Will an old cool room still get gas under the phase down?

Why the gas is being limited

The National Environmental Protection Agency's page for consumers explains why the gas is regulated at all: many old refrigerants damage the ozone layer, and other refrigerants are potent greenhouse gases. HFCs, the common modern refrigerant, do not deplete the ozone layer, but they are powerful greenhouse gases that survive in the atmosphere for many years, and they are mostly used in refrigeration and air-conditioning equipment to replace the substances the Montreal Protocol phased out.

Two figures from the agency's own material show the scale. It says that, with the energy they consume, the 60 million systems across the country that use HFCs are responsible for 12% of Australia's total emissions, and its question-and-answer page gives a single-gas comparison: HFC-23 has a global warming potential of 14,800, so releasing one tonne of it is equivalent to releasing 14,800 tonnes of carbon dioxide.

That is also why release is not an option. The agency's page for consumers is plain that it is illegal to release regulated refrigerants into the air, because some can stay in the atmosphere for decades and are thousands of times worse for climate change than carbon dioxide. The phase-down is the other end of the same policy: a gradual reduction in the maximum amount of bulk HFCs permitted to be imported into Australia, started on 1 January 2018 and managed through a quota system on imports. It is implemented through the Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 and its associated Regulations.

The phase-down, year by year

The limits are set in the Regulations, and the table below is the instrument's own schedule of the HFC industry limit. A quota period runs for two years and starts on 1 January, with the first beginning on 1 January 2018. The Act requires the sum of all HFC quotas allocated for a year not to exceed the industry limit for that year.

The agency's pages give the same schedule in prose. The phase-down started on 1 January 2018 with an annual import limit of 8 megatonnes CO2-e, and reaches its end point, an 85% reduction, on 31 December 2035, which equates to 1.607 million tonnes CO2-e annually from 2036 onwards. After the phase-down is complete the rules still provide for a residual amount of HFC imports.

What the phase-down does not touch

The limit is on bulk gas, which is the qualification that matters for a business with an old unit. The agency is explicit that the phase-down covers only imports of bulk gas, such as gas in cylinders, and does not cover gas imported in pre-charged equipment such as air-conditioners or refrigerators, and that there is no import quota for HFCs in pre-charged equipment. Bulk imports make up around two thirds of the HFCs brought into Australia, and the phase-down does not apply to used or recycled HFCs, though other restrictions may be applied to the import of used HFCs.

Equipment already in the country is outside the schedule altogether. The agency's phase-down page says existing equipment that has already been imported into Australia is not affected by the phase-down, and HFCs for servicing existing equipment will be available, because the overall pace of the phase-down is designed to match demand and end-of-life equipment replacement. The agency's answer for technicians is the same: technicians will still be able to obtain HFCs to service equipment, and should keep up to date with alternative technologies and be aware of any flammability or toxicity considerations for alternative gases. For consumers, the agency's page says there will be no direct changes, because alternative technologies using different refrigerants are already available in Australia.

Recharging an old system

An older unit is not just waiting for gas; there is a rule about which gas may go back in. The agency's technicians page says rules govern charging refrigeration and air conditioning equipment and restrict the use of high global warming potential refrigerants, and puts the offence plainly: you must not charge equipment with a higher GWP refrigerant than it was designed to use, and to do so is an offence under national legislation. The system also has to say what it contains: all systems must be labelled with the refrigerant used, its charge and whether it is flammable.

Where a change of gas is being considered, the agency's safety page lists the constraints. Several alternatives with no or very low global warming potential are available in Australia and may be appropriate for the same applications as HFCs, including ammonia, carbon dioxide and hydrocarbons, sometimes called natural refrigerants, as well as hydrofluoro-olefins. But an alternative has to be used in appropriate equipment, not in equipment designed for a specific HFC, because some alternatives can be flammable and some, such as ammonia, can be toxic. The safety page says it in the same terms: alternatives must be used in equipment that is fit for purpose.

Two consequences belong in the same conversation. The safety page warns that a change to the original refrigerant type may void the equipment warranty or have insurance implications, and advises asking the technician and checking with the equipment manufacturer and your insurer. And flammability is the direction of travel: as the global warming potential of a refrigerant is reduced it tends to become more flammable, and even R32, a common lower-GWP refrigerant, is mildly flammable.

The servicing rules do not change with the gas. The agency's technicians page says to fix any leaks before recharging a system, and to keep leak detectors, vacuum pumps and recovery units maintained, with containers checked for leaks. The agency's phase-down page adds that national regulations and licensing for refrigerant handlers and technicians remain the same, and that technicians installing or servicing equipment containing alternative gases should be appropriately trained.

New equipment, and the rules as they stand

For a buyer, the rules on new equipment are written where they apply. The Regulations in force from 1 July 2026 prescribe two kinds of equipment for the Act's provision on manufacturing equipment containing a scheduled substance without a licence: small SGG air conditioning equipment, and multi-head small SGG air conditioning equipment. The definitions turn on the refrigerant and the charge: the equipment contains or uses an HFC with a global warming potential of more than 750 and has, or will have when charged, a standard refrigerant charge of 2.6 kilograms or less, and it is designed primarily to heat or cool, for human comfort, a stationary space.

Two things follow for a commercial kitchen. First, that prescription is written for air conditioning equipment, and the same instrument, the compilation in force on 1 July 2026, is the one that sets the import limits in the table above. Second, the charging rule is the one that follows a new unit into service: it must not be charged with a refrigerant of higher global warming potential than it was designed to use.

When the old unit goes

The gas does not simply leave with the cabinet. The agency's phase-down page says products should be disposed of correctly at the end of their life, with refrigerants removed by a licensed technician for recycling or disposal, and the same rules apply at decommissioning as at every other moment: an individual who removes, handles or substitutes the refrigerant must be licensed. The council lists a recovery class of licence for exactly this work: recovering and handling refrigerant when stationary or automotive equipment is decommissioned.

For the business left holding cylinders or recovered gas, the agency's material for technicians sets out the housekeeping: keep the required records, store refrigerant in refillable containers, and return them to an authorised business or destruction facility. The authorisation side is in Who may fix it: a business that acquires, possesses or disposes of recovered refrigerant from end-of-life equipment needs a restricted trading authorisation, and holders of one may not buy bulk refrigerant.

The cool room's own line does not change with any of this. Whatever gas is in the circuit, the cabinet is judged by the temperature it holds, which is where this site's scale begins: Cool room temperature.