Executive Summary
The National Environment Agency (“NEA“) of Singapore has issued a Consultation Paper on “Public Consultation on Requirements for Equipment Containing Hydrofluorocarbon (“HFC”) Refrigerants” concerning the following key proposals:
- Introduction of Global Warming Potential (“GWP“) limits on supply of new:
- Standalone commercial refrigerator (≤150g charge)
- Centralised commercial refrigeration systems
- Passenger Cars & Light Goods Vehicles (“LGVs“)
- Mandatory on-site recovery of refrigerants recovered during the decommissioning of:
- Centralised commercial refrigeration systems
- Centralised industrial refrigeration systems for cold rooms
- LGVs
- Refrigerated Trucks
Timeline for implementation: The proposed requirements will be implemented on 1 April 2027. Suppliers of new Standalone commercial refrigerators, centralised commercial refrigeration systems and LGVs are given a grace period up to 31 March 2028 to clear existing stocks of equipment and vehicles containing refrigerants that do not meet the imposed GWP limit and to fulfil agreements / contracts entered before 1 April 2027.
The Update provides a summary of the key proposals and what they mean for the industry. It is essential to recognise the significant impact of the proposed regulations. The introduction of GWP limits and mandatory on-site recovery of refrigerants will undoubtedly drive the industry towards more sustainable practices. Businesses must adapt to these changes by ensuring compliance with the new regulations and investing in technologies that meet the prescribed standards. This proactive approach will not only help align businesses practices with the national climate goals but also position companies as leaders in environmental stewardship. Our team is happy to guide you through these regulatory changes and ensure that your business remains compliant and competitive in this evolving landscape.
The consultation exercise lasted from 8 September 2025 to 19 September 2025.
Objective and Background
The proposals aim to support the national climate ambition, which takes into consideration seven categories of greenhouse gases (“GHGs“) including HFCs, to reduce emissions to around 60 million tonnes of carbon dioxide equivalent (MtCO2e) in 2030 after peaking emissions earlier.
In October 2022, NEA banned the sale of new household air-conditioners and refrigerators, and water-cooled chillers that use refrigerants with high GWP. Among other requirements, NEA mandated on-site recovery of refrigerant from decommissioned chillers and submission of records for regulated greenhouse gas works on chillers.
Proposed Introduction of GWP Limits
The proposed regulations will ban the sale of new equipment and vehicles containing HFC refrigerants that do not meet the GWP limit of 150.
Impact: If the proposal is accepted, the applicable equipment and vehicles will be regulated under the Environmental Protection and Management Act and such regulated goods will be required to be registered and contain refrigerants that do not exceed the prescribed GWP limit of 150.
| Equipment/Vehicle | Scope |
|---|---|
| Standalone commercial refrigerator | Covers complete factory-made systems with refrigerant charge of 150g or lower and used to cool and temporarily store perishable items for commercial sale, such as beverages and food, and includes equipment such as chiller and/or freezer storage cabinets, display cabinets and counter-top refrigerators, and wine coolers |
| Centralised commercial refrigeration systems | Covers multipack compressor racks, including direct expansion systems and indirect systems, and semi-plug-in water loop systems typically used for food retail outlets such as supermarkets |
| LGVs | Covers vehicle air-conditioning systems used for passenger cabin cooling |
Proposed Mandatory On-site Recovery of Refrigerants
The proposed regulations will require companies to recover refrigerants with GWP of more than 15 from the following equipment during decommissioning works:
- Centralised commercial refrigeration systems covering multipack compressor racks, including direct expansion systems and indirect systems, and semi-plug-in water loop systems typically used for food retail outlets such as supermarkets
- Centralised industrial refrigeration systems for cold rooms covering centralised distributed systems
- LGVs
- Refrigerated Trucks
Impact: When this proposal is adopted, companies involved in installation, maintenance or decommissioning works are to:
- Register with NEA as a GHG
- Recover refrigerants with GWP of more than 15 from regulated equipment during decommissioning works.
- Ensure that the refrigerants are sent to a licensed Toxic Industrial Waste Collector (TIWC) for recycling/ reclamation/ destruction
- Maintain and submit records of regulated GHG works (installation, maintenance or decommissioning) quarterly.
If you have any queries on the development, please reach out to our Contacts or KM at [email protected]. Additionally, local small and mid-sized enterprises can tap on our ESG legal fee subsidy for environmental or climate related legal advisory under the Sustainability Legal Catalyst Programme with Enterprise Singapore (link to website). Terms and conditions apply. You can reach out to us at [email protected].
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