Do not confuse a consultation proposal with an enacted change. Defra’s 15 May 2026 update says it will not legislate in 2026 to change the HFC phasedown steps from 1 January 2027; the existing relevant Annex 5 step will continue to apply. Further reform remains an intention, not the originally proposed 2027 change already becoming law. Defra consultation update. (gov.uk)
Existing equipment restrictions still require attention. The Environment Agency’s product-ban guidance was updated on 27 August 2026 to add exemptions to its single-split-system table. Environment Agency product guidance.
Northern Ireland is different: DAERA states that the EU’s newer F-gas law, operating from 11 March 2024, applies directly there. A single Great Britain rules table is therefore insufficient for a contractor also working in Northern Ireland. DAERA.
Recommended controls for commercial AC quotation automation:
- Store jurisdiction, equipment category and refrigerant information.
- Separate restrictions on new products from assessment of existing installed equipment.
- Require a technical reviewer for refrigerant-substitution or replacement recommendations.
- Date the supporting rule and manufacturer information.
- Reject generic sales claims that every system using a named refrigerant must immediately be replaced.
The purchasing objective is traceable technical review—not asking a general-purpose chatbot to act as the refrigerant-compliance authority.
Sources cited on this page
- Defra consultation update ↗www.gov.uk
- Environment Agency product guidance ↗www.gov.uk
- DAERA ↗www.daera-ni.gov.uk