RACA Journal September 2025 RACA_September2025 | Page 14

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Business
A slide from the presentation.
Molefi outlined the proposed regulatory pillars to manage this transition:
PHASING DOWN CONSUMPTION AND QUOTA SYSTEM:
• Baseline establishment: The DFFE aims to establish a baseline for HFC production and consumption
• Import quota methodology: Based on the consumption baseline, a methodology for an HFC import quota system will be determined, along with mechanisms to control illegal imports and establish reporting requirements.
• Quotas, allocated annually and progressively decreasing, will be strictly managed, with noncompliance leading to forfeiture.
• Facilitating sector-based transition: Analysing current HFC use( with R134a, R404A and R507 being the highest consumed).
• Transition to low-GWP & PFAS-free alternatives: The core strategy is a widespread transition to refrigerants with low GWP and those free from PFAS.
• Restriction of high-GWP HFCs: The DFFE will restrict the use of high-GWP HFCs and HFC blends in specific sectors and sub-sectors, particularly where lower-GWP technologies are already available or anticipated in the near future.
• Prohibitions on new installations: There will be prohibitions on the manufacture, distribution, sale, installation, import and export of certain restricted HFCs for new systems.
• Mandatory low-GWP equipment: The use of only low-GWP refrigerants in new equipment will be enforced for certain applications, such as air conditioning and heat pumps, especially where HFCs are entirely restricted.
THE PFAS IMPERATIVE: A CALL FOR CAUTION Molefi stressed the critical issue of PFAS-affected refrigerants, warning the HVAC & R industry to exercise extreme caution as the Stockholm Convention actively phases out these ' Forever Chemicals '. " We cannot ban on the other legislation and allow it on the HFC," she warned, emphasising the need to consider the PFAS content of alternative refrigerants.
" Natural refrigerants( hydrocarbons, CO2, ammonia, water) are abundant and energy-efficient, but their flammability and toxicity necessitate urgent investment in workforce training." This involves:
• Qualification, certification and registration: beefing up and upgrading standards related to accreditation by the Quality Council for Trades and Occupations( QCTO) for servicing centres
• Qualified technicians: ensuring technicians are adequately trained to work with natural refrigerants across all sectors and for retrofitting existing systems
• System design and safety: Focusing on proper system design and incorporating all necessary safety measures
Key aspects include overseeing disposal, facilitating collaborative equipment installation, establishing robust reclamation programmes, and implementing comprehensive life cycle management from leak prevention to destruction.
This holistic approach necessitates an upgrade of waste management legislation to address electronic and electrical waste from refrigeration and air conditioning. Furthermore, Extended Producer Responsibility( EPR) schemes will be put in place to manage the disposal of all HVAC & R waste.
ACCELERATING THE TRANSITION: CALLS FOR COLLABORATION AND DATA Molefi concluded with a powerful call for industry collaboration and timely data submission. The DFFE aims to develop the HFC Management Regulation for publication for comments by the end of the current financial year. Prior to public commentary, discussions will be held at the bi-annual HFC stakeholder meeting.
The DFFE is actively collaborating with other key government departments and regulatory bodies like NRCS and SABS to ensure integrated regulation and standards.
Molefi emphasised that improving accessibility to low-GWP alternatives depends heavily on industry participation, specifically through the submission of questionnaires distributed by the DFFE. She highlighted a tight deadline: by August, a report must have been submitted to the Multilateral Fund( MLF) to determine the extent of financial assistance South Africa can receive for its transition. She warned that industries failing to provide data would risk being excluded from potential funding received through the collective efforts of others.
Finally, Molefi underscored the DFFE ' s proactive stance against dumping. They are working to expedite regulations to prevent South Africa from becoming a " dumping ground " for phased-out or restricted equipment from other countries, which would disadvantage local industries. RACA

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RACA Journal I September 2025 www. refrigerationandaircon. co. za