The Environmental Investigation Agency (EIA)’s London office has released a briefing urging the U.K. government to publish a National Cooling Action Plan that, among other things, calls for an accelerated phaseout of f-gases and the adoption of natural refrigerants.
The briefing – called U.K. Cooling Policy in a Warming World – comes in the wake of recent punishing heat waves that follow a pattern of higher ambient temperatures. “The U.K. has warmed by approximately 0.25°C (0.45°F) per decade since the 1980s and is warming faster than the global average,” said the briefing. “More frequent and intense heatwaves are already causing thousands of excess deaths each year, while overheating affects a growing proportion of homes, workplaces and public buildings.”
The U.K. was one of the first countries at the 2023 UN Climate Change Conference (COP28) to sign the Global Cooling Pledge, a commitment to cut cooling-related CO2e emissions by 68% by 2050 while rapidly expanding access to sustainable cooling. The pledge included publication by 2026 of a National Cooling Action Plan, but the U.K. has not yet published its plan, noted the EIA. The U.K. government has promised to deliver a “cooling outlook document” this year but the EIA regards that as fragmented and inadequate.
The EIA’s report refers to the work of the U.K.’s Climate Change Committee (CCC), an independent advisory body established under the U.K.’s Climate Change Act of 2009. In May the CCC published its Fourth Independent Assessment U.K. Climate Risk (CCRA4-IA), “A Well Adapted U.K.,” which noted that improving cooling is essential for climate resilience and adaptation, including an increased uptake of air-conditioning; in February CCC issued The Seventh Carbon Budget.
“There are low-GWP alternatives to HFCs for air-conditioning and heat pump applications – natural refrigerants, which have been widely used in refrigeration and could be increasingly used in space cooling and heating.”
The Environmental Investigation Agency
In its report, the EIA encourages the U.K to minimize “active cooling” – particularly air-conditioning – by supporting “passive cooling” measures in new and retrofit buildings such as external shading, cool roofs, solar control glass and increased ventilation. It also calls for expansion of urban greening, shading and nature-based cooling solutions. “Reliance on air conditioning should not become the default adaptation response,” the report said, adding that an over-reliance on conventional air-conditioning “risks locking the U.K. into decades of additional emissions from energy use and f-gases.”
However, where air-conditioning is needed, the report urges the replacement of f-gases – both high-GWP HFC and HFOs – with natural refrigerants, including mandatory energy-efficiency standards. The U.K. F-gas Regulation “must be urgently reviewed to accelerate the HFC phaseout, align with the EU [updated F-gas Regulation] and implement bans on f-gases in cooling equipment to ensure the transition to natural refrigerants,” the EIA said. The report noted that HFOs, while low GWP, can escape into the atmosphere and break down into trifluoroacetic acid (TFA), a PFAS (per- and poly-fluoroalkyl substance) pollutant that has infiltrated the natural environment.
“There are low-GWP alternatives to HFCs for air-conditioning and heat pump applications – natural refrigerants (non-fluorinated refrigerants such as propane [R290], carbon dioxide (R744] and ammonia [R717]), which have been widely used in refrigeration and could be increasingly used in space cooling and heating,” the briefing said.
Heat pump rollout
EIA pointed to the need for natural refrigerant-based heat pumps as the country seeks to decarbonize heating. The U.K.’s Heat and Building Strategy aims to roll out 600,000 hydronic heat pump systems per year by 2028 so it is critical to do this without locking in additional HFC consumption and emissions, the report said. It added that recently introduced subsidies for heat pumps under the Boiler Upgrade Scheme should be revisited to prioritize f-gas free heating and cooling models.
Government-approved prohibitions on a broad range of cooling equipment containing f-gases will be a critical “signpost” for manufacturers and end users, “driving green innovation and enabling timely investment decisions,” the report said.
In the EU, anticipation of upcoming f-gas bans has resulted in the adoption of residential propane heat pumps models, with their market share increasing from 3% in 2021 to 38% in 2024, the report noted.
The EIA also calls for an expansion of district cooling and integrated heating and cooling networks, along with temperature management standards in commercial and public buildings. In addition, highly efficient fans can avoid air-conditioning while hybrid systems, combining low-energy fans and/or evaporative coolers with air-conditioning, can greatly reduce the energy used, it said.
Mandatory training and certification
The EIA pointed out the adoption of natural refrigerants should be accompanied by the development of a skilled workforce through mandatory training and certification.
“The U.K. government “needs to encourage an increase in skilled installers able to address the expected roll out of heating and cooling technologies,” the EIA said, adding, “Research from [the U.K.] DESNZ [Department for Energy Security and Net Zero] in 2023 found that two-thirds of the heating and cooling workforce were aged over 45, with two-fifths of those surveyed planning to leave the sector in the next decade.”
As part of a National Cooling Action Plan, EIA recommended addressing the “equity gap” between those who can and can’t afford air-conditioning. “Cooling should be recognized as a public health and equity issue, with priority support for low-income households, older people and heat-vulnerable communities,” the briefing said. This would include ensuring access to cooling shelters and community cool spaces.
Another goal cited by the EIA was enhancing public awareness and behavioral change. “Heat must be treated as a major public health risk, supported by stronger communication of risks and needs to adapt behavior,” the report stated. “Heat resilience should be embedded across workplaces, schools and community planning to improve preparedness and reduce harm.”



