At its 98th meeting, the Executive Committee approved the third and final stage of Bahrain's HCFC phase-out management plan (HPMP), led by the Supreme Council for Environment with UNEP as lead implementing agency. This milestone will enable Bahrain to eliminate its remaining HCFC consumption and complete its phase-out commitments under the Montreal Protocol.
Since stage I, Bahrain has built its strategy on strong regulation, refrigerant management, and capacity building across the refrigeration and air-conditioning (RAC) servicing sector. The results speak for themselves: Bahrain has surpassed its reduction targets under both stage I and stage II, including its accelerated stage II commitment, achieving a 74 per cent reduction in HCFC consumption from baseline in 2025, offering a genuine template for other states navigating refrigerant phase-out or phase-down.
Setting the foundation
Early studies exposed the key gaps: RAC technicians lacked the training and incentive to handle refrigerants responsibly, so refrigerant was vented rather than recovered, leaks went undetected, and recycling was minimal. Stage I set out to close them.
Bahrain built its legal foundation on Europe's F-Gas regulation, adapted for local conditions, through Law 54/2014, implementing the Gulf Cooperation Council for Arabian Gulf States Unified Regulation Unified Regulation on ODS and bringing HCFC import, export, and trade under control.
Following extensive stakeholder consultation, Bahrain passed bylaws addressing key challenges including: a certification scheme for RAC technicians and companies, a ban on venting, mandatory recovery and reclamation, leak monitoring for large systems and was the first country in the region to implement a prohibition on the use of disposable cylinders. In parallel, Bahrain built the National Refrigerant Reclamation Facility and a supporting recovery, recycling, and reclamation network, so training, infrastructure, and regulation were implemented together.
Raising the bar in stage II
Stage II strengthened what was already in place. An electronic licensing system replaced manual import/export controls, while bans on HCFC-based central cooling units, used RAC equipment, non-refillable cylinders, and HCFC-141b targeted the cheapest, highest-impact sources for early cuts.
Customs officers, environmental officers, and importers were trained, and regular compliance visits followed. New standards for refillable cylinders, labelling, refilling, reclamation, and disposal backed the disposable cylinder ban; four refrigerant refilling centres came online as a result. The technician certification scheme, developed by the National Ozone Unit in cooperation with UNEP, the Italian Association of Technicians and Centro Studio Galileo and the Ministry of Education, now underpins roughly 1,100 licensed technicians and 3,000 licensed companies and workshops Supported by a structured licensing database that enables authorities to verify license validity, support inspections and maintain records of licensed technicians and servicing companies.
Locking in the gains: stage III
Recent regulatory developments include a ban on HCFC-22-based air-conditioning equipment and HCFC-141b pre-blended polyols from 1 January 2025, strengthened licensing requirements for refrigerant handling activities, expanded recovery and reclamation requirements, and additional requirements for large refrigeration and air-conditioning systems.
With stage III, Bahrain's priorities are strengthening regulatory oversight, digital monitoring and reporting systems; improving compliance and traceability by integrating licensing and technician certification systems; and preparing for the HCFC servicing tail ahead of a planned 2030 HCFC import ban.
The experience gained through HPMP implementation provides a solid platform for Bahrain to further develop an integrated lifecycle refrigerant management system, ensuring that future investments under the Kigali Implementation Plan (KIP) build upon existing achievements and maximize long-term environmental and institutional benefits.