PFAS (per- and poly-fluoroalkyl substances) are synthetic chemicals engineered with carbon-fluorine bonds — the strongest single bond in organic chemistry. Once made, they essentially never break down in the environment, which is why they are called 'forever chemicals'. Most HFC refrigerants in commercial use today are PFAS — including R410A, R404A, R134a and R32. They have been detected in rainwater, drinking water and the bloodstream of nearly every human ever tested.

What are the health concerns with PFAS?

Peer-reviewed evidence from EU ECHA and US EPA links long-chain PFAS exposure to: endocrine disruption (thyroid and reproductive hormones); kidney cancer and testicular cancer; suppression of vaccine response in children; elevated cholesterol; ulcerative colitis; and developmental effects in infants and children. The exposure is not one-off — these molecules bioaccumulate. Once in the bloodstream, they do not leave.

What refrigerants does Karnot use?

Karnot systems use only natural refrigerants: R290 (propane, GWP 3), R744 (CO2, GWP 1), R718 (water, GWP 0), and R729 (air, GWP 0). None of these are PFAS. None have any phasedown clock. None are subject to EU F-gas regulations or pending PH equivalents. They have been used as refrigerants for over 100 years; the only reason they fell out of favour in the 1930s was that early-generation HFCs were marketed as 'safer'. That marketing claim has not aged well.

What is the EU PFAS restriction proposal?

In 2023, five EU member states (Germany, Denmark, the Netherlands, Norway and Sweden) submitted a proposal to ECHA to restrict approximately 10,000 PFAS chemicals under REACH. The proposal is in its scientific evaluation phase with SEAC/RAC opinions due 2026 and Commission decision expected 2026-2028. The likely outcome is a phased ban, with HFC refrigerants in the substance scope. The Philippines historically follows EU chemical regulation with a 6-8 year lag — meaning PH PFAS restrictions in the early 2030s are a realistic planning assumption.

What is DENR DAO 2021-31?

DENR Administrative Order 2021-31 is the Philippine codification of the Kigali Amendment to the Montreal Protocol, mandating phase-down of HFC refrigerants on a calendar timeline matching the EU and ASEAN. R404A and R410A are subject to consumption quotas through 2032 and beyond. Any new equipment installed today on these refrigerants is operating against a known phasedown clock — service refrigerant availability and price will deteriorate progressively over the asset life.

Why We Only Use Natural Refrigerants | PFAS, F-Gas, Forever Chemicals

The short version

1. Most HFC refrigerants are PFAS — engineered to never break down. They are in rainwater, drinking water and almost every human bloodstream.

2. EU proposal under REACH (2023) restricts ~10,000 PFAS chemicals, including refrigerants. Decision expected 2026–28.

3. Health evidence (EU ECHA, US EPA): endocrine disruption, kidney/testicular cancer, suppressed vaccine response in children, elevated cholesterol. Once in the blood, they don't leave.

4. Karnot uses only natural refrigerants — R290 (propane), R744 (CO₂), R718 (water), R729 (air). Zero PFAS. Zero phasedown clock. Zero legacy liability.

What PFAS actually are

PFAS — per- and poly-fluoroalkyl substances — are a family of synthetic chemicals built around carbon-fluorine bonds. The carbon-fluorine bond is the strongest single bond in organic chemistry, which is why these compounds were originally engineered: they don't react, they don't degrade, they survive heat, sunlight, water, soil, microbial action and digestion. They were a triumph of mid-20th-century industrial chemistry. The problem is that the very property that made them useful — never breaking down — is also what makes them, once released, impossible to clean up.

Most HFC refrigerants in commercial buildings today are PFAS by chemical definition. R410A, R404A, R134a, R32 — the standard fills for air conditioning, walk-in coolers, supermarket refrigeration, hotel HVAC — all contain perfluorinated structures that persist in the environment indefinitely. Refrigerant leakage from commercial systems averages 15–25% of charge per year across the industry. Every leak is a permanent addition to the global PFAS load.

What the health evidence says

The peer-reviewed literature on long-chain PFAS exposure has consolidated over the past decade. The EU's European Chemicals Agency (ECHA) and the US Environmental Protection Agency (EPA) have published linked health effects that are no longer scientifically contested:

Endocrine disruption — thyroid and reproductive hormone interference, with measured effects in occupationally exposed workers
Kidney and testicular cancer — elevated risk on long-chain PFAS exposure, IARC classification consistent with this
Suppression of vaccine response in children — measured reduction in antibody response to childhood vaccinations in cohorts with elevated PFAS exposure
Elevated cholesterol and liver enzymes — clinical-relevance findings in occupationally exposed cohorts
Developmental effects — birth weight reduction, immune system development, in infants of mothers with elevated PFAS

Two facts compound the regulatory pressure: PFAS bioaccumulates (once in the bloodstream, half-life is years to decades), and it crosses the placental barrier (a pregnant woman with PFAS in her blood is passing it to her child). When parents in the audience hear this on a slide, they go quiet. They have heard the words "forever chemical" before — usually associated with firefighting foam or non-stick pans. They have not heard it associated with the chiller above the canteen.

Karnot uses only natural refrigerants. Zero PFAS. Zero forever chemicals. Zero legacy liability when the regulator catches up.

The regulatory clock

Three regulatory tracks are converging on commercial HFC equipment:

EU REACH PFAS restriction proposal (2023). Five member states (Germany, Denmark, Netherlands, Norway, Sweden) submitted a proposal to restrict ~10,000 PFAS chemicals. Scientific evaluation by SEAC/RAC due 2026, Commission decision 2026–28. HFC refrigerants are within the substance scope.
EU F-Gas Regulation revision (2024). Already in force. Mandates 95% reduction in CO₂-equivalent F-gas placed on the EU market by 2030, with category-specific bans on new equipment starting from 2025. R410A and R404A are progressively prohibited in new commercial refrigeration.
Philippine DENR DAO 2021-31 (Kigali codification). Sets phase-down quotas on HFCs in PH market on calendar timeline matching EU and ASEAN. R404A and R410A quota reductions through 2032 and beyond. Service refrigerant availability and price deteriorate progressively over the asset life of equipment installed today.

The Philippines historically follows EU chemical regulation with a 6–8 year lag. EU REACH PFAS restrictions in 2027 implies PH equivalent regulation in 2033–35 — well within the 20-year asset life of any commercial chiller specified in 2026.

Refrigerant choice, side by side

Refrigerant	GWP	PFAS?	Phasedown status (2026)	Status in 20 years
R404A	3,922	Yes	Under DENR DAO 2021-31 quota	Stranded asset by 2032
R410A	2,088	Yes	Under DENR DAO 2021-31 quota	Service refrigerant scarce/expensive
R134a	1,430	Yes	Under DENR DAO 2021-31 quota	PFAS regulation expected 2033–35
R32	675	Yes	Lower GWP, but still PFAS	Phasedown will catch this by 2035–40
R290 (propane)	3	No	No phasedown clock	Unaffected by any current regulation
R744 (CO₂)	1	No	No phasedown clock	Unaffected by any current regulation
R718 (water)	0	No	No phasedown clock	Unaffected by any current regulation

The board-level question your CFO isn't asking yet

If you specify a 20-year-asset-life chiller today on R410A, you are committing your facility to a refrigerant whose:

service availability will progressively decline under DENR DAO quotas through 2032 and beyond
service refill price will rise materially as quotas tighten — early-2020s evidence from R22 phasedown suggests 5–10× retail price increase in late phasedown years
PFAS regulatory exposure is unknown but real over the 2030s
scope 1 emissions exposure (under SEC PFRS S2 sustainability disclosure) is real today — every refrigerant leak is a reportable scope 1 emission with 2,088× CO₂-equivalent factor

The board-level question is no longer whether to switch — it's whether to switch on this capex cycle or next. The cost of switching on a planned refresh is bounded. The cost of being forced to switch on a refrigerant unavailability event, mid-asset-life, is not.

Want to audit your refrigerant exposure?

Karnot will inventory every HFC charge across your portfolio, project the phasedown service-cost trajectory, and propose a natural-refrigerant migration path that aligns with your capex cycle — no commitment.

Book a refrigerant audit iHEAT R290 range

The refrigerant in your chiller is in your bloodstream. And it never leaves.