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EU F-Gas Regulation Guidance Information Sheet 21: Training and Certification Requirements for Refrigeration, Air-Conditioning and Heat Pumps

This information sheet is aimed at individuals and organisations that carry out F-Gas handling operations related to stationary refrigeration, air-conditioning and heat pumps (RACHP) and refrigerated trucks and trailers (RTT). For mobile air- conditioning applications the requirements are different – see Information Sheet 22.

The guidance will also be useful for operators of equipment using F-Gases that need to use certificated companies and technicians for installation and maintenance.

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

Training and certification is an important feature of the F-Gas Regulation as it ensures that technicians understand how to minimise emissions during installation, maintenance and at end-of-life of equipment containing F-Gases.

This Information Sheet describes the requirements that apply to training and certification related to:

  • Stationary refrigeration, air-conditioning and heat pumps (RACHP)
  • Refrigerated trucks and trailers (RTT)

For training requirements related to mobile air-conditioning – see Information Sheet 22. 

Further guidance is available – see Information Sheet 30 for a full list and for a glossary of terms

2. Personnel Training and Certification – General Requirements for RACHP

Activities covered by personnel training requirements

Personnel involved in certain activities on equipment that contains or is designed to contain F-Gases require an F-Gas handling training qualification. In particular, this applies to:

  • Installation
  • Leakage checking
  • Maintenance or servicing
  • Refrigerant recovery
  • Decommissioning

Sectors requiring mandatory personnel training

The end user sectors for which these training requirements apply include:

  • 1)  Stationary refrigeration, air-conditioning and heat pumps – this includes equipment of any size that contains an F-Gas refrigerant (usually an HFC refrigerant).
  • 2)  NEW: Refrigerated trucks and trailers using F-Gas refrigerants.

Refrigerated trucks: motor vehicles above 3.5 tonnes and equipped with a refrigeration unit.

Refrigerated trailers: vehicles designed to be towed by a tractor or truck and equipped with a refrigeration unit. 

Who should hold a personnel training certificate?

All technicians that carry out the activities detailed above on equipment in the sectors listed above that contains F-Gases must hold an F-Gas handling certificate. This requirement applies both to in- house staff and to personnel employed by external contractors.

An appropriate qualification for personnel working on these systems can only be awarded by an approved certification and evaluation body. These are bodies that have been approved by the UK Government, as detailed in GB Statutory Instrument 261/2009.

Note: Statutory Instrument 261/2009 is being replaced, although it is still in force in the first quarter of 2015. A new SI will replace it during 2015; it is not expected that the list of approved bodies will change. 

Scope of personnel training

The F-Gas Regulation requires all EU Member States to provide suitable training programmes for personnel working in these areas. The training programmes must cover:

  • applicable regulations and technical standards
  • emission prevention
  • recovery of fluorinated greenhouse gases
  • safe handling of equipment of the type and size covered by the certificate
  • NEW: information on relevant technologies to replace or to reduce the use of fluorinated greenhouse gases and their safe handling. 

The detailed scope of training is defined in European Commission Regulations published to support the 2006 F-Gas Regulation. These Regulations are still valid. The relevant training Regulation is:

  • Regulation EC/303/2008 - Stationary refrigeration, air-conditioning and heat pumps This Commission Regulation specifies the required practical skills and theoretical knowledge and it specifies the conditions for mutual recognition of certificates between EU Member States.

It should be noted that there is currently no Commission Regulation that defines the training requirements for refrigerated trucks and trailers. Until such a Regulation has been published, it should be assumed that the requirements for stationary RACHP apply to refrigerated trucks and trailers.

Validity of existing personnel certificates

Existing certificates issued in accordance with the 2006 EU F-Gas Regulation remain valid, in accordance with the conditions under which they were originally issued.

It is important to note that the training requirements have been slightly extended in the 2014 Regulation, but this will not invalidate any existing certificates. Member States need to ensure that all personnel holding existing certificates have access to information regarding each of the following:

  • relevant technologies to replace or to reduce the use of F-Gases and their safe handling
  • existing regulatory requirements for working with equipment containing alternative refrigerants to F-Gases

It is not yet clear how this requirement will be fulfilled in the UK. It is likely that standard information material will be prepared by experts and circulated to certificate holders via Certification Bodies or training centres.

3. Personnel Training and Certification – Specific Requirements for RACHP

Categories of Training and Certification

For personnel working on stationary refrigeration, air-conditioning and heat pumps, the European Commission Regulation 303/2008 refers to four different levels of certification, which allow personnel to carry out different activities. Category I covers all activities whereas the other 3 categories are more restrictive: The categories are defined in Table 1.

Table 1: Categories of RACHP Personnel Training 

* < 6 kg for systems that are hermetically sealed

UK Personnel Certification Bodies for RACHP 

Two certification and evaluation bodies are named in the GB Fluorinated Greenhouse Gases Regulations 2009 (SI No. 261) in relation to stationary refrigeration, air-conditioning and heat pumps. These are City and Guilds and the Construction Industry Training Board (CITB). Both offer qualifications that meet the minimum requirements of EC/303/2008, as shown in Table 2. These qualifications are available from a number of specialist RACHP training providers in the UK.

Table 2: Personnel qualifications that meet the minimum requirements for RACHP 

4. Company Certification

In addition to personnel certification, contractors working on stationary RACHP systems require a Company Certificate.

Activities covered by company certification requirements

Companies (including sole traders) require an F-Gas Company Certificate if they carry out the following activities on stationary RACHP equipment containing F-Gases:

  • Installation
  • Maintenance or servicing
  • Refrigerant recovery • Decommissioning

Who should hold a Company Certificate?

A Company Certificate is required by contractors providing services related to stationary refrigeration, air-conditioning and heat pumps. It is not required by contractors that only work with refrigerated trucks and trailers. All businesses that carry out the above activities for other parties require a Company Certificate. This requirement applies to sole traders as well as limited companies. Each separate “legal person”, including both companies and sole traders, needs a Company Certificate.

Requirements for a Company Certificate

To gain a full Company Certificate, businesses need to show that:

  • a)  they employ sufficient personnel to cover the expected volume of activities and those personnel hold qualifications that meet the minimum requirements of EC/303/2008 as described above
  • b)  they have the necessary tools and procedures available to their trained personnel to ensure that their clients’ F-Gas emissions can be minimised.

UK Company Certification Bodies for RACHP

Defra has designated three Company Certification bodies. Others may be designated at a later date. To obtain a Company Certificate contact one of the designated bodies as listed in Table 3.

Table 3: UK Company Certification Bodies for RACHP 

5. Other Related Information

Purchase of F-Gases

NEW: The F-Gas Regulation states that: “bulk supplies of F-Gases shall only be sold to and purchased by undertakings that hold the relevant certificates or attestations”. Companies selling F-Gases will need to screen their customers to ensure compliance with this requirement. In most cases the required proof is a Company Certificate. See Information Sheet 19 for further details about customer screening.

Exemptions from Personnel Certification

There are exemptions for three categories of personnel:

  • 1)  Trainees are exempt for up to 2 years, but they must work under the supervision of a person with an appropriate F-Gas personnel qualification and must be enrolled on a training course to obtain one of the appropriate F gas qualifications.
  • 2)  Personnel only undertaking brazing, soldering or welding on a piece of RACHP equipment would be exempt if they hold a nationally recognised qualification to undertake such activities and if they are supervised by a person holding an appropriate personnel certificate to undertake installation of F-Gas containing equipment. 
  • 3) Personnel undertaking recovery of F-Gases from “waste equipment” under the WEEE Directive (Waste Electrical and Electronic Equipment) EC 96/2002 with an F-Gas charge less than 3 kg, in premises covered by a suitable permit, are exempt provided that they are employed by the company holding the permit and have completed a training course on the minimum skills and knowledge corresponding to Category III that is verified by an attestation of competence issued by the permit holder.

Manufacturers

Personnel and Company Certification requirements do not apply to any RAC manufacturing and repairing activity undertaken at a manufacturer’s sites.

What is the status of a non-UK personnel qualification?

The EC F gas Regulation requires that Member States give mutual recognition to certification of suitable qualifications from other EU countries. This will applies to certificates that meet the minimum requirements specified in Commission Regulation EC/303/2008. The European Commission has published a list of qualifications that meet the minimum requirements.

What is the status of a non-UK Company Certificate?

A Company Certificate issued in another EU Member State is valid in GB.

What is meant by “installation”?

Commission Regulation 303/2008 defines installation as follows:

“installation” means joining two or more pieces of equipment or circuits containing or designed to contain fluorinated greenhouse gas refrigerant, with a view to assembling a system in the location where it will be operated, including the action by which refrigerant conductors of a system are joined together to complete a refrigerant circuit irrespective of the need to charge the system after assembly

This is a wide ranging definition that covers all activities that involve joining individual parts of a refrigeration system together.

What is meant by “maintenance or servicing”?

Commission Regulation 303/2008 defines maintenance or servicing as follows:

“maintenance or servicing” means all activities, excluding recovery and checks for leakage, that entail breaking into the circuits containing or designed to contain fluorinated greenhouse gases, in particular supplying the system with fluorinated greenhouse gases, removing one or more pieces of circuit or equipment, re-assembling two or more pieces of circuit or equipment, as well as repairing leakages. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com 

 

Fridgehub, providing information and resources to Refrigeration, Air Conditioning and Heat Pump Suppliers, Contractors and Retail Business Operators

Visit the Fridgehub App StoreBecome a member of the Fridgehub communitySign up and register your Company in the Fridgehub directory

EU F-Gas Regulation Guidance Information Sheet 20: Annual Reporting Requirements

This information sheet is aimed at organisations that are required to submit an annual report to the European Commission under Article 19 of the 2014 F-Gas Regulation. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

Article 19 of the Regulation specifies requirements for annual reporting of production, import and export of F-Gases. Further details of reporting requirements are given in Annex VII of the Regulation and in Commission Implementing Regulation 1191/2014. The rules are complex and affect a number of different types of organisation – including many that did not need to report under the 2006 F-Gas Regulation. This Information Sheet provides details of the annual reporting requirements. 

This Information Sheet describes the requirements that apply to domestic refrigeration. Further guidance is available for other F-Gas users – see Information Sheet 30 for a full list and for a glossary of terms

2. Organisations that must provide an annual report

The following organisations must report data to the Commission annually (the relevant gases referred to are detailed in Section 3):

  • Producers of relevant gases in the EU
  • Importers of relevant gases into the EU
  • Exporters of relevant gases from the EU
  • Companies destroying relevant gases
  • Companies using F-Gases as chemical feedstock
  • Importers of equipment containing relevant gases into the EU

3. Gases to be reported

The relevant gases referred to in Section 2 include those listed in Annex I and Annex II of the 2014 F- Gas Regulation.

Annex I gases include HFCs, PFCs and SF. They are referred to in the Regulation as fluorinated greenhouse gases (F-Gases) – most aspects of the Regulation relate to F-Gases.

Annex II gases include unsaturated HFCs (HFOs), fluorinated ethers and alcohols and other perfluorinated compounds. The Annex II gases are currently used in small quantities and are only being monitored under the Regulation. 

4. Reporting Periods

All reporting is done on an annual basis, for a calendar year. Reports must be submitted no later than March 31st in the following year.

The first reports are for the calendar year 2014 and must be submitted by March 31st 2015.

5. Reporting Thresholds

Reporting is mandatory above relevant thresholds.

The reporting thresholds for production, import and export of bulk gases is either 100 tonnes CO2e or 1 metric tonne (the lower threshold applies), see Table 1 for some examples. For any gas with a GWP above 100, the tonnes CO2e threshold is applicable – this applies to most of the gases in both Annex I and Annex II (although very low GWP gases such as the new HFOs will use the 1 metric tonne threshold).

For most F-Gases, 100 tonnes CO2 is a very low threshold – much lower than the reporting threshold in the 2006 Regulation. This is illustrated in Table 1.

The reporting thresholds for destruction of bulk gases is either 1,000 tonnes CO2e or 1 metric tonne (the lower threshold applies). For any gas with a GWP above 1,000, the tonnes CO2 threshold is applicable.

The reporting threshold for use of feedstock is 1,000 tonnes CO2. There is no metric tonne alternative. The reporting threshold for use of imported pre-charged products and equipment is 500 tonnes CO2.

There is no metric tonne alternative.

Table 1: HFC Reporting Thresholds, with example kg equivalents 

* The reporting requirement is for 100 tonnes CO2 or 1 metric tonne – for gases with a GWP above 100 the CO2 threshold applies. For very low GWP gases the 1 metric tonne threshold may be applicable.

** The reporting requirement is for 1,000 tonnes CO2 or 1 metric tonne – for gases with a GWP above 1,000 the CO2 threshold applies.

n/a Not applicable: these reporting requirements were not in the 2006 Regulation 

6. Audit Requirements

Data must be verified by an external auditor for:

  • a)  HFC production, import and export if the quantities reported are above 10,000 tonnes CO2e
  • b)  HFC data related to imports of pre-charged equipment (for 2017 onwards)

The external auditor can be accredited to carry out financial audits or accredited to verify CO2 emissions under the EU Emissions Trading Scheme.

7. Further Reporting Details, Commission Regulation 1191/2014

The detailed reporting format is specified in Commission Implementing Regulation 1191/2014 which was published at the end of October 2014.

Data will be submitted using an electronic reporting tool provided by the European Environmental Agency, accessible from the website of the European Commission.

Reporting is in metric tonnes with accuracy to the third decimal place1, separately for each gas listed in Annex I or Annex II of the 2014 F-Gas Regulation.

Table 2 summarises the proposed reporting sections. The reporting requirements are split into 13 sections. Most companies only need to complete a few sections. It is important that companies reporting understand which sections are applicable. Each gas must be reported separately, in metric tonnes 

Table 2: Reporting Structure from Commission Regulation 1191/2014 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com 

 

Fridgehub, providing information and resources to Refrigeration, Air Conditioning and Heat Pump Suppliers, Contractors and Retail Business Operators

Visit the Fridgehub App StoreBecome a member of the Fridgehub communitySign up and register your Company in the Fridgehub directory

EU F-Gas Regulation Guidance Information Sheet 19: Customer Screening

This information sheet is aimed at companies selling bulk supplies of F-Gases. It provides details of the new customer screening requirements.

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

An important new requirement of the 2014 F-Gas Regulation is that companies selling F-Gases in bulk (e.g. in cylinders or drums) need to check that their customers have suitable certification. These new rules apply to all companies that supply F-Gases to contractors or to end users.

This Information Sheet provides details of the customer screening requirements. A screening methodology based on a “Letter of Assurance” from the buyer to the seller is presented and has been approved by the European Commission. It is not mandatory to follow this methodology, but if you choose to follow a different one it must meet the requirements of the Regulation in Article 6.3 and Article 11.4.

Other Information Sheets that may be relevant include:

A wide range of further guidance is available for other aspects of the EU F-Gas Regulation – see Information Sheet 30 for a full list and a glossary of terms. 

2. Rules for the sales of bulk HFCs

NEW: Customer Screening

Companies selling bulk F-Gases to contractors and to end users need to set up systems to ensure that they comply with new rules about checking customer certification and record keeping. Article 11.4 of the 2014 F-Gas Regulation requires that:

For the purposes of carrying out the installation, servicing, maintenance or repair of equipment that contain F-Gases, bulk supplies of F-Gases shall only be sold to and purchased by undertakings that hold the relevant certificates or attestations.

It is important that F-Gas suppliers understand the implications of this requirement and put appropriate procedures in place to comply with them. Key points to note are:

  • a)  The phrase “sold to and purchased by” puts legal responsibility on both the buyer and the seller. In the 2006 Regulation the legal responsibility was only with the buyer, hence there were no previous customer screening requirements.
  • b)  The “relevant certificates or attestations” refers to both Company Certificates and personnel F-Gas handling certificates and attestations. The precise requirements depend on what the buyer is using the F-Gases for (e.g. there are different certification requirements for stationary refrigeration and for air-conditioning in cars). The reference to “attestations” means that purchasers for car air-conditioning (MACs) are included in the screening requirements (as attestations are only applicable to this sector).
  • c)  A Company Certificate must be held by all contractors working for 3rd parties to carry out installation and maintenance work on (i) stationary refrigeration, air-conditioning and heat pumps and (ii) stationary fire protection systems. This includes sole traders as well as limited companies.
  • d)  A Company Certificate is not required for other F-Gas handling activities e.g. for working on mobile refrigeration and air-conditioning systems or on high voltage switchgear. However, personnel certification is required for these activities.

To establish a customer screening compliance process, suppliers should consider the categories of customers to whom they sell bulk F-Gases. These fall into the groups shown in Table 1. As shown in the table, each category has different certification requirements.

An appropriate screening process should take these customer categories into account and should also accommodate the new record keeping requirements described in Section 3.

3. Record Keeping Requirements

NEW: Record Keeping

Linked to the responsibility to check that purchasers are properly certificated is a new requirement to keep records about F-Gas sales. Article 6.3 of the 2014 F-Gas Regulation specifies that a seller must establish records of:

  • a)  The numbers of certificates of the purchasers
  • b)  The respective quantities of F-Gases purchased

Suppliers need to make such records available, on request, to the competent authority of the Member State concerned or to the Commission. Suppliers shall maintain those records for at least five years.

It is important to note that the Regulation refers to “certificate numbers” in plural. For those companies that hold a Company Certificate, one certificate number satisfies this requirement. For those without a Company Certificate, that are required to provide details of personnel certification, this means that a certificate number for each employee carrying out relevant F-Gas handling activities must be provided. Whilst this sounds onerous, it should be stressed to customers that they cannot manage compliance with Article 10 of the Regulation (training and certification) unless they keep their own up-to-date records about their employees’ certification status.

Table 1: Bulk F-Gas Customer Characteristics

1 Contractors only working on refrigerated trucks and trailers do not need a Company Certificate. The training requirements for this sector have not been fully clarified in the new Regulation. In the interim, the personnel certificates for stationary RACHP, based on Commission Regulation 303/2008, are appropriate.

2 Vehicles affected by MAC Directive 2006/40/EC

3 Service companies in the MAC sector do not need a Company Certificate. The personnel attestations for MACs, based on Commission Regulation 307/2008, are appropriate.

4 Other transport refrigeration includes small vans, iso-containers, trains, ships. Other mobile air-conditioning includes buses, trains, ships.

5 Service companies in the HV switchgear sector do not need a Company Certificate. The personnel certificates for HV switchgear, based on Commission Regulation 305/2008, are appropriate.

6 Certification is required when purchasing F-Gases for installation and maintenance activities. Manufacture of equipment and specialist use falls outside this definition. 

4. Compliance with Screening and Record Keeping Rules

To comply with these requirements it will be necessary to have a customer database. For each customer this must include (a) appropriate certification details and (b) an on-going record of the quantities of F-Gas sold. In most cases such a database will be computerised, although that is not mandatory.

It is important to note that ad hoc cash sales to an unknown customer could not be considered as being compliant. If a customer is not in your customer database they should not be able to purchase F-Gases until you have proof of certification.

F-Gas suppliers will need to approach each customer and obtain appropriate information to keep in a customer database. The data required for a customer screening database is dependent on the customer categories described in Table 1. Six different screening processes may be required, as follows:

1) Contractors holding a Company Certificate for work on stationary refrigeration, air- conditioning and heat pumps (RACHP) and fire protection systems (FPS) should provide you with details of their Company Certification. This is the simplest way of screening a customer. For many wholesalers this category covers the majority of their customers.

You should record 3 pieces of information:

  • a)  the name of the body that issued the certificate
  • b)  the certificate number
  • c)  the expiry date (UK F-Gas Company Certificates need to be renewed every 3 years).

Your customer should provide a “Letter of Assurance” providing certificate details (Click here to view or download example Appendices to this Information Sheet). Certification must be checked when you enter a new customer into your database and when the Company Certificate expiry date is reached (to check that the customer has renewed their certificate). The Commission has confirmed that it is not necessary to see a copy of each certificate if an appropriate Letter of Assurance is used.

As discussed above, all contractors carrying out installation and servicing activities on stationary RACHP and FPS must hold a Company Certificate. If they cannot show they have a Company Certificate you should not be selling them F-Gases. You should alert the Environment Agency if you are concerned that a contractor is operating without a Company Certificate.

2) Contractors or service companies that only require personnel with a training certificate or training attestation. As shown in Table 1, contractors working on refrigerated trucks and trailers, MACs in cars / vans and HV switchgear do not require a Company Certificate but they must prove they have staff with relevant personnel certification. This makes the customer screening process more complicated.

You should create a customer database entry based on a “Letter of Assurance” from the customer that confirms that their operations only relate to work on refrigerated trucks and trailers or on MACs in cars / vans or HV switchgear. The confirmation should specify how many staff hold a relevant personnel certificate or attestation details. You should request the certificate number for each trained employee (e.g. if the company employ 50 staff, a list of 50 certificates should be provided). It is the view of the European Commission that any contractor or service company that is operating in compliance with the F-Gas Regulation should have such a list readily available – otherwise they cannot be certain that all their employees hold a suitable personnel certificate or attestation.

3) Contractors or service companies that do not require any form of certification. As shown in Table 1, companies working on “other transport refrigeration or other mobile air-conditioning” do not require proof of certification.

Note: Other mobile air-conditioning means mobile refrigeration outside of refrigerated trucks and trailers (e.g. containers, trains, ships) and mobile air-conditioning outside the scope of the MAC Directive (e.g. air-conditioning for buses, trains, ships). 

You should create a database entry based on a “Letter of Assurance” from the customer that confirms that their operations only relate to work “on other transport refrigeration or other mobile air-conditioning”. You can then sell them F-Gases and it is not mandatory to keep records of the volumes sold. Note, if a company does some work in this category, but also does work on stationary RACHP, then proof of Company Certification is required and records of quantities sold should be kept.

4) End users buying F-Gases for use in equipment such as refrigeration and air-conditioning are complex from a screening perspective. End users may be purchasing F-Gases for:

  • Use by their own staff that hold an F-Gas handling certificate (it should be noted that end users that employ certificated staff do not need to hold an F-Gas Company Certificate).
  • To issue the F-Gas to 3rd party contractors that hold appropriate F-Gas certification.
  • For use on “other transport refrigeration and air-conditioning” which does not require certification.

You should create a database entry based on a “Letter of Assurance” from the customer that confirms how they intend to use the gas purchased. If they are using the F-Gases with in-house staff the buyer will need to provide a list of certificate numbers for their staff. If they are issuing the F-Gases to contractors they should provide Company Certificate details for their contractors, to prove that the end user is checking the certification details of their contractors. You need to keep records of quantities sold to end users for use in installation or servicing activities.

5) Equipment manufacturers and specialist users that require F-Gases to fill new equipment in their factory do not need certification to be able to purchase bulk F-Gases.

  • Examples of equipment manufacturers are OEMs producing aerosols, RAC equipment, insulating foam etc.
  • Examples of specialist uses are SF6 and HFCs in magnesium smelting and use of various F- Gases in semi-conductor manufacturing, solvent applications and laboratory applications.

You should create a database entry based on a “Letter of Assurance” from the customer that confirms that they are either:

  • a)  an equipment manufacturer using the F-Gas to fill pre-charged equipment and products
  • b)  a specialist end user.

You can then sell them F-Gases and it is not mandatory to keep records of the volumes sold.

6) F-Gas Reseller that purchase F-Gases to sell to other customers in bulk. You should create a database entry based on a “Letter of Assurance” from the customer that confirms that they are an F-Gas reseller and that they will ensure that their customers are screened in accordance with the customer categories and certification requirements described in Table 1.

The customer database needs to be accessible by all staff selling F-Gas products. When someone from a particular customer collects some F-Gas, either in a cash sale or on account, your sales staff should check that they are authorised to collect gas on behalf of that company and that they have a suitable certification status in the customer database. The type and amount of F-Gas sold should be recorded in the database.

For customers that provided a Letter of Assurance based on personnel certification it is good practice to ask the company to renew their Letter of Assurance on a periodic basis, and so ensure that their operations have not changed in nature. Letters should be renewed every 1 to 3 years (the renewal period for UK Company Certificates is every 3 years).

5. Letters of Assurance

The Letters of Assurance referred to above should be standardised. The Commission has approved the approach described in this document, based on the example Letter of Assurance in the Appendix to this Information Sheet.

Each letter should:

  • a)  Identify the customer
  • b)  Give a general assurance that the customer is aware of the relevant rules in the F-Gas Regulation
  • c)  Give an assurance that the certification details provided are accurate
  • d)  Provide specific details about which customer category (or categories) is relevant.
  • e)  Provide related certification details if required
  • f)  Be signed by an authorised signatory.

An example Letter of Assurance is attached (Click here to view or download an example Letter of Assurance). This has been designed to cater for all types of customer.

The example Letter of Assurance can be used in the attached format, or modified to suit specific circumstances providing the key content is not altered. The most likely modification will be to create several letters that each address just one market category.

A copy of the Letter of Assurance from a customer should be kept for at least 5 years, as it forms part of the record keeping requirement specified in Article 6.3. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com

 

Fridgehub, providing information and resources to Refrigeration, Air Conditioning and Heat Pump Suppliers, Contractors and Retail Business Operators

Visit the Fridgehub App StoreBecome a member of the Fridgehub communitySign up and register your Company in the Fridgehub directory

EU F-Gas Regulation Guidance Information Sheet 18: F-Gas Wholesalers

This information sheet is aimed at wholesalers of bulk F-Gases and of equipment pre- charged with HFC refrigerants. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

F-Gas wholesalers play an important role in the UK F-Gas supply chain. Most wholesalers sell F-Gases in small cylinders (e.g. 15 kg or 60 kg cylinders) or drums, supplying these for technicians carrying out installation and servicing work for end users. The biggest wholesale markets are in the refrigeration, air-conditioning and heat pump sectors. Wholesalers usually purchase F-Gases from “packer-filler” companies that purchase bulk supplies and then blend and re-package the gases into small cylinders.

Wholesalers need to be fully aware of the HFC phase down process in the 2014 F-Gas Regulation. They also need to be aware of new obligations regarding the sale of bulk F-Gases to contractors and other users. There are also new rules about the sales of certain types of equipment pre-charged with HFCs. These issues are discussed in this Information Sheet. Further details about the rules related to the screening of customers prior to sale of bulk F-Gases are given in Information Sheet 19. 

A wide range of further guidance is available for other aspects of the EU F-Gas Regulation – see Information Sheet 30 for a full list and a glossary of terms. 

2. The HFC Phase Down Process

A key feature of the 2014 F-Gas Regulation is the introduction of a phase down in the quantity of HFCs than can be placed on the EU market. The proposed phase down will lead to a 79% cut in current levels of HFC sales by 2030. This is a very significant cut and requires strong controls on the companies that place bulk supplies of HFCs on the EU market.

The phase down process is described in detail in Information Sheet 28. Key features are:

  • a)  The phase down is based on a series of cuts in supply from a baseline, which is the average reported consumption of HFCs on the EU market during the years 2009 to 2012.
  • b)  It is a phase down not a phase out. 21% of baseline can be placed on the market after 2030.
  • c)  It is “GWP-weighted” process”, encouraging the rapid phase down of high GWP HFCs.
  • d)  A quota system has been introduced to control HFC sales in the EU market.
  • e)  There are a number of exemptions from the phase down. 

3. Who can produce or import HFCs for the EU Market?

The HFC phase down mechanism only allows organisations with an HFC quota to produce or import HFCs for placing on the EU market. The European Commission allocates the quotas.

Incumbent Quota Holders

For 2015 to 2017, 89% of the HFC quota was allocated to those companies that produced or imported HFCs in the baseline period, 2009 to 2012. These are referred to as “incumbent quota holders”. There are 79 incumbents, although the incumbent quota allocations are dominated by just 5 companies that produced or imported most of the HFCs in the baseline period.

New Entrant Quota Holders

11% of the HFC quota is allocated to new entrants. The new entrant amount for 2015 was heavily over-subscribed – in 2015 there are 334 new entrants. Most will receive an equal quota of around 65,000 tonnes CO2e. The physical amount of gas that this equates to depends on the GWP of the HFC being imported. For HFC 404A it is around 16 metric tonnes.

4. Where will wholesalers purchase HFCs?

Wholesalers will need to purchase HFCs placed on the market by a quota holder. Most packer-fillers will hold a small quota, but they will need to purchase most of their supplies from the 5 major incumbent quota holders or their intermediaries.

Wholesalers need to check their sources of supply:

  • If you are purchasing directly from a quota holder, you should get written confirmation that the HFCs being supplied are from the supplier’s HFC quota.
  • If you are purchasing from a non-quota holder (e.g. a packer-filler), wholesalers should request written confirmation from their suppliers that the HFCs being supplied have been placed on the market from within the EU quota mechanism.

From January 1st 2015 it will be illegal to import HFCs from outside the EU without an HFC quota.

5. The Annual Maximum Allocation

It is important that wholesalers are aware of the HFC phase down steps and the possible impact that will have on HFC availability and price.

The quantity of HFCs that can be placed on the EU market each year is defined as a percentage of the baseline amount, as listed in Annex V of the Regulation. The baseline amount is 183 million tonnes CO2 equivalent (based on the average annual amount reported to have been placed on the market for the period 2009 to 2012). In 2015 the market will be capped at 100% of this amount. In 2016 only 93% of the baseline can be placed on the EU market. Following a series of cuts, the amount available from 2030 will be 21% of the baseline amount.

The phase down steps are illustrated in Figure 1. In the first 3 years (2015 to 2017) the cuts are modest. The first big cut is in 2018 – this could create supply shortages and high prices. This cut will strongly encourage users of very high GWP HFCs such as HFC 404A to use lower GWP alternatives.

Figure 1: HFC Phase Down Steps

6. Rules for the sales of bulk HFCs by wholesalers

NEW: Customer Screening

Wholesalers will need to set up new systems to ensure that they comply with new rules about checking customer certification and record keeping. The Regulation requires that:

For the purposes of carrying out the installation, servicing, maintenance or repair of equipment that contain F-Gases, bulk supplies of F-Gases shall only be sold to and purchased by undertakings that hold the relevant certificates or attestations.

It is important that wholesalers understand the implications of this requirement and put appropriate procedures in place to comply with them. The Customer Screening process is described in detail in Information Sheet 19.

NEW: Record Keeping

Linked to the responsibility to check that purchasers are properly certificated is a new requirement to

keep records about F-Gas sales. For each customer, a wholesaler must establish records of:

  • a)  Certification details (including certificate number and expiry date)
  • b)  The quantities of F-Gases purchased

To facilitate compliance with the screening and record keeping requirements wholesalers need to identify what a buyer intends to use F-Gases for and obtain the relevant certification details. The record keeping requirements are described in detail in Information Sheet 19.

7. Rules for the sales of pre-charged equipment by wholesalers

NEW: Wholesalers that sell equipment pre-charged with F-Gases, such as split system air-conditioning units, must comply with new controls introduced to ensure that such equipment is properly installed. This is to prevent DIY installation by unqualified individuals.

The Regulation requires that: Non-hermetically sealed equipment charged with F-Gases shall only be sold to the end user where evidence is provided that the installation is to be carried out by an undertaking certified in accordance with Article 10.

This rule applies only to pre-charged equipment that requires assembly or connection of components in the F-Gas circuits, such as split system air-conditioning, VRV air-conditioning or condensing units for refrigeration. It does not apply to hermetically sealed systems such as integral retail refrigerators or mono-block heat pumps.

An “undertaking certified in accordance with Article 10” means a contractor holding an F-Gas handling certificate and a Company Certificate. The phrase “where evidence is provided” will depend on the customer type:

  • If the equipment is being purchased by an installation contractor, then the evidence required is their F-Gas Company Certificate. All contractors carrying out installation of the types of pre-charged equipment described above must have a Company Certificate. This applies to sole traders as well as limited companies. A contractor screened for purchase of bulk F-Gases will automatically be suitable for this requirement.
  • If the equipment is being purchased by an end user or a 3rd party on behalf of an end user (e.g. a facility management company), they must provide a “Letter of Assurance” confirming that they will ensure that the installation will be carried out by someone with a suitable F-Gas handling certificate. The letter should state that the buyer is aware that the equipment being purchased must be installed by a qualified technician and give an assurance that the work will be done either by:
    • a)  In-house staff with the relevant F-Gas personnel certificate or
    • b)  By a contractor holding an F-Gas Company Certificate.

8. Exemptions from the HFC Phase Down

t is worth noting that there are a number of exemptions from the phase down quota system. HFCs sold for exempt applications do not count as part of the sellers’ quota. These exemptions include:

  • a)  HFCs imported into the Union for destruction
  • b)  HFCs used by a producer in feedstock applications or supplied directly by a producer or an importer to undertakings for use in feedstock applications
  • c)  HFCs supplied directly by a producer or an importer to undertakings, for export out of the EU where those HFCs are not subsequently made available to any other party within the EU, prior to export
  • d)  HFCs supplied directly by a producer or an importer for use in military equipment
  • e)  HFCs supplied directly by a producer or an importer to an undertaking using it for the etching of semiconductor material or the cleaning of chemicals vapour deposition chambers within the semiconductor manufacturing sector
  • f)  from 1st January 2018 onwards, HFCs supplied directly by a producer or an importer to an undertaking producing metered dose inhalers for the delivery of pharmaceutical ingredients
  • g)  Imports of less than 100 tonnes CO2e per year are allowed outside of the quota mechanism. This is a very low threshold, equivalent to approximately 25 kg of HFC 404A.

The exemptions (c) to (f) apply to direct sales by a producer or importer to an exempted end user. The sales cannot be via 3rd parties in the HFC supply chain. This means that wholesalers cannot make sales related to these exempted activities unless (a) they import the relevant F-Gas themselves or (b) they sell F-Gas supplied from within the EU quota.

Reclaimed and recycled refrigerant

The quota system only applies to production and import of virgin HFCs. HFCs recovered from equipment that is reprocessed to create reclaimed or recycled HFC can be sold outside of the quota system.

Reclaimed HFCs can be used for any purpose. Recycled HFCs must always be used with care as they may be contaminated or of unknown composition. The use of recycled refrigerant with a GWP above 2,500 is restricted to either (a) the organisation owning the plant from which the gas was recovered or (b) the organisation that carried out the recovery.

9. Exports of Bulk HFCs and Pre-charged Equipment

Exports of bulk HFCs are outside the EU quota mechanism. If a quota holder exports some of their product, it does not count as placing on the EU market. If a quota holder sells HFCs to a 3rd party (including a wholesaler) who then exports the bulk gas, the gas need not come from the supplier’s quota, providing the exporter informs the quota holder about the amount exported and reports the exports to the European Commission in an annual data return2.

Exports of pre-charged equipment manufactured in the EU are included within the quota system. This means that HFCs used by an EU manufacturer of pre-charged equipment must be purchased on the EU market from the quota system.

There is a customs procedure available (inward processing relief) that might allow an EU equipment manufacturer to import HFCs outside of the quota mechanism, providing it is identified as gas that is to be used to charge equipment that will be exported. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com

 

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EU F-Gas Regulation Guidance Information Sheet 17: F-Gas Producers, Importers and Exporters

This information sheet is aimed at organisations that are producers, importers and exporters of bulk F-Gases. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6.

Contractors play a major role supporting operators of refrigeration, air-conditioning and heat pump (RACHP) equipment. They have to comply with a number of requirements under the F-Gas Regulation. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

A crucial aspect of the 2014 Regulation is the introduction of the phase down in the supply of HFCs within the EU market. The phase down process has a significant impact on those companies that produce, import or export bulk HFCs. This Information Sheet provides guidance on new requirements that affect the bulk F-Gas supply industry in the EU.

A wide range of further guidance is available for other aspects of the EU F-Gas Regulation – see Information Sheet 30 for a full list and a glossary of terms. 

2. The HFC Phase Down Process

A key feature of the 2014 F-Gas Regulation is the introduction of a phase down in the quantity of HFCs than can be placed on the EU market. The proposed phase down will lead to a 79% cut in current levels of HFC sales by 2030. This is a very significant cut and requires strong controls on the companies that place bulk supplies of HFCs on the EU market.

The phase down process is described in detail in Information Sheet 28. Key features are:

  • a)  It is a phase down not a phase out. 21% of current sales can be placed on the market after 2030.
  • b)  It is based on a “GWP-weighted” process, which will encourage the rapid phase down of the highest GWP HFCs.
  • c)  The phase down is based on a series of cuts in supply from a “baseline”, which is the average consumption of HFCs on the EU market during the years 2009 to 2012. The baseline amount is 183 million tonnes CO2 equivalent.
  • d)  A quota system will be introduced to control sales in the EU market. The quota system will affect all HFC producers, importers and exporters. 
  • e)  There are comprehensive annual reporting requirements so that the European Commission can monitor and control the phase down.
  • f)  There are a number of exemptions from the phase down.
  • g)  The quota system is based on control of bulk HFC production, import and export. There are additional controls for import of pre-charged products.

3. The HFC Phase Down Regulations

In the 2014 EU F-Gas Regulation the following Articles are of key importance to F-Gas producers, importers and exporters:

  • Article 15 introduces the phase down. It places controls on producers and importers to ensure that the total quantity of HFCs that each of them places on the EU market does not exceed the quota allocated to them. The phase down steps are given in Annex V.
  • Article 15 also lists 6 exemptions from the phase down and describes a process for agreeing further short-term exemptions should they be required.
  • Article 16 describes the quota system. In particular it states that quotas will be allocated to those companies that reported production and imports during the baseline period (“incumbents”) and that some of the quota would be allocated to “new entrants”. The detailed methodology for allocation of quotas is given in Annex VI.
  • Article 17 describes the Registry that will be used to monitor and control the production and import of HFCs in the EU.
  • Article 18 describes rules for transfer of quota between companies.
  • Article 19 specifies the annual reporting requirements, with further details given in Annex VII and Commission Implementing Regulation 1191/2014.

4. The Annual Maximum Allocation

The amount of HFCs that can be placed on the EU market each year is defined as a percentage of the baseline amount, as listed in Annex V of the Regulation. The average baseline amount (for the period 2009 to 2012) is 183 million tonnes CO2 equivalent. In 2015 the market will be capped at 100% of this amount. In 2016 only 93% of the baseline can be placed on the EU market. Following a series of cuts, the amount available from 2030 will be 21% of the baseline amount. The phase down steps are illustrated in Figure 1.

Figure 1: HFC Phase Down Steps

5. Allocation of HFC Sales Quotas

The phase down process is being implemented via a sales quota system. Only companies with an official HFC quota, received from the European Commission, will be allowed to produce HFCs or import them into the EU.

  • It will be illegal for quota holders to produce or import more than their allocated quota
  • It will be illegal to produce or import HFCs without a quota.

Under the 2006 Regulation there was a legal requirement to report production, imports and exports of HFCs and other F-Gases on an annual basis. For 2015, 89% of the quotas (i.e. 89% of 183 MT CO2 baseline amount) are being allocated to the companies that reported production or imports of HFCs during the baseline period (2009 to 2012). These quota holders are referred to in this guidance as “incumbents”. The allocation is being made to incumbents is in proportion to their average share of the market in the 4 year baseline period. For example a company that sold 10% of the total EU HFC sales in 2009 to 2012 will get 10% of the amounts available for incumbents. In 2015 there will be 79 incumbents, although it is important to note that the majority of the quotas will go to 5 companies that were the dominant producers and importers in the baseline period.

A small proportion (11%) is allocated to “new entrants”. New entrants can apply for an amount that they would like to receive and will be given an allocation based on the amount they asked for and the number of other companies that applied for a new entrant allocation. A large number of companies applied for the 2015 new entrant allocation. As the allocation was significantly oversubscribed, most of the 334 valid new entrants will receive the same fairly small quota allocation for 2015 (in the region of 65,000 CO2e, which is equivalent to around 16 tonnes of HFC 404A).

The new entrant allocations will be made annually. Every 3 years there will be a recalculation of quotas, with current new entrants being merged with the incumbents, to allow further new entrants to join the market. Each recalculation will be made on the basis of the annual averages of the quantities placed on the market from the 1st January 2015.

Quotas shall only be allocated to producers or importers which are established within the EU, or which have mandated an “only representative” established within the EU for the purpose of compliance with the requirements the F-Gas Regulation. The only representative may be the same as the one mandated pursuant to Article 8 of Regulation (EC) No 1907/2006.

6. Exemptions from the HFC Phase Down

The following exemptions allow some trade in HFCs outside of the quota system:

  • a)  HFCs imported into the Union for destruction
  • b)  HFCs used by a producer in feedstock applications or supplied directly by a producer or an importer to undertakings for use in feedstock applications
  • c)  HFCs supplied directly by a producer or an importer to undertakings, for export out of the EU where those HFCs are not subsequently made available to any other party within the EU, prior to export
  • d)  HFCs supplied directly by a producer or an importer for use in military equipment
  • e)  HFCs supplied directly by a producer or an importer to an undertaking using it for the etching of semiconductor material or the cleaning of chemicals vapour deposition chambers within the semiconductor manufacturing sector
  • f)  from 1st January 2018 onwards, HFCs supplied directly by a producer or an importer to an undertaking producing metered dose inhalers for the delivery of pharmaceutical ingredients
  • g)  Imports of less than 100 tonnes CO2e per year are allowed outside of the quota mechanism. This is a very low threshold, equivalent to approximately 25 kg of HFC 404A.

It is important to note that these exemptions apply to direct sales by a quota holder to an exempted end user. The sales cannot be via 3rd parties in the HFC supply chain.

7. The EU HFC Registry

The European Commission has set up a Registry to monitor and control the quota system. Registration in the registry shall be compulsory for the following:

  • a)  producers and importers with an HFC quota (i.e. incumbents and new entrants)
  • b)  undertakings to which a quota is transferred (see Section 8 on transfers)
  • c)  producers and importers supplying, or undertakings in receipt of HFCs for the exempted purposes listed in points (a) to (f) of Section 6 above
  • d)  importers of equipment placing pre-charged equipment on the market where the HFCs contained in the equipment have not been placed on the market prior to the charging of that equipment.

The Commission shall ensure that registered producers and importers are informed via the registry about the quota allocated and about any changes to it during the allocation period. The competent authorities, including customs authorities, of the Member States shall have access, for information purposes, to the registry.

8. Transferring quotas to another company

Any incumbent quota holder may transfer in the registry that quota for all or any quantities to another producer or importer in the EU or to another producer or importer which is represented in the EU by an only representative.

Any incumbent quota holder or undertaking to whom a quota has been transferred (as described in the paragraph above) may authorise another undertaking to use its quota for the purpose of producing pre-charged equipment outside the EU for subsequent import into the EU (see Section 10 below).

New entrant quota holders are not allowed to transfer their quotas. New entrant quota holders may only authorise another undertaking to use its quota for the purpose importing pre-charged equipment provided that the corresponding quantities of HFCs are physically supplied by the authorising producer or importer.

9. Annual reporting requirements

All producers, importers and exporters of HFCs (as listed in Annex I of the Regulation) and of other gases listed in Annex II of the Regulation, must annually report data to the Commission.

Reporting thresholds defined in terms of tonnes CO2e and are summarised in Table 1.

Table 1: HFC Reporting Thresholds

* The reporting requirement is for 1 metric tonne or 100 tonnes CO2 – for all HFCs the 100 tonnes CO2 threshold always applies. For some very low GWP products listed in Annex II of the Regulation the 1 metric tonne threshold may be applicable.

n/a Not applicable: these requirements were not in the 2006 Regulation

Information Sheet 20 gives further details of annual reporting requirements.

Further details of the reporting requirements are specified in Annex VII of the Regulation and in Commission Implementing Regulation 1191/2014.

10. Imports of Pre-charged Equipment

From 2017 onwards, any refrigeration, air-conditioning or heat pump equipment imported into the EU that is pre-charged with HFCs, must use HFCs obtained from the EU quota. Importers will need to prove to the authorities that the equipment they import complies with this requirement.

Non-EU manufacturers will have the option of:

  • a)  Purchasing their required HFCs from an EU quota holder (the quota holder would deliver actual HFC fluids to the non-EU manufacturer)
  • b)  Obtain an authorisation from an EU quota holder to use a specified amount of their quota (the non-EU manufacturer will then be able to source the actual HFC fluid from a local supplier)

EU-based manufacturers of pre-charged equipment can only use HFCs from the EU quota to pre- charge their products.

11. Exports of Bulk HFCs and Pre-charged Equipment

Exports of bulk HFCs are outside the EU quota mechanism. If a quota holder exports some of their product, it does not count as “placing on the EU market”. If a quota holder sells HFCs to a 3rd party who then exports the bulk gas, that quantity does not count towards the quota holder’s allocation providing that the 3rd party exporter informs the quota holder that the gas is for export. Both parties must report the export transaction to the Commission (see Information Sheet 20).

Exports of pre-charged equipment manufactured in the EU are included within the quota system. This means that HFCs used by an EU manufacturer of pre-charged equipment must be purchased on the EU market from the quota system.

There is a customs procedure available (inward processing relief) that might allow an EU equipment manufacturer to import HFCs outside of the quota mechanism, providing it is identified as gas that is to be used to charge equipment that will be exported. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com 

 

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EU F-Gas Regulation Guidance Information Sheet 16: Manufacturers and Importers of Refrigeration, Air-Conditioning and Heat Pump Equipment

This information sheet is aimed at manufacturers and importers of refrigeration, air- conditioning and heat pump equipment (RACHP). 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6.

Manufacturers and importers of refrigeration, air-conditioning and heat pump equipment (RACHP) using HFC refrigerants have to comply with a number of requirements under the F-Gas Regulation. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

The F-Gas Regulation is an important piece of legislation that will result in significant reductions in the emissions of F-Gases. These are very powerful greenhouse gases, with global warming impacts that are several thousand times higher than CO2 (per kg of gas emitted). All EU Member States agree that it is important to reduce emissions of these gases.

This Information Sheet describes the requirements that apply to RACHP equipment manufacturers and importers. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms. 

2. Sector description

The RACHP sector covers a wide range of equipment and end users, ranging from small domestic and commercial systems to large industrial plant. Key sectors of the RACHP market include

  • Domestic refrigeration
  • Commercial refrigeration
  • Industrial refrigeration
  • Transport refrigeration
  • Stationary air-conditioning and heat pumps
  • Mobile air-conditioning

Detailed guidance on the impact of the 2014 F-Gas Regulation on each of these sectors is available in Information Sheets 1 to 6. 

Manufacturers and importers of RACHP equipment that serve these markets must become fully aware of relevant parts of the 2014 F-Gas Regulation so that they can provide suitable equipment to their customers and comply with certain legal obligations.

3. NEW: Bans on the use of HFCs in certain types of RACHP equipment

The 2014 Regulation includes a number of HFC bans as summarised in Table 1. Equipment manufacturers and importers must ensure they do not place any banned products on the market after the dates shown in Table 1.

Manufacturers should also be aware that these bans “do not tell the full story”. The HFC phase down and the service ban (see below) also have a significant influence on selecting refrigerants for new plant. Equipment manufacturers may gain a competitive advantage if they can supply equipment that uses low GWP refrigerants.

Table 1: Bans affecting manufacturers and importers of RACHP Equipment

2 All start dates are January 1st of year specified
3 This ban includes both refrigerant and foam blowing agent
4 This ban includes both refrigerant and foam blowing agent

5 Exemption for equipment cooling products below -50oC
6 The primary circuit of cascade systems can use an HFC with a GWP up to 1,500

4. NEW: Impact of the Service Ban on sales of new equipment

Purchasers of new commercial and industrial refrigeration equipment should be made aware that a “Service Ban” will affect certain existing systems using HFCs with a GWP above 2,500 from 2020. The ban applies to systems containing more than 40 tonnes CO2 equivalent (10 kg for HFC 404A). To avoid future problems manufacturers and importers should advise clients purchasing plants above this size threshold to select only refrigerants with a GWP below 2,500, with immediate effect. It makes no sense to be purchasing equipment that will need converting or replacing within just a few years.

5. NEW: Impact of the HFC Phase Down on the sales of new equipment

When purchasing new RACHP equipment your clients should also conider the HFC phase down. This will reduce the quantity of HFCs that can be sold in the EU – by 2030 there will be an 80% cut in HFC supply. Equipment bought now will still be operating when deep cuts in HFC supply are in force. Irrespective of the bans shown in Table 1, it will become increasingly important to purchase equipment using refrigerants with the lowest practical GWP to minimise the future impact of the phase down.

6. HFC Ban in MAC Directive

Mobile air-conditioning (MAC) used in cars and light vans are affected by the MAC Directive (2006/40/EC). This bans the use of any refrigerant with a GWP above 150 in new car and light van air- conditioning systems. The ban applies to new “vehicle types” (i.e. new models) with immediate effect and to all new cars from January 2017. This creates a ban on the standard MAC refrigerant (HFC 134a). Most car manufacturers are starting to use HFO 1234yf.

7. Equipment design requirements

It is important to consider the overall aims of the F-Gas Regulation and the obligations that it places on purchasers of RACHP equipment. Your equipment should be designed to help customers comply with the F-Gas Regulation. The key design rules are:

  • a)  Use the refrigerant with the lowest practical and cost effective GWP
  • b)  Design the plant for very low leakage
  • c)  For large plant fit an automatic leak detection system

Energy Efficiency is Crucial

When designing RACHP equipment it is also important to maximise the energy efficiency. During the life cycle of such equipment it is the energy related CO2 emissions that dominate the overall greenhouse gas emissions. It is counter-productive, from an environmental perspective, to use an ultra-low GWP alternative but have to sacrifice energy efficiency. Always try to ensure that the low GWP alternative that you select has equal (or preferably better) energy efficiency to the best high GWP option available on the market. 

8. Product Labelling

All RACHP products that contain F-Gases (including HFCs) shall not be placed on the market unless the F-Gases are identified with a label. The label shall indicate the following information:

  • 1)  A reference that the RACHP system contains F-Gases
  • 2)  The accepted industry designation for the F-Gas concerned or, if no such designation is available, the chemical name
  • 3)  NEW: From 1 January 2017, the quantity expressed in weight and in CO2 equivalent of F-Gas contained in the equipment, and the global warming potential of the gas
  • 4)  If applicable, a reference that the F-Gases are contained in hermetically sealed equipment

9. NEW: Pre-charged RACHP equipment

From 1st January 2017 RACHP equipment pre-charged with HFCs cannot be placed on the market unless the HFCs are accounted for within the EU HFC phase down quota system. This is an important rule that affects all pre-charged RACHP equipment (including both manufactured in the EU and imported). Examples of equipment affected includes:

  • a)  Hermetically sealed systems (e.g. for commercial refrigeration)
  • b)  Split system and VRV air-conditioning systems
  • c)  Chillers
  • d)  Mono-block heat pumps

For equipment manufactured within the EU, manufacturers should purchase refrigerant from an EU supplier that holds a quota to sell HFCs under the 2014 F-Gas Regulation. An EU based equipment manufacturer cannot import HFCs directly from outside the EU unless they hold an import quota.

From January 2017 onwards, any RACHP equipment imported into the EU that is pre-charged with HFCs, must use HFCs obtained from the EU quota. Importers will need to prove to the authorities that the equipment they import complies with this requirement.

Non-EU manufacturers will have the option of:

  • a)  Purchasing their required HFCs from an EU quota holder (the quota holder would deliver actual HFC fluids to the non-EU manufacturer)
  • b)  Obtain an authorisation from an EU quota holder to use a specified amount of their quota (the non-EU manufacturer will then be able to source the actual HFC fluid from a local supplier)

The compliance information required from manufacturers and importers of pre-charged equipment includes documentation to show the source of HFCs and a declaration of conformity.

From 1st January 2018, where HFCs contained in the equipment have not been placed on the market prior to the charging of the equipment, importers of that equipment shall ensure that by 31st March every year the accuracy of the documentation and declaration of conformity is verified, for the preceding calendar year, by an independent auditor.

Note: The auditor shall be either: (a) accredited pursuant to Directive 2003/87/EC (the EU Emissions Trading Directive) or (b) accredited to verify financial statements in accordance with the legislation of the Member State concerned.  

Manufacturers and importers of pre-charged equipment must keep the documentation and declaration of conformity for a period of at least five years after the placing on the market of that equipment. Importers of pre-charged equipment must ensure they are registered in the HFC quota system registry and must submit their verified conformity data to the European Commission annually.

10. NEW: Reporting Imports of Pre-charged RACHP equipment

Linked to the pre-charge restrictions discussed in the section above is an important new reporting requirement that applies to importers of pre-charged RACHP equipment. Key requirements include:

  • The reporting rules apply to F-Gases being placed on the EU market in all products and equipment, including RACHP equipment.
  • The rules apply to both F-Gases and “gases listed in Annex II”. F-Gases refers to a list in Annex I of the Regulation and it includes all the currently used HFC refrigerants. The gases in Annex II includes five of the new HFO refrigerants (e.g. HFO 1234yf) and a number of very unusual gases (not likely to be used in RACHP equipment).
  • The reporting threshold is 500 tonnes CO2 per year - this is a low threshold for an equipment importer. The metric tonne equivalent depends on the GWP of the refrigerant in the imported equipment. For HFC 410A, 500 tonnes CO2e is only 0.24 metric tonnes.
  • The data that must be reported includes:
    • a)  the categories of the products or equipment containing F-Gases / Annex II refrigerants
    • b)  the number of units placed on the market
    • c)  the quantities of each refrigerant contained in the products or equipment.
  • The first report must be made before March 31st 2015 for imports in calendar year 2014.
  • It is worth noting that these reporting rules do not apply to pre-charged equipment manufactured within the EU, as any HFC refrigerants contained in such equipment is already being reported by the production / import quota holder. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com 

 

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EU F-Gas Regulation Guidance Information Sheet 15: Fire Protection System Contractors

This information sheet is aimed at contractors that carry out installation, maintenance and decommissioning work on fire protection systems using HFCs. It is also useful for operators of fire protection systems that use 3rd party contractors to maintain their system. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6.

Fire protection system (FPS) contractors play a major role supporting operators of FPS equipment. They have to comply with a number of requirements under the F-Gas Regulation. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

The F-Gas Regulation is an important piece of legislation that will result in significant reductions in the emissions of F-Gases. These are very powerful greenhouse gases, with global warming impacts that are several thousand times higher than CO2 (per kg of gas emitted). All EU Member States agree that it is important to reduce emissions of these gases.

This Information Sheet describes the requirements that apply to FPS contractors. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms. 

2. Sector description

The fire protection industry make use of HFC fire extinguishing products in certain specialised building applications, where building contents have a high value and other fire protection systems (e.g. water based) could cause too much damage. In the UK most systems of this type use HFC 227ea (also referred to by trade names such as FM 200).

Detailed guidance on the impact of the 2014 F-Gas Regulation for end users in the FPS sector is available in Information Sheet 10.

Most operators of FPS make use of specialist contractors for installation and maintenance work. The skill and expertise of the FPS contracting industry is crucial, providing operators with various services through the life cycle of FPS equipment. The F-Gas Regulation places legally binding obligations on contractors to ensure that they help end users minimise the use and emissions of high GWP HFCs. It is important that contractors comply with the Regulations that apply to them and also that they are aware of other relevant parts of the F-Gas Regulation so that they can provide their clients with appropriate advice.

3. Advice regarding purchase of new equipment

Contractors often provide important advice to their clients about purchase of new equipment. In the 2014 F-Gas Regulation there are 2 important new requirements that will change the advice that contractors give to their clients. These are:

  • a)  Various specific bans, that will require lower GWP fire extinguishing fluids to be used
  • b)  The impact of the HFC phase down, that will encourage low GWP fluids in all applications

NEW: HFC Bans

The 2014 Regulation adds a ban on HFC 23 from 1st January 2016 to an exisiting ban on PFCs. See Table 1 for details.

Table 1: Bans affecting FPS Equipment

NEW: Impact of the HFC Phase Down on the purchase of new equipment

When purchasing new FPS equipment your clients should also consider the HFC phase down. This will reduce the quantity of HFCs that can be sold in the EU – by 2030 there will be an 80% cut in virgin HFC supply. Equipment bought now may still be use when these cuts in virgin supply take effect. Irrespective of the bans described above, it makes sense to always purchase equipment using fluids with the lowest practical GWP to minimise the future impact of the phase down.

The fire protection industry is committed to the responsible use of HFCs in fire protection and always recommends minimising the impact on the environment by recycling material at end-of-life. There is a significant bank of HFCs in installed systems. As these systems reach the end of their natural life the fire extinguishant may be available for recycling

4. Contractor training and certification requirements

All HFC handling operations on FPS equipment containing HFCs must be carried out by suitably trained technicians holding an F-Gas ‘Competency’ certificate and working for an F-Gas Certificated company. This includes system installation, leak testing, HFC recovery, maintenance and end-of-life decommissioning. The training and certification requirements are based on those already specified in the 2006 F-Gas Regulation.

Existing individual F Gas qualification certificates remain valid in accordance with the conditions under which they were originally issued.

NEW: Qualified technicians must also be given “information on relevant technologies to replace or to reduce the use of fluorinated greenhouse gases and their safe handling”. No further assessments are required, but all technicians should be aware of relevant information about the use of alternatives. It is expected that standard information will be prepared and then circulated via Certification Bodies.

Company Certification is required by all contractors carrying out installation and maintenance work. This applies to sole traders as well as limited companies. The process is unchanged from the 2006 Regulation. Defra has designated the Fire Industry Association (FIA) as the industry certification body who can issue a Company Certificate for FPS:

Fire Industry Association: Telephone: 0203 166 5002, email: info@fia.uk.com; website: www.fia.uk.com

See Information Sheet 23 for details of all FPS training and certification requirements.

5. Contractor responsibilities to minimise HFC emissions

Under the 2006 F-Gas Regulation the legal responsibilities related to F-Gas emissions from FPS equipment were held only by the system operator.

NEW: In the 2014 Regulation there is an explicit legal requirement for contractors to share this responsibility. Article 3 of the Regulation states that “The intentional release of F-Gases into the atmosphere shall be prohibited where the release is not technically necessary for the intended use.”

The Regulation then states that contractors “carrying out the installation, servicing, maintenance, repair or decommissioning of FPS equipment shall be certified and shall take precautionary measures to prevent leakage of F-Gases”.

This is an important new requirement about which contractors may need to inform a client, if they are being asked to do something that does not comply with the Regulation.

6. Contractor responsibilities during system installation

All contractor staff carrying out installation work related to HFC handling must hold the appropriate F-Gas competence certificate and must take precautionary measures to prevent leakage. Technicians carrying out unrelated installation activities, e.g. electrical work, do not need a competence qualification. However, anyone doing work that could affect the activation of the FPS and give rise to possible leakage must be qualified.

Product Labelling

All FPS products that contain F-Gases (including HFCs) shall not be placed on the market unless the F- Gases are identified with a label. The label shall indicate the following information:

  • 1) A reference that the FPS system contains F-Gases
  • 2) The accepted industry designation for the F-Gas concerned or, if no such designation is available, the chemical name
  • 3) NEW: From 1 January 2017, the quantity expressed in weight and in CO2 equivalent of F-Gas contained in the equipment, or the quantity in weight and the global warming potential of the gas

For most FPS equipment the label will be provided by the equipment manufacturer that fills the cylinders of fire extinguishing fluid – however, the contractor should always check that the system is properly labelled.

7. Contractor responsibilities during maintenance activities

The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance of existing FPS containing HFCs. The rules depend on the size of FPS being used. The regulations affecting existing equipment relate to (a) leak prevention and (b) record keeping. These requirements are described below.

Mandatory leak checks

Mandatory leak checks are required on all FPS equipment above certain size thresholds.

Under the 2006 F-Gas Regulation, the thresholds were set in terms of the physical quantity of refrigerant in the system – those containing more than 3 kg required a regular leak check. NEW: Under the 2014 Regulation the requirements are similar, but the size thresholds are defined in terms of tonnes CO2 equivalent. These new CO2 equivalent (CO2 e) size thresholds mean that the kg threshold for each HFC is different. HFCs with a high GWP (e.g. HFC 23) will have a lower size threshold than HFCs with a lower GWP (e.g. HFC 227ea). Table 2 shows leak testing requirements under both Regulations. Example thresholds are given for HFC 23 and HFC 227ea.

A comprehensive table of thresholds is given in Information Sheet 25.

Table 2: Size Thresholds for Mandatory Leak Checks

* Leak check frequency is halved if automatic leak detection system is installed

All stationary fire protection systems using HFCs contain considerably more than the lower threshold shown in Table 2, so they will all require a mandatory leak test regime. This is unlikely to impact the fire protection industry as there is already a strict 6 monthly maintenance regime for most systems. The Regulation recognises that most fire protection systems have regular maintenance and leak checks. The leak checking obligations shall be considered to be fulfilled provided the following two conditions are met:

  • the existing inspection regime meets ISO 14520 or EN 15004 standards; and
  • the fire protection equipment is inspected as often as shown in Table 2

If a leak is found during a mandatory leak check it must be repaired without undue delay and the leak test repeated within one month to ensure the repair was effective.

Mandatory automatic leak detection

NEW: For all fire protection systems containing 500 tonnes CO2e or more there is a mandatory requirement for an automatic leak detection system to be fitted. This is a continuation of a similar requirement in the 2006 Regulation, although the size threshold is changed from 300 kg to 500 tonnes CO2e. This will have an impact on systems using high GWP fire extinguishing fluids. As shown in Table 2, for HFC 227ea systems the new threshold for automatic leak detection systems is reduced from 300 kg to 155 kg. For HFC 23 systems the threshold for automatic leak detection is even lower – at just 34 kg. This rule applies from 1st January 2015. Most systems are provided with an automatic leak detection facility as standard.

An automatic leak detection system is defined as a “calibrated mechanical, electrical or electronic device for detecting leakage of F-Gases which, on detection, alerts the operator or a service company of any leakage”.

Automatic leak detection systems must be tested at least once every 12 months to ensure their proper functioning.

Record keeping

Operators of fire protection systems must keep records for each piece of equipment that is subject to a mandatory leak check (i.e. above the 5 tonnes CO2e threshold). The records that must be kept are similar to those required under the 2006 Regulation:

  • a)  quantity and type of F-Gas installed
  • b)  quantities of F-Gas added during installation, maintenance or when repairing a leak
  • c)  NEW: whether the F-Gases used have been recycled or reclaimed (including the name and address of the recycling or reclamation facility and, where applicable, the certificate number).
  • d)  quantity of any F-Gases recovered
  • e)  the identity of the undertaking that installed, serviced or decommissioned the equipment, including, where applicable, their certificate number
  • f)  dates and results of all mandatory leak checks
  • g)  NEW: if the equipment was decommissioned, the measures taken to recover and dispose of the F-Gases.

NEW: Records must be kept by the “operator” for at least 5 years. Where a contractor prepares records for the operator, the records should also be kept by the contractor for at least 5 years. The records shall be made available on request to the UK Government’s competent authority (i.e. the Environment Agency) or to the Commission.

8. Purchase of bulk HFCs

HFCs shall only be sold to and purchased by certified undertakings. This means that HFC suppliers will require evidence that contractors are certified or qualified to make the purchase. You should contact your suppliers to confirm what new requirements they plan to introduce – it is likely to be evidence based on your Company F-Gas Certificate.

9. Contractor responsibilities for systems at end-of-life

Any fire protection systems containing HFCs that is being disposed of at end-of-life must undergo an HFC recovery process. Recovery must be carried out by a certificated technician.

All recovered F-Gases can either be:

  • a)  given a basic cleaning process, to create “recycled HFC”.
  • b)  sent to a specialist facility that can re-process the old HFC into a fluid with properties identical to virgin HFC, to create “reclaimed HFC”
  • c)  sent for destruction by incineration at a licenced waste facility

Given the HFC supply shortage that will be created by the phase down process, it is worth trying to send the old HFC for reclamation as it may have a good residual value. If the old HFC is too contaminated it cannot be reclaimed and must be sent for destruction. It is important not to mix different gases in the same recovery cylinder – as this would render them unsuitable for reclamation. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com 

 

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EU F-Gas Regulation Guidance Information Sheet 14: Refrigeration, Air-Conditioning and Heat Pump Contractors

This information sheet is aimed at contractors that carry out installation, maintenance and decommissioning work on refrigeration, air-conditioning and heat pump systems (RACHP). It is also useful for operators of RACHP systems that use 3rd party contractors to maintain their plant. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6.

Contractors play a major role supporting operators of refrigeration, air-conditioning and heat pump (RACHP) equipment. They have to comply with a number of requirements under the F-Gas Regulation. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

The F-Gas Regulation is an important piece of legislation that will result in significant reductions in the emissions of F-Gases. These are very powerful greenhouse gases, with global warming impacts that are several thousand times higher than CO2 (per kg of gas emitted). All EU Member States agree that it is important to reduce emissions of these gases.

This Information Sheet describes the requirements that apply to RACHP contractors. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms. 

2. Sector description

The RACHP sector covers a wide range of equipment and end users, ranging from small domestic and commercial systems to large industrial plant. Key sectors of the RACHP market include

  • Domestic refrigeration
  • Commercial refrigeration
  • Industrial refrigeration
  • Transport refrigeration
  • Stationary air-conditioning and heat pumps
  • Mobile air-conditioning

Detailed guidance on the impact of the 2014 F-Gas Regulation on each of these sectors is available in Information Sheets 1 to 6.

Most operators of RACHP equipment in these sectors make use of specialist contractors for installation and maintenance work. There are over 5,000 RACHP contractors in the UK, ranging from large companies with UK-wide capability to very small businesses working in a small geographic area. The skill and expertise of the RACHP contracting industry is crucial, providing operators with various services through the life cycle of RACHP equipment.

The F-Gas Regulation places legally binding obligations on contractors to ensure that they help end users minimise the use and emissions of high GWP refrigerants. It is important that contractors comply with the Regulations that apply to them and also that they are aware of other relevant parts of the F-Gas Regulation so that they can provide their clients with appropriate advice.

3. Advice regarding purchase of new equipment

Contractors often provide important advice to their clients about purchase of new equipment. In the 2014 F-Gas Regulation there are 3 important new requirements that will change the advice that contractors give to their clients. These are:

  • a)  Various specific bans, that will require lower GWP refrigerants to be used
  • b)  The impact of the HFC phase down, that will encourage use of low GWP refrigerants
  • c)  The impact of the service ban, which affects the purchase of new systems using high GWP refrigerants such as HFC 404A

NEW: HFC Bans

The 2014 Regulation includes a number of HFC bans as summarised in Table 1. Contractors should be aware that these bans “do not tell the full story”. You must make clients aware of the phase down and the service ban (see below) – these also have a significant influence on selecting new plant.

NEW: Impact of the Service Ban on purchase of new equipment

Purchasers of new commercial and industrial refrigeration equipment must be aware that a “Service Ban” will affect certain existing systems using HFCs with a GWP above 2,500 from 2020. The ban applies to systems containing more than 40 tonnes CO2 equivalent (10 kg for HFC 404A). To avoid future problems you should advise clients purchasing plants above this size threshold to select only refrigerants with a GWP below 2,500, with immediate effect. The service ban is discussed in more detail in Section 7, below.

NEW: Impact of the HFC Phase Down on the purchase of new equipment

When purchasing new RACHP equipment your clients should also consider the HFC phase down. This will reduce the quantity of HFCs that can be sold in the EU – by 2030 there will be an 80% cut in HFC supply. Equipment bought now will still be operating when deep cuts in HFC supply are in force. Irrespective of the bans described above, it makes sense to always purchase equipment using refrigerants with the lowest practical GWP to minimise the future impact of the phase down.

Table 1: Bans affecting RACHP Equipment

4 All start dates are January 1st of year specified
5 This ban includes both refrigerant and foam blowing agent
6 This ban includes both refrigerant and foam blowing agent
7 Exemption for equipment cooling products below -50oC
8 The primary circuit of cascade systems can use an HFC with a GWP up to 1,500 

4. Contractor training and certification requirements

All refrigerant handling operations on RACHP equipment containing HFC refrigerants must be carried out by suitably trained technicians holding an F-Gas handling certificate and working for an F-Gas certificated company. This includes plant installation, leak testing, refrigerant recovery, maintenance and end-of-life decommissioning. The training and certification requirements are based on those already specified in the 2006 F-Gas Regulation.

Existing individual F Gas qualification certificates remain valid in accordance with the conditions under which they were originally issued. This means that those who hold certificates with an expiry date (CITB J11-J14) will need to be re-assessed and an updated assessment is now available.

NEW: The certification requirements have been extended to include technicians working on refrigerated trucks (>3.5 tonnes) and refrigerated trailers.

NEW: Qualified technicians must also be given “information on relevant technologies to replace or to reduce the use of fluorinated green house gases and their safe handling”. No further assessments are required, but all technicians should be aware of relevant information about the use of alternatives. It is expected that standard information will be prepared and then circulated via Certification Bodies.

Company Certification is required by all contractors carrying out installation and maintenance work. This applies to sole traders as well as limited companies. The process is unchanged from the 2006 Regulation. Defra has designated three bodies that can issue an RACHP Company Certificate: Refcom, Bureau Veritas and Quidos.

See Information Sheet 21 for details of all RACHP training and certification requirements.

5. Contractor responsibilities to minimise refrigerant emissions

Under the 2006 F-Gas Regulation the legal responsibilities related to F-Gas emissions from RACHP equipment were held only by the plant operator (usually the owner).

NEW: In the 2014 Regulation there is an explicit legal requirement for contractors to share this responsibility. Article 3 of the Regulation states that “The intentional release of F-Gases into the atmosphere shall be prohibited where the release is not technically necessary for the intended use.”

The Regulation then states that contractors “carrying out the installation, servicing, maintenance, repair or decommissioning of RACHP equipment shall be certified and shall take precautionary measures to prevent leakage of F-Gases”.

This is an important new requirement about which contractors may need to inform a client, if they are being asked to do something that does not comply with the Regulation.

6. Contractor responsibilities during plant installation

All contractor staff carrying out installation work related to refrigerant handling must hold the appropriate F-Gas handling certificate and must make precautionary measures to prevent leakage. Engineers carrying out unrelated installation activities (e.g. electrical work) do not need a refrigerant handling qualification. However, anyone doing work that could affect the refrigerant circuit and give rise to possible leakage must be qualified – e.g. an engineer setting a high pressure cut-out device should be qualified – if this was set incorrectly it could give rise to a leak.

Product Labelling

All RACHP products that contain F-Gases (including HFCs) shall not be placed on the market unless the F-Gases are identified with a label. The label shall indicate the following information:

  • 1)  A reference that the RACHP system contains F-Gases 
  • 2)  The accepted industry designation for the F-Gas concerned or, if no such designation is available, the chemical name
  • 3)  NEW: From 1 January 2017, the quantity expressed in weight and in CO2 equivalent of F-Gas contained in the equipment, and the global warming potential of the gas
  • 4)  If applicable, a reference that the F-Gases are contained in hermetically sealed equipment

For some pre-charged RACHP equipment the label will be provided by the equipment manufacturer. However, for all RACHP systems that are filled or topped up with refrigerant during installation, it is the responsibility of the installation contractor to ensure that a suitable label is attached, stating the total amount of refrigerant in the system.

7. Contractor responsibilities during maintenance activities

The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance of existing industrial refrigeration equipment containing HFC refrigerants. The rules depend on the type and size of industrial refrigeration equipment being used. The regulations affecting existing equipment relate to (a) leak prevention, (b) record keeping and (c) the Service Ban. These requirements are described below.

Mandatory leak checks

Mandatory leak checks are required on all RACHP equipment above certain size thresholds.

Under the 2006 F-Gas Regulation, the thresholds were set in terms of the physical quantity of refrigerant in the system – those containing more than 3 kg required a regular leak check. NEW: Under the 2014 Regulation the requirements are similar, but the size thresholds are defined in terms of tonnes CO2 equivalent. These new CO2 equivalent (CO2 e) size thresholds mean that the kg threshold for each refrigerant is different. Refrigerants with a high GWP (e.g. HFC 404A) will have a lower size threshold than refrigerants with a lower GWP (e.g. HFC 134a). Table 2 shows leak testing requirements under both Regulations. Example thresholds are given for HFC 404A and HFC 134a.

A comprehensive table of thresholds is given in Information Sheet 25.

The new CO2e thresholds will require some systems below the old 3 kg threshold to be regularly leak tested. As shown in Table 2, the size threshold for HFC 404A is only 1.3 kg. Contractors should check which of the systems they maintain are affected by the new CO2e size thresholds. Most of the leak checking rules apply from 1st January 2015, continuing the similar requirement in the 2006 Regulation. For systems with less than 3 kg, the 5 tonnes CO2e threshold only applies from 1st January 2017.

Table 2: Size Thresholds for Mandatory Leak Checks

* Leak check frequency is halved if automatic leak detection system is installed
** The threshold for annual leak checks of hermetically sealed equipment is 10 tonnes CO2e

If a leak is found during a mandatory leak check it must be repaired without undue delay and the leak test repeated within one month to ensure the repair was effective.

Mandatory automatic leak detection

For all RACHP systems containing over 500 tonnes CO2e there is a mandatory requirement for an automatic leak detection system to be fitted. An automatic leak detection system is defined as a “calibrated mechanical, electrical or electronic device for detecting leakage of F-Gases which, on detection, alerts the operator or a service company of any leakage”.

NEW: Mandatory automatic leak detection is a continuation of a similar requirement in the 2006 Regulation, although the size threshold is changed from 300 kg to 500 tonnes CO2e. This will have a significant impact on plants using high GWP refrigerants. For HFC 404A systems the new threshold for automatic leak detection systems is reduced from 300 kg to 127 kg.

This rule applies from 1st January 2015. The lower size threshold for HFC 404A will affect many large refrigeration systems as they often contain more than 127 kg. Table 3 shows the size threshold for automatic leak detection for a number of refrigerants used in RACHP systems. For most refrigerants, the new size threshold is lower than the 300 kg threshold in the 2006 Regulation.

Automatic leak detection systems must be tested every 12 months to ensure their proper functioning.

Table 3: Size Thresholds for Automatic Leak detection and the Service Ban

* Note: the service ban only applies to refrigerants with a GWP above 2 500 

Record keeping

Operators must ensure records are kept for each piece of equipment that is subject to a mandatory leak check (i.e. above the 5 tonnes CO2e threshold). The records are similar to those required under the 2006 Regulation:

  • a)  quantity and type of F-Gas installed
  • b)  quantities of F-Gas added during installation, maintenance or when repairing a leak
  • c)  NEW: whether the F-Gases used have been recycled or reclaimed (including the name and address of the recycling or reclamation facility and, where applicable, the certificate number).
  • d)  quantity of any F-Gases recovered
  • e)  the identity of the undertaking that installed, serviced or decommissioned the equipment, including, where applicable, their certificate number
  • f)  dates and results of all mandatory leak checks
  • g)  NEW: if the equipment was decommissioned, the measures taken to recover and dispose of the F-Gases.

NEW: Records must be kept by the plant operator for at least 5 years. Where a contractor prepares records for the operator, the records should also be kept by the contractor for at least 5 years. The records shall be made available on request to the UK Government’s competent authority (i.e. the Environment Agency) or to the Commission.

NEW: Service Ban

An important new feature of the 2014 F-Gas Regulation is the Service Ban:

  • From 1st January 2020 the use of F-Gases with a GWP above 2,500 to maintain refrigeration systems with a charge size of 40 tonnes CO2e or more shall be prohibited.

In the refrigeration sector this will mostly affect systems that use HFC 404A. The size threshold of 40 tonnes CO2e is equivalent to 10 kg of HFC 404A. The size thresholds for various other refrigerants are given in Table 3.

It is important to note that several refrigerants used as “drop-in” replacements for R22 have a GWP above 2,500 and are affected by the Service Ban. Some of these are listed in Table 3 (e.g. HFC 434A, HFC 422D).

It will be legal to continue operating systems affected by the Service Ban, but you will not be allowed to top up any leaks with virgin refrigerant. Contractors should advise operators of equipment affected by the Service Ban that they have 3 main options:

  • a)  They can replace the plant with new equipment using a refrigerant with a lower GWP. This is a good option for plants close to end-of-life.
  • b)  They can “retrofill” the plant, replacing the refrigerant with a lower GWP alternative (for HFC 404A you can use alternatives such as HFC 407A, HFC 407F, HFC 448A and HFC 449A for most applications). This option is a good one for younger equipment. There is good evidence that retrofilling HFC 404A with one of these refrigerants will improve energy efficiency by between 5% and 10% - this creates a good financial case for retrofill.
  • c)  You can use reclaimed or recycled refrigerant for plant maintenance until 1st January 2030.

8. Purchase of bulk refrigerant and pre-charged systems

NEW: HFC refrigerants shall only be sold to and purchased by certified undertakings or undertakings that employ certificated personnel. This means that refrigerant suppliers will require evidence that contractors are certified or qualified to make the purchase. You should contact your refrigerant suppliers to confirm what new requirements they plan to introduce – it is likely to be evidence based on your Company F-Gas Certificate.

NEW: Non-hermetically sealed equipment pre-charged with HFCs (e.g. split system air-conditioning units) can only be sold to end-users where evidence is provided that the installation will be properly carried out by a suitably qualified contractor.

9. Contractor responsibilities for plants at end-of-life

Any RACHP equipment containing HFCs in either the refrigeration circuit or the insulation foam that is being disposed of at end-of-life must undergo an HFC recovery process.

All refrigerant must be recovered by a certificated technician before the plant is dismantled. Modern refrigerant recovery machines should be able to remove well over 95% of the refrigerant in an old system. Any insulating foam associated with these refrigeration systems (e.g. PU foam used for pipe / vessel insulation or in cold store panels) should be sent to a specialist recovery facility, where the foam can be crushed and the HFCs recovered.

All recovered F-Gases can either be:

  • a)  sent for destruction by incineration at a licenced waste facility
  • b)  sent to a specialist plant that can re-process the old refrigerant into a gas with properties identical to virgin refrigerant, to create “reclaimed refrigerant”
  • c)  given a basic cleaning process, to create “recycled refrigerant”.

Given the HFC supply shortage that will be created by the phase down process, it is worth trying to send the old refrigerant for reclamation as it may have a good residual value. If the old refrigerant is too contaminated it cannot be reclaimed and must be sent for destruction. It is important not to mix different gases in the same recovery cylinder – as this would render them unsuitable for reclamation.

Reclaimed refrigerant may be used in any refrigeration equipment, by any qualified person. Recycled refrigerant must always be used with care as it may be contaminated or of unknown composition. The use of recycled refrigerant with a GWP above 2,500 is restricted to either (a) the organisation owning the plant from which the gas was recovered or (b) the organisation that carried out the recovery. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com 

 

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EU F-Gas Regulation Guidance Information Sheet 29: Low GWP Alternatives

This information sheet is aimed at organisations that may be affected by the 2014 EU F-Gas Regulation. This includes end users, maintenance contractors and equipment manufacturers. It is also of relevance to F-Gas producers, importers and exporters. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

The 2014 F-Gas Regulation includes a significant phase down in the supply of HFCs to the EU market – by 2030 there will be a 79% cut in supply. The phase down will force end-users of HFCs to find alternatives that have a much lower global warming impact. This Information Sheet provides guidance for HFC users about the use of low global warming potential (GWP) alternatives. In Sections 2 to 5 we provide general background to the selection of low GWP alternatives and in Sections 6 to 17 we give specific details for different market sectors. 

A wide range of further guidance is available for other aspects of the EU F-Gas Regulation – see Information Sheet 30 for a full list and a glossary of terms.

2. GWPs of HFCs in current use

The global warming potential (GWP) of a fluid is a measure of its contribution to global warming compared to the most common greenhouse gas, carbon dioxide (CO2). The GWP values used in the 2014 F-Gas Regulation are based on the UN IPCC’s 4th Assessment Report, as listed in Annex I of the Regulation. The GWP of CO2 is 1. The GWPs of common HFCs in current use are between 750 and 4,000. The most widely used HFCs in 2012 are shown in Table 1. It is the very high GWPs shown in Table 1 that make HFCs so potentially damaging to the environment.

The HFC phase down is based on “GWP-weighted” amounts of HFCs. It is interesting to note that the average GWP of all the HFCs used in 2012 was approximately 2,000. To achieve a 79% reduction in GWP-weighted sales over the next 15 years, the average GWP of HFCs and their alternatives sold in 2030 will need to fall to around 400. This will be achieved by:

  • a)  Using non-HFC alternatives with ultra-low GWPs that are not part of the HFC phase down
  • b)  Using new HFC products with much lower GWPs than those currently used. 

Table 1: GWPs of HFCs widely used in the EU, 2012 

3. Why are HFCs so widely used?

It is useful to note that HFCs are in widespread use because they have a number of properties that are well suited to their end use applications. In particular, the fact that the commonly used HFCs are non- flammable and non-toxic makes them easy to use.

It is important to recognise that the physical properties required vary because the range of end uses is so broad. HFCs are used for many applications including refrigerants, foam blowing agents, aerosol propellants and solvents. HFCs are well suited to this wide range of end user requirements as they form a large family of fluids providing a wide range of different physical properties.

4. Fluid properties that affect selection of alternatives

The process of selecting an alternative fluid is complex and must take into account many different properties. Some of the most important are:

  • a)  Basic suitability to the relevant application (e.g. as a refrigerant, foam blowing agent etc.)
  • b)  Impact on energy efficiency (especially for refrigerants and foam blowing agents)
  • c)  Flammability
  • d)  Toxicity
  • e)  Suitable operating pressure
  • f)  Good materials compatibility (e.g. with metals, flexible seals, lubricants)
  • g)  Reasonable cost.

As a general rule, HFCs used in current applications have a better set of properties than the available alternatives – if the alternatives were better, then market forces would lead to their adoption. This is illustrated by the fact that in some markets there has already been widespread voluntary uptake of low-GWP alternatives where there has been a good commercial driver (e.g. hydrocarbons used in domestic refrigerators, in aerosols for personal / domestic products and in certain types of polyurethane foam).

The HFC phase down will force a move to lower GWP alternatives. In many cases end users will need to adapt to the use a fluid with slightly less favourable properties (e.g. use of a flammable fluid in place of a non-flammable HFC). It is expected that, for particular uses, these difficulties will be overcome as the fluid and equipment suppliers develop new products and codes for their safe operation. It is likely that HFCs will get more expensive as the phase down restricts supply – this will create a better commercial case to use alternatives, which currently may be more expensive to use. 

5. Overview of Available Alternatives

Table 2 summarises some of the alternatives under consideration in 2014. The GWP bands used in Table 2 are somewhat arbitrary, but show the GWP options available. It is worth noting that there are no alternatives currently being proposed with GWPs in the 10 to 140 range.

Ideally there should be maximum use of ultra-low GWP alternatives. There are a number of such fluids available as shown in Table 2, although they all have safety and practicality issues. Ammonia, hydrocarbons (HCs) and CO2 have all been available for many years and are increasing in market share in some applications.

HFOs (hydro-fluoro-olefins) are newly introduced fluids. Like HFCs they consist of carbon, fluorine and hydrogen. A key difference is that they are unsaturated molecules – this means they have a double bond between 2 carbon atoms. This gives them much lower GWPs than HFCs. However, most HFOs have a small degree of flammability (referred to as “mildly flammable”) which makes them more difficult to use than non-flammable HFCs. HFOs were first introduced for commercial use in around 2013 and there should be growing commercial availability from 2015.

A number of HFO/HFC blends are also under development. These are being formulated to provide properties similar to current HFCs but with much lower GWPs. Mildly flammable HFO/HFC blends are available with GWPs between around 140 and 700. To create non-flammable blends the GWPs are higher, in the 600 to 1,400 range.

Table 2: Examples of Low GWP HFC Alternatives 

6. Energy Efficiency is Crucial

When purchasing a new refrigeration, air-conditioning or heat pump system or when selecting a suitable insulation foam it is important to maximise the energy efficiency. During the life cycle of products of this sort it is the energy related CO2 emissions that dominate the overall greenhouse gas emissions. It is counter-productive, from an environmental perspective, to use an ultra-low GWP alternative but have to sacrifice energy efficiency. Always try to ensure that the low GWP alternative that you select has equal (or preferably better) energy efficiency to the best high GWP option available on the market.

7. Domestic Refrigeration – Low GWP Alternatives

After the phase out of CFCs in 1995 the domestic refrigeration market used HFC 134a as the main alternative. However, from around 2000, hydrocarbons (HCs) were introduced and they are currently the dominant refrigerant in this market. With refrigerant charges of under 0.15 kg the flammability issues related to use of HCs have been overcome.

A small proportion of large refrigerators and freezers, particularly imported models, still use HFC 134a. Under the 2014 F-Gas Regulation the use of any HFC with a GWP above 150 will be banned in this market from January 2015. Two alternatives are likely to be used:

  • a)  Where possible, HCs will be used as these are well established in this market.
  • b)  If flammability issues are especially important (e.g. a very large refrigerator with a charge above 0.15 kg) then HFOs may be adopted.

8. Commercial Refrigeration – Low GWP Alternatives

The commercial refrigeration market makes use of 3 main types of system:

  • a)  Small hermetically sealed systems (refrigerant charge typically 0.1 to 0.5 kg)
  • b)  Condensing units (split systems with refrigerant charge typically 2 to 10 kg)
  • c)  Central pack systems (large systems with refrigerant charge typically 50 to 150 kg)

It is also important to note that this market uses 2 distinct temperature levels for chilled and for frozen products – that can affect the best refrigerant selection.

Small Hermetic Systems

Where the refrigerant charge is below 0.15 kg, HCs can be used – a number of commercial hermetic units are already available with propane refrigerant.

CO2 is an option for larger systems – it is already in use for some large bottle coolers.

It is likely that HFOs, including both 1234yf and 1234ze, will be used for commercial hermetic systems. The mild flammability of these refrigerants should not be an issue for such small systems.

Commercial Condensing Units

Currently many condensing units use HFC 404A – which has a very high GWP of 3,922. Use of HFC 404A in all new equipment should be avoided with immediate effect. 

As an interim, refrigerants such as HFC 407A or HFC 407F can be used in new condensing units for frozen applications. These have a GWP that is only half that of HFC 404A. For chilled foods, HFC 134a offers an even lower GWP.

Various much lower GWP options are becoming available from 2014. CO2 has been trialled in some convenience stores. HCs will not be suitable as the flammability risk is too high for such large refrigerant charges.

Some of the new HFO / HFC blends can be considered. For chill applications R450A has a GWP of 601 and is non-flammable. If a mildly flammable refrigerant is acceptable, then HFO 1234yf or 1234ze can be considered – these have GWPs below 10. For frozen food applications the non-flammable options (e.g. R448A and R449A) have GWPs just under 1400. Mildly flammable blends such as Opteon XL40 and Solstice L40 are under development – these have GWPs of under 300.

Commercial Central Pack Systems

Most central pack systems use HFC 404A – which has a very high GWP of 3,922. Use of HFC 404A in all new equipment should be avoided with immediate effect.

As an interim, refrigerants such as HFC 407A, HFC 407F, HFC 448A and HFC 449A can be used in new pack systems for frozen applications. These have a GWP that is only half that of HFC 404A. For chilled foods, HFC 134a offers an even lower GWP. However, there have already been significant developments of much lower GWP alternatives, so these interim options can be avoided.

There are now several hundred supermarket pack systems operating with CO2. This is likely to become a widely used refrigerant for all new central pack systems.

Some supermarkets are using small hermetic HC systems together with a chilled water system to remove the condenser heat from each hermetic system. As the HC charge of each system can be very small, the flammability risk is manageable.

It is likely that mildly flammable HFOs and HFO/HFC blends will also be considered for central pack systems in the future.

9. Industrial Refrigeration – Low GWP Alternatives

The industrial refrigeration market is especially broad in scope, both in terms of system size and the temperature level required. Three main types of equipment are used:

  • a)  Large central systems serving several major loads e.g. used for blast freezing and large cold stores. These systems often contain several tonnes of refrigerant.
  • b)  Large chiller systems, cooling a secondary refrigerant such as glycol which is distributed to a number of loads. Chillers often contain several hundred kg of refrigerant.
  • c)  Smaller dedicated plants, each serving a single cooling load. These usually contain less than 100 kg of refrigerant.

The majority of industrial plants operate at similar temperature levels to commercial systems e.g. to produce chilled or frozen food products. However, some industrial plants operate at much lower temperatures than commercial systems e.g. well below -100oC. 

Large Central Industrial Systems

Large central systems are well suited to ultra-low GWP systems. Ammonia is already widely used, especially in food manufacturing, breweries and cold stores. All purchasers of large industrial plant with an evaporating temperature above -500C should strongly consider using ammonia.

CO2 is also an interesting candidate for industrial systems, especially if heat recovery (e.g. for producing process hot water) is a useful secondary objective.

Large central systems below -50oC are more problematic as ammonia and CO2 are unsuitable below this temperature. It may be necessary to use an HFC in cascade with ammonia. The very low temperatures required to produce liquid oxygen and liquid nitrogen (around -200oC) are created using a very sophisticated form of air cycle refrigeration system.

Large Industrial Chiller Systems

Industrial chillers are also well suited to ultra-low GWP refrigerants. Ammonia is already widely used (e.g. in breweries). New HFO refrigerants including HFO 1234ze and HFO 1233zd will become available for large centrifugal chillers.

Small Dedicated Industrial Systems

These will be the most problematic type of equipment to find a suitable ultra-low GWP refrigerant. Most existing plants in this category use HFCs such as HFC 404A, HFC 407C and HFC 134a.

It is worth considering ammonia, although many plants in this category are too small to make ammonia cost effective. CO2 is also an important new option – relatively small CO2 plants are being used in supermarkets and this technology may be transferable to industry.

As with commercial refrigeration systems, a key question is whether mild flammability is an issue. In many industrial plants flammability can be managed, by careful compliance with well-established safe codes of practice for design, maintenance and operation.

If mild flammability is acceptable then a range of pure HFO or HFO / HFC blends may be applicable. HFOs 1234yf and 1234ze have properties similar to HFC 134a and have ultra-low GWP (4 and 7 respectively). These could be suitable for medium temperature and high temperature systems (e.g. with evaporating temperatures above -10oC. Some new mildly flammable HFO / HFC blends are being developed with properties similar to HFC 404A, with GWPs below 300 (e.g. XL40 and L40). These could be suitable for lower temperature applications, down to around -50oC.

If a non-flammable refrigerant is required then CO2 is the only ultra-low GWP option. For medium and high temperature applications HFO/HFC blends such as R450A and R513A may be suitable – these have GWPs around 600. For lower temperatures it may be necessary to use blends such as R448A and R449A – these have GWPs around 1400.

As discussed above for large central systems, very low temperature plants (below -50oC) are more difficult and may require use of an HFC.

10. Transport Refrigeration – Low GWP Alternatives

Most refrigerated trucks and trailers and refrigerated containers use HFC 404A. They require a non- flammable refrigerant (e.g. due to rules travelling through certain tunnels) and the flexibility to provide chilled or frozen temperature levels. There are rigorous testing rules (through ATP 

Regulations) that make development of systems with new refrigerants more difficult in this sector than some other refrigeration sectors.

CO2 is being trialled by some equipment manufacturers and may become the dominant replacement for HFC 404A. Currently, various other non-flammable options are being considered including R452A (GWP 2,140), R448A and R449A (GWPs around 1,400) and R407F (GWP 1,825).

For smaller systems (e.g. in delivery vans) a mildly flammable option may be acceptable. Pure HFOs and blends such as DR7and L40 (GWP below 300) are being trialled. Non-flammable options such as R407F are also being trialled.

11. DX Air-Conditioning – Low GWP Alternatives

DX (direct expansion) air-conditioning includes:

  • a)  Small single splits, typically with refrigerant charge in the 1 kg to 3 kg range
  • b)  Larger single and multi-splits with refrigerant charge in the 4 kg to 15 kg range
  • c)  VRV systems with refrigerant charge in the 15 kg to 30 kg range
  • d)  Packaged roof-top systems with refrigerant charge in the 15 kg to 30 kg range

Currently HFC 410A (GWP 2,088) is the dominant refrigerant for all these categories. Older systems often used HFC 407C.

Hydrocarbons have been proposed for small splits, although the flammability risk is considerable. HCs may be acceptable for very small splits (e.g. with a refrigerant charge below 1 kg) but are unlikely to be considered safe for larger charges.

CO2 has also been trialled, but it is very difficult to achieve high enough energy efficiency, especially as air-conditioning equipment needs to run in hot weather, when CO2 is least efficient.

Pure HFOs are possible where mild flammability is acceptable, although systems would require a much bigger compressor than those used with HFC 410A, which could add a significant extra cost.

A good candidate for a mildly flammable refrigerant is HFC 32 (GWP 675). This is already in widespread use in the Far East and was being sold commercially in Europe in 2014. HFC 32 systems have the potential to be more energy efficient than HFC 410A. For small splits a mildly flammable refrigerant will be acceptable in many circumstances. However, for larger systems (e.g. VRV) there is much work to be done to prove the safety of refrigerants like HFC 32 and also safety codes may need to be updated. Other mildly flammable options are becoming available including R447A (GWP 582). Wherever mildly flammable gases are used, all relevant safety codes must be followed.

If a non-flammable refrigerant is required there are no easy choices at present. HFO blends with properties similar to HFC 134a are available with a GWP around 600, but these may not produce the same energy efficiency as HFC 410A.

12. Air-Conditioning Chillers – Low GWP Alternatives

Currently most small chillers use HFC 410A and large chillers use HFC 134a. Air-conditioning chillers are usually located in a plant room or in an enclosure that is out of doors, hence in most situations a mildly flammable refrigerant will be acceptable (note, this may not be the case in certain basement locations). 

HFO 1234ze is being trialled in a range of chiller sizes and could become an ultra-low GWP option for most chillers. Also, HFO 1233zd is being considered for large chillers – it is a low pressure refrigerant and can be very energy efficient. For small chillers HFC 32 or HFC 447A may be considered.

13. Mobile Air-Conditioning – Low GWP Alternatives

HFC 134a is the refrigerant used worldwide for MACs in cars and other small vehicles. Other refrigerants such as HFC 410A may be used in larger systems in buses and trains.

For small MACs it is likely that HFO 1234yf will become the dominant refrigerant. It is mildly flammable, but most car manufacturers have been satisfied by the safety trials and are launching models with HFO 1234yf.

HFO 1234yf will also be acceptable for some larger systems. However, if a non-flammable refrigerant is required there are no obvious alternatives to HFC 410A. See comments above for larger DX stationary air-conditioning.

14. Technical Aerosols – Low GWP Alternatives

Under the 2006 Regulation the use of HFCs in two categories of aerosol was banned. For one component foam most of the market switched to flammable propellants (such as hydrocarbons) as it was shown that they were safe to use. For novelty aerosols most of the market switched to HFO 1234ze, as a non-flammable propellant was required.

Most technical aerosols use HFC 134a as a propellant. HFO 1234ze looks to be a suitable candidate for most applications.

15. Foams – Low GWP Alternatives

Extruded polystyrene foam (XPS) is currently manufactured using either HFC 134a or CO2. For some types of XPS foam CO2 is not considered suitable. HFO 1234ze has been successfully trialled for XPS and in 2014 was in commercial production in some premium foam products.

Polyurethane foam (PU) and similar foams (polyisocyanurate and phenolic) are manufactured using hydrocarbons (if a highly flammable blowing agent is acceptable) or HFC 365mfc or HFC 245fa. The use of a number of new ultra-low GWP HFOs (1233zd, 1336mzz and 1233xf) is being trialled.

16. Fire Protection – Low GWP Alternatives

In the UK HFC 227ea is the dominant HFC in current use. A fluoro-ketone (FK 5-1-12) with ultra-low GWP has been available for some years and can be used in many applications that might consider HFC 227ea.

17. Solvents – Low GWP Alternatives

HFC 4310mee and HFC 365mfc have had some minor use as solvents, although their market is not widespread. New HFO products, including HFO 1233zd are undergoing promising trials. 

18. Low GWP Alternatives – Summary of Market Sector Trends 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com

 

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EU F-Gas Regulation Guidance Information Sheet 28: The HFC Phase Down Process

This information sheet is aimed at all organisations that may be affected by the phase down of HFC supply that is defined in the 2014 EU F-Gas Regulation. This includes end users, maintenance contractors and equipment manufacturers. It is also of relevance to F-Gas producers, importers and exporters. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures.

A crucial aspect of the 2014 Regulation is the introduction of the phase down in the supply of HFCs within the EU market. This Information Sheet provides guidance on how the phase down process will occur and the impact that this will have on the current market for HFCs. 

A wide range of further guidance is available for other aspects of the EU F-Gas Regulation – see Information Sheet 30 for a full list and a glossary of terms.

2. Why an HFC Phase Down?

HFCs are used in a range of applications such as refrigeration, air-conditioning, heat pumps, foam insulation and aerosols. HFCs are very powerful greenhouse gases – the most commonly used HFCs have a global warming potential (GWP) between 1,000 and 4,000 times higher than CO2.

The HFC phase down is being introduced to drive the market towards use of lower GWP alternatives. Many lower GWP alternatives already exist and are “near market” but they are not in widespread use in current HFC markets. The phase down will force technology change and make a substantial contribution towards lower greenhouse gas emissions.

The proposed phase down will lead to a 79% cut in current levels of HFC sales by 2030. This is a very significant cut and will only be achieved with widespread action from fluid suppliers, equipment and product manufacturers, installation and maintenance contractors and end users.

It is important to note that this is a phase down not a phase out. 21% of current sales can be placed on the market after 2030. This is because there are some end uses where there are currently no safe, cost-effective or environmentally beneficial alternatives to HFCs.

The phase down is based on a series of cuts in supply from a “baseline”. It is based on a “GWP- weighted” process, which will encourage the rapid phase down of the highest GWP HFCs. A quota system will be introduced to control sales in the EU market. 

3. HFC Baseline

The baseline for the HFC phase down process is the average consumption of HFCs on the EU market during the years 2009 to 2012. Under the 2006 EU F-Gas Regulation, all producers, importers and exporters of F-Gases had to report annual data for quantities of bulk HFCs. The baseline is calculated in terms of “CO2 equivalent”. The baseline amount is 183 million tonnes CO2 equivalent.

4. Phase Down Steps

The phase down starts in 2015 with a series of cuts from the baseline amount, as shown in Figure 1. 

It is worth noting:

  • The start of the process is fairly gentle, with 100% of baseline sales allowed in 2015 and a 7% cut in 2016 and 2017.
  • There is a “hidden step” in 2017 as all imported pre-charged equipment must use HFCs from the EU quota from 2017 onwards. Under business-as-usual this will add a further 11% to EU demand. This makes the cut in 2017 equivalent to 18%.
  • There is a very big cut in 2018. As shown in Figure 1, the cut is 37%. However, the pre-charged imports must be taken into account – this makes the cut equivalent to 48%. It is clear that HFC users are going to need to significantly reduce their demand by 2018 to avoid supply shortages. Early action is vital!
  • By 2024 the cut is nearly 70% and from 2030 onwards the cut is 79%. 

5. A GWP Weighted Process 

The annual quantities in the baseline and the phase down steps are based on “GWP tonnes”. This means the physical tonnage of each gas sold multiplied by its GWP (global warming potential). This is very important, as it will put most pressure on the refrigerants with the highest GWP. Table 1 illustrates the GWPs of a number of common HFCs.

Two commonly used HFCs are HFC 404A and HFC 134a. As shown in Table 1, these have GWPs of 3,922 and 1,430 respectively. HFC 404A has a very high GWP – it is 2.7 times higher than the GWP of HFC 134a. This means that selling 1 kg of HFC 404A will “use up” 2.7 times as much of the allowed HFC allocation as selling 1 kg of HFC 134a. 

It is reasonable to expect that the prices of HFCs will rise considerably as supplies become constrained. It is also reasonable to expect that this price rise will be GWP weighted – there will clearly be greatest phase down pressures on HFC 404A and HFC 507. 

Table 1: Example GWPs (based 100 year GWP values in Annex I of the 2014 F-Gas Regulation) 

The first 7 fluids in Table 1 are HFCs – these are all affected by the phase down. It is important to note that there are many other HFCs not shown in Table 1 also affected. The last 4 fluids in Table 1 are not affected by the phase down as they are not HFCs – they are included to illustrate some of the ultra- low GWP alternatives that are available.

6. An EU-Wide Process

It is important to be aware that the phase down process is for the whole EU. There is no guarantee that UK will get pro-rata share of the phase down amounts.

7. The Sales Quota System

The phase down process is being implemented via a sales quota system. Only companies with an HFC quota, received from the European Commission, will be allowed to produce HFCs or import them into the EU. Most of the quotas are being given to the companies that produced or imported HFCs during the baseline period (2009 to 2012). A small proportion (11%) is allocated to “new entrants”.

8. Imports of Pre-charged Equipment

From 2017 onwards, any refrigeration, air-conditioning or heat pump equipment imported into the EU that is pre-charged with HFCs, must use HFCs obtained from the EU quota. Importers will need to prove to the authorities that the equipment they import complies with this requirement.

Non-EU manufacturers will have the option of:

  • a)  Purchasing their required HFCs from an EU quota holder (the quota holder would deliver actual HFC fluids to the non-EU manufacturer)
  • b)  Obtain an authorisation from an EU quota holder to use a specified amount of their quota (the non-EU manufacturer will then be able to source the actual HFC fluid from a local supplier)

EU-based manufacturers of pre-charged equipment must also use HFCs from the EU quota. 

9. Exports of Bulk HFCs and Pre-charged Equipment

Exports of bulk HFCs are outside the EU quota mechanism. If a quota holder exports some of their product, it does not count as “placing on the EU market”. If a quota holder sells HFCs to a 3rd party who then exports the bulk gas, the quota holder can receive an “export credit” providing the exporter informs the quota holder about the amount exported.

Exports of pre-charged equipment are included within the quota system where the HFCs are purchased on the EU market. However, an equipment manufacture is allowed to import HFCs for filling into pre-charged equipment and subsequent re-export – this will be outside the quota mechanism if the correct customs processes are used.

10. Responding to the Phase Down

The phase down will clearly put pressure on manufacturers and users of HFC based products and equipment. To achieve the required cuts, users of HFCs will need to combine 4 strategies:

  • a) For existing refrigeration systems, consider the possibility of replacing high GWP refrigerant with a “medium GWP” HFC. For example, use HFC 407F in place of HFC 404A. This will create a 50% cut in GWP weighted demand. This is a realistic example as HFC 407F can often be “retrofilled” into existing HFC 404A equipment.
  • b) For existing systems, reduce the quantity of HFCs used by reducing leakage. A good leak reduction strategy can often reduce annual leak rates by at least 50%.
  • c) For new systems, carefully consider which HFCs to use. Very high GWP HFCs such as HFC 404A and HFC 507 should be avoided immediately – there are virtually no refrigeration applications that still need these high GWP refrigerants in new systems. If possible use one of the “ultra- low” GWP refrigerants in Table 1 (e.g. ammonia, CO2, HFO 1234yf) – these fall outside the scope of the phase down. If that is not possible, there are various new “moderate GWP” refrigerants that will come on the market over the next few years. These have GWPs in the 200 to 700 range (see Information Sheet 28 for further guidance).
  • d) For new systems, ensure a low leakage design. Spending a little extra on good quality components and design strategies that avoid problems like vibration of pipework can keep leakage to a minimum – this will be a good investment as the prices of HFCs rise in response to the phase down. 

This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs

This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.

To find out more about Gluckman Consulting visit www.gluckmanconsulting.com

 

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