sufficient to continue to service the existing equipment that requires it for the rest of that plant’s working life.

Another barrier for equipment that can have natural refrigerants retrofitted has been price, as naturals were initially significantly more expensive per kilo. However, price is going down as supply and demand goes up.

Other experts have suggested that the blanket approach of the current phase-down may need to become more targeted. Some self-contained applications and small to medium refrigeration applications are seen to be lagging on innovation and initiative.

According to Kirby National Sales and Marketing Manager Brett Hedge, M.AIRAH, there needs to be more contractor awareness around the different sectors and what those sectors could do. He nots that although larger and smaller applications are both tracking well with the phase-down, challenges remain in the middle.

Small equipment is benefiting from changes at the manufacturer end in Europe and Asia, where standards have driven a switch to low-GWP products. The larger applications, such as the big supermarket chains, have shown leadership in transitioning to natural refrigerants.

For the middle of the market, one of the push factors that is missing is the life-cycle cost appraisal and cost-benefit analysis over 15 years or more. Many businesses in this part of the market do not look or plan that far ahead, so they are not calculating the life-cycle picture or requesting that information.

Another background issue is a lack of training options available in recent times for trades and technicians. This is particularly in relation to the safety practices required for the use of the natural refrigerants. Cost and safety are over-riding factors around natural refrigerant usage, but a full transition to natural refrigerants is still seen as possible.

Impacts of COVID-19

The past two years have caused disruption due to the quota-based approach of Australia’s HFC phase-down.

There were two main problems. First, the quota system has a “use it or lose it” approach, so whatever quantity of high-GWP refrigerants are imported in any calendar year then becomes the maximum amount allowed the following year. Because of global supply-chain disruptions and demand-side issues in Australia during the pandemic, the amount that physically arrived in the country was not a true reflection of demand or current need.

For many businesses, cashflow issues associated with lockdown restrictions and other impacts also meant they could not afford to import additional refrigerant and stockpile until the economy revived again.

The government has put in place a provision that if a business imported between 76–100 per cent of its allocated quota, it would be counted as the full 100 per cent. It also allowed capacity for a small number of overages not to be considered in the 2020 calendar year.

Going forward, between 95–100 per cent will also be counted as full quota.

Another issue relates to the disruption to global shipping – which has seen cargo delayed due to congestion in the North Asia trade nodes – equipment shortages, blank sailings (cancelled transport trips), and disruptions to supply-chain transport links. Goods ordered in expectation they would arrive in 2021 often did not arrive until 2022.

A new regulation allows for those who in “good faith” ordered in 2021 and had every reason to believe it would arrive before December 31, can count them in the 2021 quota, even if they arrive in January 2022. In these cases, there will be no penalty for being over quota.

Future measures

Industry stakeholders have highlighted the need to incentivise new equipment that has low-GWP refrigerants. In selected areas, the government could put in place GWP limits. This includes small split systems still using R410A instead of the low-GWP R32, and car air conditioning.

There is also a need to raise awareness among technicians and trades about making refrigerant choices based on GWP, so they can effectively advise their clients. Many are not thinking about the future availability of specific products when they are giving product advice based on what is available today.

Clients are seen to go with the path of least resistance with refrigerants, and high-GWP product is still available in abundance.

Raising consumer awareness would also be helpful so a client like a café owner starts asking questions about what a refrigerant will cost in 10 or 12 years’ time. As the supply of high-GWP refrigerants continues to shrink, the cost of them is likely to increase.

Good policy leadership could also help. Another issue highlighted by stakeholders is the lack of government funding for innovation and downstream awareness. Policy certainty and support for innovation could encourage some of the large, landmark assets to shift to low-GWP refrigerants. Currently, many of Australia’s iconic buildings have not done so, making it appear all but impossible to smaller businesses.

Making refrigerants part of sustainable and low-carbon building design standards would also act as a lever. Australia has strong ratings systems such as NABERS and Green Star that can recognise low-GWP refrigerants within their rating credits and standards.

Training and education is seen as a major underlying issue. Improving the quality and quantity of the available HVAC&R workforce means getting the message across that the sector offers well-paying jobs and is a highly skilled profession.

Stakeholders are unanimous that more investment in training and education is required, though there is less agreement about who should fund it. Some have suggested that there is scope for a creative government to launch a huge “trades for the future” package across renewables, trades and building, and also to find ways to better support people already working in the sector.

Further reading

To read the government’s latest report on the HFC phase-down, go to

As part of its work to support industry, AIRAH organises conferences and forums focusing on specific areas of the HVAC&R sector. The Refrigeration Conference includes many presentations on refrigerants and the HFC phase-down. The keynote address from this year’s event is available online.


The Australian Institute of Refrigeration, Air conditioning and Heating (AIRAH) is an independent, specialist, not-for-profit technical organisation providing leadership in the air conditioning, refrigeration and heating sector through collaboration, communication, engagement and professional development. 
Formed in 1920, AIRAH has earned renown from government and other industry bodies for its expertise across a broad expanse of issues in the realm of engineering services for the built environment.  AIRAH represents the entire breadth of the Heating, Ventilation, Air conditioning and Refrigeration (HVAC&R) industry, from “the man in the van” to research-focused academics; from plumbers to designers of the nation’s most high-performing buildings; from sole operators to the chief executives of large corporations. 
As Australia’s leading refrigeration and air conditioning organisation AIRAH represents a membership – and an industry – that is crucial to our community’s comfort, health and safety.

This article, written by Willow Aliento, first appeared in the February/March 2022 issue of HVAC&R News. To read this article online, and access other issues, go to


Willow Aliento

For over a decade, Willow Aliento has been researching and reporting on the built environment with a focus on sustainability. The intersection of science, policy and practices throughout the supply chain, and the asset life-cycle from design/delivery to ongoing operational improvements are topics she finds particularly compelling. After many years freelancing for industry publications including AIRAH’s HVAC&R News, The Fifth Estate and Australian National Construction Review, Willow recently joined global multidisciplinary engineering and sustainability consultants, Cundall, as in-house Corporate Journalist.