The refrigerant phase-down: what it means for ageing cold-store plant

What DCCEEW's own assessment found

The Department of Climate Change, Energy, the Environment and Water's "Cold Hard Facts" series tracks Australia's refrigerant supply and demand under the international Kigali Amendment phase-down. Its most recent assessment, Cold Hard Facts 4 (most recently updated December 2024), found that Australia is using more refrigerant than it is currently importing — a gap being masked, for now, by stockpiles built up before quota controls began restricting imports in 2018.

That stockpile is not permanent. It is a buffer built from a period when imports were unrestricted, being drawn down against a legal import quota that only shrinks from here. Once it is exhausted, the gap between what the country uses and what it is legally allowed to import becomes visible in scarcity and price, not just in a government report — a genuine planning issue for any cold storage facility weighing when to service or replace ageing plant.

The phase-down schedule

Australia's HFC phase-down, implemented under the Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 in line with the Kigali Amendment to the Montreal Protocol, began cutting import quotas from 1 January 2018. Reporting on the schedule indicates a further quota cut of around 19% from 1 January 2026, a larger step-down around 2030, and a final quota of roughly 15% of the 2018 baseline by 2036. These schedule figures are drawn from secondary reporting on the legislated schedule rather than a direct reading of the Act's own quota table, so a business planning a specific capital decision around an exact percentage should confirm the current year's figure against the Ozone Protection Act schedule itself before committing.

The direction is not in doubt either way: every step in this schedule reduces how much legally imported refrigerant is available, on a fixed timetable, regardless of what happens to demand.

Why this is a plant-replacement issue, not just a compliance one

A cold store still running older plant on high-GWP refrigerants — R404A, R134a and similar — is exposed on two fronts at once as the phase-down continues: a shrinking legal quota for replacement gas when a system needs a top-up, and, mechanically, rising scarcity-driven cost for that same gas as supply tightens against steady or growing demand. Neither of those pressures depends on the plant breaking down; both apply simply from continuing to operate an older system through a schedule that keeps cutting the gas it depends on.

This sits alongside the energy-cost picture in where a cold store's energy actually goes — refrigeration is already the dominant cost line in a cold store's energy bill, and ageing plant running on an increasingly scarce, increasingly expensive refrigerant charge compounds that cost rather than sitting apart from it.

• DCCEEW's Cold Hard Facts 4: Australia using more refrigerant than it imports
• A pre-2018 stockpile is currently masking the gap — it is being drawn down, not replenished
• A further import quota cut of roughly 19% is reported from 1 January 2026
• Final quota reported at roughly 15% of the 2018 baseline by 2036

What this changes about a plant-age decision

For a facility weighing whether to keep servicing an older refrigeration system or invest in newer, lower-GWP plant, the phase-down schedule is a reason to treat that decision on a timeline rather than waiting for a fault to force it — the cost and availability of the refrigerant an old system depends on is scheduled to keep moving in one direction regardless of when the equipment itself actually fails. A newer cold-store building specification increasingly assumes lower-GWP refrigerant from the outset for exactly this reason, and the capital cost of a plant swap is worth budgeting alongside the wider numbers in warehouse fitout costs rather than treated as a stand-alone maintenance line.

This is a capital-planning and supply question, not a safety or emissions-compliance claim about any specific plant — get a refrigeration engineer's assessment of your own system's refrigerant type and remaining service life before treating any of the above as a reason to act on a fixed timeline.

Where a plant replacement is being scoped anyway, it is worth folding into the same review as general energy cost management and, for a facility wanting a comparable external benchmark once the new plant is running, a NABERS rating — both are more efficient to assess alongside a major plant change than as separate later exercises.

Common questions

What did DCCEEW's Cold Hard Facts assessment actually find?

That Australia is using more refrigerant than it is currently importing, with the gap currently masked by a stockpile of refrigerant imported before 2018 quota controls began — a stockpile that is being drawn down, not replenished.

What is the HFC phase-down?

A legislated schedule of shrinking refrigerant import quotas under the Ozone Protection and Synthetic Greenhouse Gas Management Act 1989, implementing Australia's Kigali Amendment commitments, running from 2018 through to 2036.

Does the phase-down mean older refrigeration plant becomes illegal to run?

No — it restricts new import quota for the refrigerant gases, which affects the cost and availability of top-up gas for older systems over time. It is not a statement about the legality of operating existing plant.

Should a cold store replace ageing refrigeration plant now because of this schedule?

That is a decision for a refrigeration engineer assessing the specific system's refrigerant type, condition and remaining service life — this page describes the supply and cost trend the schedule creates, not a recommendation for any individual plant.

Read next

• the refrigeration share of a cold store's energy bill
• the NABERS Warehouses and Cold Stores tool
• cold storage facilities Australia
• the cold-store coating case
• demand charges
• wholesale gas contract prices