Director GDC Change Enablement

Report on cost-effective F-gas emission reduction option for PFAS restriction. 22.06.2026 The European Partnership for Energy and the Environment (EPEE) commissioned Environmental Resources Management Ltd (ERM) to conduct a Socio-Economic Assessment (SEA) and Analysis of Alternatives (AoA) on the use of F-gas refrigerants in RACHP (refrigeration, air conditioning and heat pump) applications. The study evaluates the potential impacts of restricting per- and polyfluoroalkyl substances (PFAS) under REACH on the RACHP sector across four application groups: (1) comfort heating and cooling; (2) industrial processes for heating and cooling; (3) commercial and industrial refrigeration; and (4) transport refrigeration. The report evaluated and compared continued use of F-gases with Risk Mitigation Measures (RMM), a baseline with no restrictions and the two restriction options (full ban and full ban with derogations as set out in the updated restriction dossier published by ECHA in August 2025). The RMM option is introduced in the report as an alternative regulatory option. For the RMM, F-gases remain permitted subject to a projected maximum leak rate per equipment category and progressively higher end-of-life recovery rates. These are aligned with EPEE HFC Outlook model assumptions. A cautious 5% whole-of-life cost increase is modelled for the leak rate reduction. The ERM study's central conclusion is that the RMM is the most proportionate regulatory option: it achieves a 39% reduction in PFAS emissions at €20/kg - compared to €92/kg under full ban - while avoiding severe economic and market disruption, over 43,000 direct job losses in 2030 and significant supply chain risks. The SEAC's draft opinion has already noted that a full ban appears likely disproportionate. The data show that full ban with derogations performs worse than the RMM on cost-effectiveness while delivering far lower emission reductions. Key finding: continued use under conditions (RMM) is the most proportionate restriction option The key headline findings are: * Cost-effectiveness under RMM is 4.6x better than full ban (€92) and 10x better than full ban with derogations (€198) * GVA (gross value added) impact under RMM is 8x lower than both full ban and full ban with derogations * The RMM avoids more PFAS emissions than full ban with derogations, at one tenth the economic cost * For comfort heating and cooling: the RMM emission reduction exceeds full ban, because RMMs apply to the existing installed base, not only new products placed on market from 2030 * About 42,800 jobs preserved in 2030 under the RMM, compared to the full ban The reports key messages (extracts) are: Material economic impact. A full ban would deliver the largest emission reduction but at severe socio-economic cost. A full ban with derogations offers limited environmental benefit relative to its cost. The RMM option provides the best cost-effectiveness and system continuity and is the preferred option for stationary applications. Broader system dependencies and wider impacts. Downstream sectors face elevated operational and supply-chain risks if refrigerant availability is constrained without workable alternatives. Reduced refrigerant choice would weaken EU manufacturing competitiveness, slow heat-pump rollout, and risk backsliding on electrification and decarbonisation objectives, leading to a lock-in on fossil fuel-based technologies. No universal alternative refrigerant exists for RACHP applications. There is no single alternative refrigerant that can safely, efficiently and economically replace F-gases across all RACHP applications. Non-PFAS alternatives are constrained by flammability, toxicity, high pressure and performance limits. Safety - not refrigerant choice - is the dominant factor determining whether substitution is feasible for a given application. Transition timelines proposed are unrealistic. Substituting refrigerants requires long, application-specific development cycles - typically 5-12 years and longer for novel solutions - significantly exceeding the derogation periods proposed under the PFAS restriction for many applications. Proportionality, sequencing and coherence with F-gas policies are essential. A future PFAS regulation must reduce environmental risk without jeopardising EU climate, industrial and social goals. Building on the F-gas Regulation rather than overriding it is the only path that achieves both objectives. The RMM option demonstrates that this is possible. These are extracts of the report which has detailed sections on * Background and Regulatory Context * Study Methodology and Scenarios * Analysis of Alternatives (AoA) * Socio-Economic Assessment (SEA) The Executive Report of the ERM Socio-Economic Assessment on F-gas Uses in HVACR Applications Prepared in the framework of the SEAC Public Consultation on PFAS under REACH - May 2026, commissioned by EPEE is available here.

ERM and Ecolumix partner to help clients harness data to enhance EHS performance. 05 March 2026 ERM, the world's largest specialist sustainability consultancy, has developed a strategic partnership with Ecolumix, the leading provider of US environmental, health and safety (EHS) data intelligence and benchmarking. As a leader in EHS programs, regulatory compliance, and operational performance improvement, ERM helps organizations anticipate risk, strengthen core EHS programs, and sustain measurable performance improvements. Ecolumix's expertise includes analyzing EHS data across millions of facilities and hundreds of KPIs to enable rapid identification of outliers and performance trends. Businesses are facing rising regulatory expectations around environmental and safety performance, while publicly available EHS data and advancements in AI-enabled data analytics are driving increased stakeholder scrutiny and ushering in a new era of transparency. The ERM and Ecolumix partnership provides EHS leaders with a comprehensive view of their organization's performance across the US, at enterprise and facility levels and against industry peers, enabling strategic resource allocation that reduces exposure and delivers measurable, data-backed ROI. Through data-driven insights and EHS program expertise, ERM and Ecolumix are helping clients reduce risk, strengthen compliance, drive performance improvements and enhance their reputation in the market. The partners are already working on client engagements including: * Measuring facility-level EHS performance and risk across enterprises to identify issues that could trigger regulatory action or affect customer relationships. * Applying Ecolumix performance data to target EHS audits more effectively, helping clients focus resources on the highest-risk locations and programs. * Assessing supplier and vendor EHS risks that may impact operations, legal exposure, and brand reputation. Ramesh Narasimhan, Global Managing Partner, Safe & Sustainable Operations at ERM said: "We are seeing increased client demand for EHS performance benchmarking, while the rise of public data transparency has raised the stakes, amplifying both risk and opportunity. ERM's partnership with Ecolumix will help our clients to see how they compare against peers, understand performance variability across their own operations, and apply ERM's expertise to turn those insights into targeted, sustainable EHS performance improvements." Doug Parker, CEO at Ecolumix said: "We're excited to partner with ERM to help organizations unlock greater value from their EHS data and better understand how they stack up to their competitors. Ecolumix assesses data in context - across operations and against peers - to pinpoint where risk truly exists and where investment and corrective action will matter most. Paired with ERM's deep technical and regulatory expertise, these insights translate into practical, defensible actions that help companies prioritize resources, reduce regulatory and reputational risk, and drive real improvement at the facility level - where EHS performance truly matters." Sustainability is our business. As the world's largest specialist sustainability consultancy, ERM partners with clients to operationalize sustainability at pace and scale, deploying a unique combination of strategic transformation and technical delivery capabilities. This approach helps clients accelerate the integration of sustainability at every level of their business. With more than 50 years of experience, ERM's diverse team of 8,000+ experts across 40 countries and territories helps clients create innovative solutions to their sustainability challenges - unlocking commercial opportunities that meet the needs of today while preserving opportunity for future generations. About Ecolumix Ecolumix is an AI-driven data intelligence company built by industry experts that mines billions of verified data points to measure corporate environmental, health, and safety (EHS) performance across the United States. Ecolumix's insights enable companies to accurately assess facility-level environmental and compliance risks, evaluate supplier performance, identify emerging risk trends, and benchmark effectively against peers - turning complex regulatory data into clear, actionable intelligence. Media contact. Meryl Hanlon PR and Brand Communications, ERM +44 (0)7385 971303