F Gas Regulatory Update 2014

The F‐Gas Regulation, or “Regulation of the European Parliament and of the Council on fluorinated gases and repealing Regulation (EC) No 842/2006” is an EU legislative instrument which is directly applicable in all EU Member States. It aims to reduce emissions stemming from F‐gases and is part of the European’s climate change agenda as set out in the EU Low Carbon Roadmap. The F‐gas Regulation (EU) N 517/2014 was published in the Official Journal on 20 May 2014. The 2014 Regulation fully replaces the 2006 F‐Gas Regulation as of January 2015. There are still some Commission regulations linked to the 2006 F‐Gas Regulation that remain valid for now, and these will be revised by the Commission at a later stage.

The new Regulation introduces additional requirements compared to the 2006 Regulation. Although the new rules maintain the principles of the 2006 Regulation, the new rules go much further as they introduce a completely new mechanism to ensure emission reductions. This mechanism is called the phase‐down and will gradually reduce the consumption of HFCs. It will also change the way industry can use HFCs.

The phase‐down is a step‐by‐step approach where the quantities of HFCs expressed in CO2 equivalent that are placed on the market are gradually reduced through the allocation of quotas by the European Commission to producers and importers of bulk HFCs. As a result of the phase‐down, HFC consumption will be reduced by 79% by 2030. This is an unprecedented reduction and means that industry and users need to make the transition to refrigerants with a lower global warming potential.

Phase down schedule
YEAR  
2015 100%
2016 ‐ 2017 93%
2018 ‐ 2020 63%
2021 ‐ 2023 45%
2024 ‐ 2026 31%
2027 ‐ 2029 27%
2030 21%

The focus on GWP and their CO2 equivalents (rather than weight, as in the 2006 Regulation) goes further than the phase‐down and can be found in other relevant provisions of the new rules. For example, leak checks will now be based on CO2 equivalents rather than kilograms.

Quotas also are expressed in CO2 equivalent. This means that the higher the Global Warming Potential (GWP) of a refrigerant, the higher the amount of CO2 equivalent for a given number of kilograms and the higher the quota required. For example, 10kg of the refrigerant R134a which has a Global Warming Potential (GWP) of 1430 will correspond to a quantity of 10kg x GWP1430 = 14,300kg of CO2 equivalent, whilst 10kg of R404A (GWP3922) will correspond to 39,220 kg of CO2 equivalent.

The Regulation covers the use of HFCs, PFCs and SF6 in all their applications with the exception of Mobile Air Conditioning, which is covered by the MAC Directive:

  • Directive 2006/40/EC of the European Parliament and of the Council of 17 May 2006 relating to emissions from air conditioning systems in motor vehicles and amending Council Directive 70/156/EEC

Bans

The new bans particularly target refrigeration and air‐conditioning applications. Below you will find the overview of the different bans and their dates of entry into force. These bans complement the bans that are already in force since the 2006 Regulation.

Domestic refrigerators and freezers that contain HFCs with GWP of 150 or more 1 January 2015
Refrigerators and freezers [...] for commercial use
(hermetically sealed systems)
that contain HFCs with GWP of 2500 0r more 1 January 2020
That contain HFCs with GWP of 150 or more 1 January 2022
Stationary refrigeration equipment, that contains, or that relies upon for its functioning HFCs with GWP of 2500 or more except equipment intended for application designed to cool products to temperatures below ‐500C 1 January 2020
Multipack centralised refrigeration systems for commercial use with a capacity of 40kW or more that contain, or that rely upon for their functioning, fluorinated greenhouse gases with GWP of 150 or more, except in the primary refrigerant circuit of cascade systems where fluorinated greenhouse gases with a GWP of less than 1500 may be used 1 January 2022
Movable room air‐conditioning appliances (hermetically sealed equipment which is movable between rooms by the end user) that contain HFCs with GWP of 150 or more 1 January 2020
Single split air‐conditioning systems containing less than 3kg of fluorinated greenhouse gases, that contain, or that rely upon for their functioning, fluorinated greenhouse gases with GWP of 750 or more 1 January 2025
Foams that contain HFCs with GWP of 150 or more except when required to meet national safety standards Extruded polystyrene (XPS) 1 January 2023
Other foams 1 January 2018
1 January 2018

Servicing

As of 2020, refrigeration equipment with a charge size of 40 tonnes of CO2 equivalent or more will no longer be able to be serviced or maintained with virgin HFCs with a GWP above 2500.

Note that this ban does not apply to military equipment or equipment intended for applications designed to cool products to temperatures below – 50 °C.

Until 2030, recycled or reclaimed HFCs with a GWP above 2500 can still be used for service or maintenance purposes. There are no restrictions for the service and maintenance with HFCs with a GWP below 2500.

Leak Checks

Just like the 2006 Regulation the regularity of checking depends on the refrigerant content of the equipment (per refrigerant circuit). However, instead of basing the content on the amount in kilograms (as was the case in the 2006 legislation), the leak checks will now depend on the amount of tonnes of CO2 equivalent contained in the refrigerant circuit:

For equipment that contains fluorinated greenhouse gases of between 5 and 50 tonnes of CO2 equivalent per circuit, checks will need to be done every 12 months (or 24 months with a leakage detection system). Equipment with less than 3kg charge which was previously exempted may now need to be leak checked. Example: systems with 1.2kg of 404A.

For equipment between 50 and 500 tonnes of CO2 equivalent per circuit, the checks will need to take place every 6 months (or 12 months if you have a leakage detection system).

For equipment with over 500 tonnes of CO2 equivalent per circuit, the checks will need to take place every 3 months (or 6 months if you have a leakage detection system).

Amount of tonnes of CO2 equivalent / circuit Frequency of leakage checks
Without a leakage detection system With a leakage detection system
From 5 to 50 tonnes Every 12 months Every 24 months
From 50 to 500 tonnes Every 6 months Every 12 months
Over 500 tonnes Every 3 months Every 6 months

If equipment is hermetically sealed, it is not subject to leak checks provided the quantity in the circuit is less than 10 tonnes of CO2 equivalent, provided that the equipment is labelled as such.

Labels

Until the end of 2016 the existing equipment labels can be used. From 2017, labels for new equipment placed on the market will need to be changed as the new legislation requires slight adaptations compared to the 2006 regulation.

The existing labelling obligations will be maintained, but as of 2017 refrigerant quantities will need to be indicated in CO2 equivalents. It will also be necessary to include information on GWP (for gases with a GWP above 150) in descriptions used for advertising.

If recycled or reclaimed refrigerants are used, the batch number and name and address of the reclamation or recycling facility must be indicated.

Implementing regulations

There are ten implementing Regulations that provide the necessary detail for successful operation of the F‐ Gas Regulation. These are:

  • COMMISSION REGULATION (EC) No 1493/2007 of 17 December 2007 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, the format for the report to be submitted by producers, importers and exporters of certain fluorinated greenhouse gases.
  • COMMISSION REGULATION (EC) No 1494/2007 of 17 December 2007 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, the form of labels and additional labelling requirements as regards products and equipment containing certain fluorinated greenhouse gases.
  • COMMISSION REGULATION (EC) No 1516/2007 of 19 December 2007 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, standard leakage checking requirements for stationary refrigeration, air conditioning and heat pump equipment containing certain fluorinated greenhouse gases.
  • COMMISSION REGULATION (EC) No 1497/2007 of 18 December 2007 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, standard leakage checking requirements for stationary fire protection systems containing certain fluorinated greenhouse gases.
  • COMMISSION REGULATION (EC) No 303/2008 of 2 April 2008 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, minimum requirements and the conditions for mutual recognition for the certification of companies and personnel as regards stationary refrigeration, air conditioning and heat pump equipment containing certain fluorinated greenhouse gases.
  • COMMISSION REGULATION (EC) No 304/2008 of 2 April 2008 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, minimum requirements and the conditions for mutual recognition for the certification of companies and personnel as regards stationary fire protection systems and fire extinguishers containing certain fluorinated greenhouse gases.
  • COMMISSION REGULATION (EC) No 305/2008 of 2 April 2008 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, minimum requirements and the conditions for mutual recognition for the certification of personnel recovering certain fluorinated greenhouse gases from high‐voltage switchgear.
  • COMMISSION REGULATION (EC) No 306/2008 of 2 April 2008 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, minimum requirements and the conditions for mutual recognition for the certification of personnel recovering certain fluorinated greenhouse gas‐based solvents from equipment.
  • COMMISSION REGULATION (EC) No 307/2008 of 2 April 2008 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, minimum requirements for training programmes and the conditions for mutual recognition of training attestations for personnel as regards air‐conditioning systems in certain motor vehicles containing certain fluorinated greenhouse gases.