Persistent Blind Spots: Refrigerants Are Still Hiding in Plain Sight – 2026 Update

July 13, 2026

By Jeremy Mansfield OAM Mansfield Advisory Pty Ltd

Introduction

In June 2025, my article Blind Spots on the Road to Net-Zero (featured in Ecolibrium) highlighted how Australia’s refrigerant reporting rules were allowing thousands of tonnes of refrigerant gases to remain invisible. Twelve months later, the Australian Sustainability Reporting Standard (ASRS) is well underway for Group 1 and about to commence for Group 2 entities. The blind spots have not been closed. They have been reaffirmed, with the 2026 amendments to the National Greenhouse and Energy Reporting (NGER) scheme now confirmed, and no changes to refrigerant reporting following the recent consultation on proposed updates.

Australia’s refrigerant bank contained an estimated 55,000 metric tonnes in 2022 and is projected to grow to over 80,000 metric tonnes by 2035 (per Cold Hard Facts 4). The contained CO₂e, however, is expected to decline by 20 per cent, from approximately 100 million tonnes in 2022 to 79 million tonnes in 2036.

Yet most refrigerants used in split systems, rooftop units, and mobile refrigeration are still not captured in current reporting. Without full lifecycle visibility, asset owners risk both under-reported emissions today and material future liabilities tomorrow.

This follow-up article explains why these reporting blind spots remain and what needs to be done to address this persistent gap in accounting for the refrigerants in use.

Why NGER Thresholds Are Now Outdated

The ASRS adopted the NGER scheme by allowing in-scope entities to use NGER methodologies to measure their Scope 1 and Scope 2 greenhouse gas emissions. However, entities not required to report under NGER are supposed to use the GHG Protocol approach for ASRS reporting.

NGER requirements only capture individual HVAC systems with a unit refrigerant charge exceeding 100 kg and a Global Warming Potential (GWP) greater than 1000 (using the older 2007 AR4 values). In simple terms, GWP measures how much heat a greenhouse gas traps in the atmosphere compared with the same amount of carbon dioxide over 100 years. Australia’s rules still rely on these older GWP figures, even though newer science shows many refrigerants have a higher climate impact. There are also no facility, portfolio or fleet-wide cumulative thresholds defined in NGER or ASRS.

Early ASRS 'Group 1' Company reports show refrigerant disclosures that are relatively high-level, with no details on thresholds included in the accounting of Scope 1 emissions. In fact, the GHG Protocol Corporate Standard states that if your organisation owns or controls the cooling or refrigeration equipment, any resulting emissions from refrigerant leaks are classified as Scope 1 (Direct Emissions) and must be accounted for and reported.

The GHG Protocol emphasises relevance and inventory completeness. If a source is material to your corporate carbon footprint, it cannot be excluded regardless of size. The GHG Protocol also offers a standardised HFC Tool that uses a mass-balance approach to calculate emissions based on the equipment’s starting charge, maintenance charges added, and the amount recovered at the time of disposal.

The use of NGER methodologies creates a clear tension:

• Commonwealth entities and the APS use NGER to maintain continuity with Australia’s national carbon accounts and government operations targets (such as the APS Net Zero 2030 target). This includes the specific per-unit thresholds in NGER (100 kg charge and GWP > 1000) that were originally designed for large industrial point sources.
• These same thresholds have not been updated and now limit broader accounting of refrigerant emissions across distributed assets, building portfolios, government operations, and transport fleets.
• This approach conflicts with the GHG Protocol, which requires full inventory completeness. If your organisation owns or controls the cooling or refrigeration equipment, refrigerant leak emissions are Scope 1 and must be accounted for regardless of size.
• Without accounting for all refrigerants (beyond current thresholds), it is difficult to make credible absolute or net zero claims, as a material source of Scope 1 emissions remains unaddressed or understated.

This creates a significant opportunity to improve visibility by tracking total refrigerant use in transport fleets and mobile refrigeration systems below current NGER thresholds. As Australia updates its emissions reporting to align with the GHG Protocol’s focus on complete inventories, it would enhance decision-making and responsible refrigerant management. However, this shift deviates from current practices based on NGER thresholds.

Global Leaders Are Moving on Full Lifecycle Accountability

One important difference stands out when comparing Australia’s approach with international approaches to refrigerants. Australia already has a structured reporting framework through NGER and ASRS. However, it focuses mainly on reporting thresholds, when refrigerant emissions must be included in Scope 1 inventories. Leading international jurisdictions have taken a different path with robust operational leak management and equipment stewardship rules. These require mandatory leak detection, repair timelines, recordkeeping and recovery at much lower equipment charge sizes. The goal is to actively minimise actual releases, not just report them.

While Australia has yet to embrace comparable operational requirements for smaller distributed systems, other jurisdictions are tightening thresholds and demanding full lifecycle visibility:

• US EPA AIM Act (effective 2026): Mandatory leak detection, repair, and recordkeeping rules apply to most appliances containing ≥ 6.8 kg (15 lb) of HFC refrigerant with GWP > 53. This covers both stationary equipment and refrigerated transport. (Note: These provisions may be subject to change following shifts in EPA administration.)
• California CARB Refrigerant Management Program (RMP): Facilities with the largest refrigeration systems containing >22.7 kg (50 pounds) of high-GWP refrigerant must register, conduct periodic leak inspections, promptly repair leaks, and maintain on-site service records. Retail food chains also face portfolio-level weighted-average GWP tracking and cumulative reduction targets.
• EU F-Gas Regulation 2024/573: Leak-check obligations apply at low CO₂-e thresholds: 10 t CO₂e for HFCs (equivalent to roughly 5 kg of R410A or 15 kg of R32), with mandatory certified recovery at end-of-life for stationary systems and for mobile refrigeration on trucks and trailers.

These jurisdictions enforce accountability from installation through leaks to end-of-life, while Australia has yet to define equivalent requirements.