The F-Gas Regulation and its requirements for operators

From 2024, the maximum quantity and the corresponding quota for placing F-gases on the market will be reduced to 31% in accordance with Article 15(1). This will lead to a further significant shortage of F-gases.

Negotiators from the EU Parliament and Council recently agreed on a proposal to amend the F-Gas Regulation (German only) . Key points of this include an accelerated phase-down of F-gases to zero in 2050 and a ban on placing stationary refrigeration systems with F-gases with a GWP of over 150 on the market from 2030.

In principle, the F-Gas Regulation (EC) No. 517/2014 went into effect on January 1, 2015. It applies in all European Union member states. The regulation governs the industrial use of fluorinated greenhouse gases (“F-gases”) and aims to reduce Europe-wide emissions of climate-relevant F-gases 70 percent from 1990 levels by 2030.

Among other things, this regulation:

• Establishes rules for the containment, use, recovery and destruction of fluorinated greenhouse gases and related ancillary measures
• Imposes restrictions and prohibitions on the marketing of specific products and equipment that contain, or whose functioning relies upon, fluorinated greenhouse gases
• Imposes usage restrictions for certain fluorinated greenhouse gases, e.g. during maintenance and service
• Establishes quantitative limits for the marketing of hydrofluorocarbons (“phase down”).

The new regulation establishes a raft of restrictions and bans for designers, manufacturers, importers and operators of commercial and industrial air-conditioning, refrigeration and heat pump equipment that uses refrigerants. Some of the provisions in the regulation were implemented several years ago, while other provisions will be phased in over the next few years.

This article provides an overview of the most important provisions of the new regulation. It is designed to help you comply promptly and effectively with the F-Gas Regulation provisions that apply to you.

What is the significance of the F-Gas Regulation?

The F-Gas Regulation (EU) 517/2014 came into force on January 1, 2015 and is stricter than the previous F-Gas Regulation of 2006. It applies in all European Union member states and is part of the European roadmap to a low-carbon economy. Its central goal is to significantly reduce fluorinated greenhouse gases in order to protect the climate and environment.

Key content of the Regulation

The revised regulation essentially aims to reduce emissions of available virgin F-gases and/or their global warming potential (GWP) in the EU by 70 million metric tons of CO₂ equivalents to 35 million metric tons of CO₂ equivalents by 2030.

(Please see the “Phase-down” section for an explanation of the term “CO₂ equivalent” (abbreviated “CO₂-eq”).)

Three main regulatory approaches will be followed to reduce F-gas emissions:

1. 1. Introducing a phase-down of the quantities of hydrofluorocarbons (HFCs) available in the market.
2. 2. Phased-in bans on the use and marketing of F-gases.
3. 3. Retaining or supplementing safety and environmental regulations on the installation of refrigeration and heat pump equipment and on leak checks, certification, disposal and labeling.

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What gases are covered by the F-Gas Regulation?

The F-Gas Regulation generally covers the following classes of fluorinated greenhouse gases: HFCs (hydrofluorocarbons), PFCs (perfluorocarbons) and SF6 (sulfur hexafluoride) . However, the new regulation’s measures do not apply to all F-gases. The all-important phase-down, for instance, applies to HFCs but not to PFCs and SF6, which are covered by other provisions in the regulation.

Synthetic refrigerants covered by the regulation and used in refrigeration, air-conditioning and heat pump equipment and systems include the following important refrigerants:

• R-134a (GWP 1,430)
• R-407c (GWP 1,744)
• R-410a (GWP 2,088)
• R-404a (GWP 3,922)
• R-507 (GWP 3,990)

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The phase-down: gradual reduction of new refrigerants.

A key component of the F-Gas Regulation is the phase-down, a detailed roadmap that requires EU member states to gradually reduce available virgin synthetic refrigerants by 79 percent between 2015 and 2030.

Specifically, the goal is to reduce the F-gases used and/or their global warming potential (GWP) in the EU by 70 million metric tons of CO₂ equivalents to 35 million metric tons of CO₂ equivalents by 2030. “CO₂ equivalent” is the new unit of measure for the calculation: The reduction in new F-gases is no longer quantified in metric tons but in a number that describes the F-gases’ global warming potential (GWP). The GWP number is specified in kilograms of CO₂ equivalents.

Each refrigerant has a specific GWP value. For example, “x kg CO₂ equivalents” means: The increase in the greenhouse effect from emitting one kilogram of refrigerant is equal to the increase from emitting x thousand kilos of CO₂ from burning oil or gas in a heating system.

Calculate the GWP value now:

• How GWP values are calculated

The phase-down affects the industry’s entire value chain, from manufacturers to users. First, equipment manufacturers, importers and distributors (wholesalers) have to report the previous quantities of refrigerants that they have used to the EU. This information is then used to allocate certain restricted quantities of refrigerants (measured in metric tons of CO₂ equivalents) to companies in future years.

These phase-down-compliant quantities may then be put into equipment or given to certified professionals performing service and maintenance work on equipment and systems. This drastic new measure will force manufacturers and users to switch to lower-GWP refrigerants

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Maximum HFC consumption – CO₂ equivalent (in %)

The 100% baseline represents the estimated average GWP in 2015 and corresponds to the average consumption between 2009 and 2012.

The phase-down will affect plant operators in various ways, too. It will reduce the amount of HFCs available in the market in the future, which will likely increase prices significantly. Also, alternative refrigerants will probably be used more, especially in systems operated with refrigerants that are slated to be banned.

However, most of these alternative refrigerants are flammable and/or have other properties that require special consideration. Users and operators will thus have to face new requirements and regulations designed to ensure the safe, efficient and compliant handling of these substances in the foreseeable future.

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Key duties for refrigeration system operators

The F-Gas Regulation imposes numerous obligations on system operators, including leak checks and proper record-keeping and recovery. In addition, operators must only employ certified personnel for installation and commissioning as well as operation, maintenance, repair and decommissioning. The operator’s obligation to verify that the companies and individuals it hires have the necessary expertise to work on refrigerant-containing systems is one of the key provisions of the updated F-Gas Regulation.

Operators should take care to only hire refrigeration system designers and builders who can advise them on all the implications of the F-Gas Regulation from the start.

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Leak checks

Since January 1, 2015, operators of systems containing a certain amount of CO₂ equivalents of fluorinated greenhouse gases (that are not included in foams) have been required to have their systems checked for leaks in specific intervals. The specific number of leak checks depends on the refrigerant charge in the equipment. Systems must be checked for leaks in the following intervals depending on the CO₂ equivalents per refrigeration cycle:

• 5 to 50 metric tons (or 10 to 50 metric tons for hermetic systems) of CO₂ equivalents per refrigeration cycle: every 12 months, or every 24 months if a leak detection system is installed
• 50 to 500 metric tons of CO₂ equivalents per refrigeration cycle: every six months, or every 12 months if a leak detection system is installed
• More than 500 metric tons of CO₂ equivalents per refrigeration cycle: every three months, or every six months if a leak detection system is installed

Leak detection systems are mandatory above 500 metric tons of CO₂ equivalents

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Record-keeping obligations

The F-Gas Regulation requires refrigeration system operators to keep records of legally mandated leak checks. The records must be retained by the system operator and the personnel or company performing the checks for at least five years.

Records are generally required for systems that require leak checks. They must contain the following information:

• Quantity and type of F-gases
• All quantities of F-gases added during activities such as installation, maintenance, servicing or leak response
• Name and address of the recycling or reclamation facility (with certificate number, if applicable) if recycled or reclaimed F-gases are used
• All quantities removed and reclaimed
• The company that worked on the equipment (with certificate number, if applicable)
• Results of the leak check (retest)
• If the system is decommissioned: measures taken to recover and dispose of the fluorinated greenhouse gases

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Recovery obligations

Operators of stationary equipment that holds fluorinated greenhouse gases not contained in foam shall ensure that the gases are properly recovered by certified individuals or entities prior to system disposal and, where necessary, during system service and maintenance. This ensures that the gases are recycled, reclaimed or destroyed.

Conclusion

The new F-Gas Regulation tightens current provisions and introduces new ones on the manufacture and operation of refrigeration, air-conditioning and heat pump equipment. However, the most important change is the drastic reduction in CO₂ equivalents, which will result in serious changes in the use of refrigerants in refrigeration, air conditioning and heat pump equipment. The quota system (gradual reduction of marketed quantities to 21% in 2030) will likely produce a noticeable shortage of GWP-relevant refrigerants in upcoming years.

For this reason, operators should not wait until the last minute to have their systems professionally maintained and/or modified to accept alternative refrigerants under the F-Gas Regulation. Certain refrigerants will be completely banned in new systems in the future. For example, the production of systems that use R-404a/R-507 has been banned since 2020.

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