RACA Journal October 2025 RACA_October2025 | Page 3

RACA Journal I October 2025 1
RACA Journal: ISSN 1812-772X
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RACA Journal Publication www. refrigerationandaircon. co. za eamonn @ interactmedia. co. za

A DATA BLACK HOLE: SA’ S STRUGGLE TO MEET 2026 KIGALI AMENDMENT

As the global climate agenda accelerates, South Africa is racing against time to meet the fast-approaching 2026 deadline for compliance with the Kigali Amendment to the Montreal Protocol.

The Kigali Amendment mandates a major reduction in hydrofluorocarbons( HFCs) – potent greenhouse gases used in refrigeration and air conditioning.

Yet with just a few months to go, mounting concerns are surfacing across the country’ s HVAC & R sector. The main issue: South Africa is flying blind.
One of the most pressing challenges is the lack of reliable national data on refrigerant usage. Industry stakeholders say there ' s still no comprehensive database on refrigerant types, volumes, sectors or users.
This data vacuum severely hampers the development of a workable national quota system— a requirement of the Kigali Amendment. Quotas are based not just on volume, but on CO₂equivalent tonnage. High-GWP refrigerants use up more of the quota; low-GWP ones allow larger volumes. Without clear baseline data, it becomes nearly impossible to design fair, accurate and enforceable quotas for importers, users and service providers.
Another major hurdle is the slow pace of regulatory development. As with earlier efforts under the HCFC Phase-Out Management Plan( HPMP), South Africa will need to formally gazette a suite of regulations to enforce Kigali compliance. These will likely include permits, quotas, tracking systems and enforcement provisions. Unlike HCFCs, which were phased out due to their ozonedepleting potential, HFCs are targeted primarily because of their climate-warming impact. This adds a new layer of complexity, as authorities must now incorporate climate policy objectives into technical regulations and trade controls.
Unfortunately, stakeholders report that these regulations remain in draft or consultation stages, with little communication about when or how implementation will unfold. Many in the industry feel that the country is reactive rather than proactive, with meaningful engagement and preparedness starting far too late in the timeline. In addition to regulatory gaps, there are critical shortages in technical infrastructure and human capacity. It will require trained inspectors, updated protocols and industry-wide technical training.
To date, many of these systems remain underdeveloped or entirely absent. Without clear government guidance, industry players are being left to navigate a fast-changing global compliance landscape largely on their own.
Adding to the challenge is a growing market flood of unvetted refrigerant alternatives, equipment modifications and conversion kits. As the 2026 deadline approaches, suppliers and manufacturers are rushing to promote new‘ climate-friendly’ products— often with conflicting claims and incomplete performance data.
This environment risks overwhelming end users, contractors and procurement officers— many of whom may not have the technical expertise to distinguish between credible low-GWP alternatives
www. refrigerationandaircon. co. za and opportunistic marketing claims. As companies scramble to prepare for the Kigali transition, the influx of new products and‘ solutions’ on the market is creating confusion. Without proper guidance, decision-makers may invest in refrigerants or technologies that are unsafe, incompatible, or economically unsustainable.
What the industry urgently needs is clear, science-based information to evaluate which alternative refrigerants are both safe and technically viable. Stakeholders also require insight into the potential costs and safety considerations of retrofitting existing systems and must understand how to assess whether new refrigerants are compatible with their current infrastructure.
Looking back, South Africa has demonstrated the ability to manage complex refrigerant transitions. The country successfully phased out chlorofluorocarbons( CFCs), followed by hydrochlorofluorocarbons( HCFCs), through co-ordinated national efforts. However, the HFC phasedown introduces a far greater level of complexity. Unlike earlier transitions, this one spans a wider and more fragmented range of sectors, from retail to agriculture to data centres. The refrigerant market itself has become more diverse, with a broader spectrum of chemical options and performance characteristics. Additionally, because the Kigali Amendment is rooted in climate policy, the entire process is subject to far greater international scrutiny and carries more significant long-term environmental implications.
At its core, the Kigali Amendment is not merely a technical exercise or an environmental checkbox. It forms part of a global climate action plan, with major implications for national policy, trade and sustainable development. For South Africa, successful implementation could unlock access to climate finance, support green technology transfer and improve the resilience of key sectors.
But failure to act decisively may leave the country isolated— unable to meet international expectations, vulnerable to trade restrictions, and ill-prepared for a future where carbon intensity and refrigerant emissions are increasingly regulated. With 2026 fast approaching, South Africa must urgently collect refrigerant data, finalise regulations and begin industrywide training to prevent supply shocks and compliance failures. South Africa may still have time to rise to the occasion— but only if government, industry and technical bodies act quickly, collaboratively and with transparency. RACA

Eamonn

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