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EU F-Gas Regulation Guidance Information Sheet 27: Flammability Issues

This information sheet is aimed at all organisations that need to consider using flammable or mildly flammable fluids in place of non-flammable HFCs. 

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 key feature of the 2014 F-Gas Regulation is the introduction of the phase down in the supply of HFCs within the EU market. This will lead to an 80% cut in the amount of HFCs that can be sold in the EU by 2030. To achieve such significant cuts, the users of HFCs will need to start using alternative fluids with much lower global warming potentials (GWPs) than the current HFCs. Many of the low GWP alternatives to HFCs are flammable – this creates potential safety issues and may restrict their usage. This Information Sheet provides guidance on the impact of using flammable HFC alternatives. 

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. Non-flammable HFCs

Most HFCs are non-flammable and this is a characteristic that made HFCs a popular choice for many end user applications. Key uses of non-flammable HFCs include:

  • Refrigeration, air-conditioning and heat pumps (RACHP)
  • Technical and medical aerosols
  • Insulation foam
  • Fire extinguishing fluids

The non-flammable property of most HFCs makes it relatively easy to manufacture, install and maintain equipment such as RACHP systems. If some non-flammable refrigerant leaks there will be no risk of fire. Similarly, an aerosol using a non-flammable HFC propellant may be safer to use in circumstances where there may be a source of ignition.

One of the reasons that most HFCs are non-flammable is that their molecular structure is very stable. Unfortunately, this property also gives HFCs a very long atmospheric life and a high GWP. Low GWP alternatives usually have less stable molecules – this is good from a GWP perspective, but it results in many alternatives being flammable. 

3. Flammability is not a simple issue

If there are plenty of non-flammable options available it is easy to apply a simplistic approach to flammability: if a flammable fluid is undesirable, safety codes take a conservative view and state that flammable fluids cannot be used.

This simplistic approach is not ideal when there are fewer non-flammable fluids to choose from. To make more widespread use of low GWP alternatives, it is important to recognise that there are widely varying “levels of flammability”. There is a continuous spectrum of flammability which includes:

  • Highly flammable fluids – these are very easy to ignite and can burn with explosive impacts. The most common examples are hydrocarbons (HCs) such as propane and butane. These have very useful properties for use as refrigerants, aerosol propellants and foam blowing agents. However, they are also used as fuels and they can be ignited very easily.
  • Flammable fluids – they are more difficult to ignite, but once ignited will continue to burn and could create a significant hazard.
  • Mildly flammable fluids – these are very difficult to ignite, they burn “gently” and might be extinguished when the source of ignition is removed. Mildly flammable fluids create a smaller fire risk than an equivalent amount of a more flammable fluid.
  • Non-flammable fluids – these cannot be ignited.

Existing safety codes do not properly distinguish between different levels of flammability. For example EN 378 2008 (“Refrigerating systems, safety and environmental requirements”) only has 3 categories of flammability which are based on a simplified set of flammability parameters. EN 378 is currently being updated to include a 4th flammability category, although that may still prove to be an over- simplification that restricts the use of mildly flammable fluids.

A problem faced by both the authors of safety codes and users of flammable fluids is that flammability is a complex issue and it is not easy to find a simple way of defining a safe operating envelope for each fluid. Flammability can be measured in a number of ways. The most important parameters include:

  • 1) LFL, lower flammability limit. LFL is the minimum concentration of a gas or vapour that is capable of propagating a flame within a homogeneous mixture of that gas or vapour and air.
  • 2)  UFL, upper flammability limit. UFL is the maximum concentration of a gas or vapour that is capable of propagating a flame within a homogeneous mixture of that gas or vapour and air.
  • 3)  HoC, heat of combustion. HoC is the energy released as heat when a compound undergoes complete combustion with oxygen under standard conditions.
  • 4)  BV, burning velocity. The BV is the speed at which a flame propagates.
  • 5)  MIE, minimum ignition energy. The MIE indicates how much energy must be in an ignition source (e.g. a spark or naked flame) to initiate ignition of a gas or vapour. 

The safety code EN 378 2008 uses LFL and HoC to distinguish between highly flammable, flammable and non-flammable fluids. In the revised code currently being written, it is expected that a new category of “mildly flammable” is to be introduced, based on those fluids that have a low burning velocity. Table 1 summarises the characteristics of flammability used in EN 378. 

Table 1: European Safety Code EN 378: Flammability Classes

* For EN 378 the 2L category is a proposal that is still under discussion.
However, the 2L category is used in ISO 817:2014 “Refrigerants — Designation and safety classification”

The flammability issue is made even more complicated by various other effects that influence combustion. Three important examples are:

  • a)  The exact geometry of an ignition source can change the MIE – a spark between thin electrodes will ignite a gas with less energy than a spark between thick electrodes (due to the effect of heat removed from the combustion zone, via conduction along the electrodes).
  • b)  High air humidity can increase the burning velocity of some fluids; for example the BV of HFO 1234yf is 1.5 cm/s in dry air, but 5.9 cm/s in very humid air. However, this effect does not occur for all fluids. For example, HFC 32 has a BV of 6 cm/s at all levels of humidity.
  • c)  A dilution effect occurs when a leaking gas mixes with the air around it. For a highly flammable gas, the LFL is low and a lot of dilution must occur before the gas concentration drops to below the LFL. For mildly flammable gases, the LFL is much higher and dilution below the LFL can occur much more quickly. Figure 1 illustrates this effect (which can also be affected by gas density). The highly flammable propane leak rate is only a quarter of the leak rate for mildly flammable HFC 32, but it creates a much greater “ignition risk footprint” (the red area).

These issues have been discussed to illustrate the high complexity of the flammability issue. Safety codes must take a conservative approach in the absence of sufficient technical data. 

Figure 1: Modelling of leakage and areas of gas concentration above the LFL

These diagrams illustrate a computer prediction of the extent of the flammable region, when gases of different flammability leak into a room. The scenario shown here relates to leaks of R290 (propane, flammability class 3) and R32 (HFC 32, flammability class 2L) from a wall-mounted RACHP unit. The areas shown in red represents the zone where the gas concentration is between the LFL and the HFL, which means there is a risk of ignition if a sufficiently strong ignition source is present. Note, the R290 leak is 60 g/min, whilst the HFC 32 leak is over 4 times larger at 250 g/min. 

 

4. Likelihood and Severity of Risks

It is important to distinguish between the likelihood of ignition and the severity of the consequences of ignition.

The likelihood of ignition depends significantly on the LFL and the MIE:

  • A highly flammable fluid has a low LFL (i.e. there only needs to be a small amount of the gas mixed with air for ignition to be possible) and a low MIE (i.e. a low energy ignition source such as a small spark will cause ignition).
  • A mildly flammable fluid has a higher LFL – this means there will be a smaller area in which there is risk of ignition (in most normal circumstances, as illustrated in Figure 1). It also requires a much higher MIE, which means there needs to be a much more powerful ignition source located in the risk of ignition area.

The severity of the consequences of ignition depends significantly on BV and HoC:

  • A highly flammable fluid has a high BV – this can lead to explosive ignition within a cloud of gas that is above the LFL. If the HoC is also high, then the damage caused by the burning gas will be greater. 
  • A mildly flammable fluid has a low BV – in the situation where ignition occurs, the burning takes place slowly. Burning cannot be sustained if the air velocity is higher than the BV and it might not be sustained if the ignition source is removed.

Flammability Class 3 gases (highly flammable) such as propane exhibit both a high likelihood of ignition and a high severity of consequences following ignition.

Flammability Class 2L gases (mildly flammable) such as HFO 1234yf or HFC 32 are relatively difficult to ignite (both in terms of high LFL and high MIE) and their low BV makes the consequences of ignition much less severe.

Table 2 illustrates the variation in some of the key flammability characteristics discussed above,

Table 2: Examples of Key Parameters 

5 These MIE values are only approximate – they can vary considerably depending on test conditions

The data in Table 2 clearly show that a class 3 fluid is very easy to ignite (very low LFL and MIE) and that the consequences of burning can be severe (high BV and high HoC).

It is interesting to note that ammonia has been widely used in large industrial systems for many years. There are very few cases of fire related to an ammonia leak (due to the difficulty of ignition).

HFC 152a has a higher LFL and lower HoC than ammonia. Based on previous safety codes that would indicate that HFC 152a is “less flammable” than ammonia. However, practical experience indicates that HFC 152a is much more readily flammable than ammonia. This can be explained by the low MIE (making ignition much easier) and the high BV (making the consequences more severe). This shows the importance of avoiding a simplistic way of categorising flammability.

Ultra-low GWP fluids such as HFO 1234yf and moderate GWP fluids like HFC 32 are important alternatives that could help meet the EU HFC phase down targets. The data in Table 2 indicates that these fluids are much more difficult to ignite (much higher MIE and LFL than ammonia) and that consequences of ignition are more limited (low BV and Low HoC). These are encouraging characteristics, although it must be stressed that until safety codes have been revised it is difficult to define the safe “operating envelope” for fluids of this type. 

5. What does this mean for equipment manufacturers and end users?

To achieve a rapid phase down in the use of high GWP HFCs, it is likely that there will need to be a greater use of flammable fluids.

The safe operating envelop for well-established flammable fluids such as propane and ammonia can be established using existing safety codes such as EN 378 2008. In the case of propane and other hydrocarbons (HCs) this severely limits the applicability of these fluids except in very small systems (e.g. sealed refrigeration systems with less than 0.15 kg of refrigerant). For ammonia, the key safety issue is toxicity and this restricts the use of ammonia outside restricted locations such as factories and special plant rooms.

The safe operating envelop for new fluids such as HFO 1234yf and HFC 32 will need to be established over a period of time, based on increasing levels of practical experience and further technical research. This is likely to proceed in 3 stages:

  • a) Existing codes can be used immediately. Whilst these do not give full credit for the mildly flammable characteristics, they still allow much greater refrigerant charge than for HCs. For example a charge limit might be 1 kg for HCs and 7.8 kg for HFC 32. This allows quite widespread application in small retail refrigeration and small air-conditioning systems.
  • b) Revised codes are likely to be available by the end of 2015. These will widen the operating envelope for mildly flammable fluids (e.g. the charge limit quoted above would rise from 7.8 kg to 11.7 kg for HFC 32). This will enable a greater range of application than the current codes.
  • c) Within another few years it is likely that codes will be revised again, to take account of practical experience and new research. These may allow even larger charges to be used, although that clearly depends on the nature of the experience gained. 

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 26: Bans for New Products and Equipment

This information sheet is aimed all organisations that purchase new equipment and products that could contain F-Gases. This includes end users of refrigeration, air- conditioning, aerosols, fire protection systems and insulating foams. It is also of relevance to companies that manufacture and sell such products. 

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 Regulation includes a number of bans on the use of F-Gases in new products. This Information Sheet summarises all the bans in the F-Gas Regulation.

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. New Product Bans in the F-Gas Regulation

The 2014 F-Gas Regulation includes 20 bans on the use of F-Gases in specific new products and new equipment. Bans affect the following markets:

  • a)  Refrigeration
  • b)  Air-conditioning
  • c)  Fire protection
  • d)  Aerosols
  • e)  Foam insulation
  • f)  Others (including windows, footwear and car tyres)

Nine of the bans were already in the 2006 F-Gas Regulation and were all in force by 2009. The 11 new bans come into force between 2015 and 2025.

The bans are specified in Article 11 of the Regulation and detailed in Annex III. Each ban is based on a product definition and a specified scope of F-Gases (e.g. HFCs with a GWP above 150). It is important to emphasise that the bans referred to in this Information Sheet are for new products and equipment.

Article 11 describes three exemptions to the bans:

1)  Military equipment (this only refers to specialised equipment such as tanks and aircraft)

2)  Eco-design: If the lifecycle emissions (including energy and F-Gases, established under Directive 2009/125/EC) are lower with a banned product, an exemption can be granted.

3)  Limited 4 year exemptions, where it can be shown that there are technical or safety issues.

Exemptions (2) and (3) require the agreement of the European Commission for each specific product. 

New Products and Equipment: F-Gas Ban Summary Table

1 All start dates from 2015 onwards are January 1st of year specified

2 This ban includes both refrigerant and foam blowing agent
3 This ban includes both refrigerant and foam blowing agent
4 Exemption for equipment cooling products below -50oC

5 The primary circuit of cascade systems can use an HFC with a GWP up to 1,500

6 Exemption where F-Gas is required to meet national safety standards

7 For entertainment and decorative purposes as listed in Point 40, Annex XVII, Regulation EC/1907/2006

8 Exemptions: (a) when required to meet national safety standards, (b) medical applications

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 25: Understanding CO2 Size Thresholds

This information sheet is aimed all organisations that need to use the “CO2 size thresholds” that appear in several parts of 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 SF6The 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 Regulation makes use of various thresholds, using “CO2 equivalent”. This Information Sheet provides guidance on how these new thresholds are defined and how they should be used.

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. Use of Size Thresholds in the F-Gas Regulation

Various rules in the F-Gas Regulation use a size threshold. Small equipment below a threshold might not be affected, but above a certain size a relevant rule starts to apply. Thresholds are important as it is not always cost effective or practical to apply certain rules to small equipment. The requirements in both the 2006 and 2014 EU F-Gas Regulations that make use of a size threshold are:

  • a)  Mandatory leak check
  • b)  Automatic leak detection systems
  • c)  Record keeping
  • d)  The refrigeration equipment Service Ban (2014 Regulation only)
  • e)  Reporting on production, import and export of bulk F-Gases

From 2017 product and  equipment labels must show the amount of F-Gas in a system expressed in kg and in CO2 equivalent. This information must also be in instruction manuals and advertising material.

3. CO2 Equivalent (CO2e) Size Thresholds

In the 2006 Regulation, the thresholds were based on the quantity of F-Gas, measured in terms of the mass of fluid (in kilograms). For example, mandatory leak checks were required on all refrigeration and air-conditioning systems containing more than 3 kg of HFC refrigerant. The same kilogram threshold applied to all refrigerant types. Under the 2014 Regulation the thresholds have been changed to CO2 equivalent (CO2e). For example, the 3 kg leak checking threshold has been replaced with a threshold of 5 tonnes CO2e. 

What is “tonnes CO2 equivalent”? Tonnes CO2 equivalent is calculated by multiplying the mass of gas (in tonnes) by the GWP (global warming potential) of that gas. GWP compares the global warming impact of a gas compared to that of CO2 (which has a GWP of 1). F-Gases have high GWPs.

For the purposes of the 2014 EU F-Gas Regulation, the GWPs to be used in these calculations are those from the UN IPCC 4th Assessment Report. For pure gases, these GWP values are listed in Annex I of the Regulation. Many refrigerant gases in common use are blends, and for these you can calculate the GWP from the proportions and GWPs of the component pure gases (see table 2).

Why has the change to tonnes CO2 equivalent been made? The use of CO2e thresholds creates a lower kg threshold for F-Gases with a high GWP. This penalises those organisations that use high GWP gases and will encourage them to select equipment that uses F-Gases with the lowest practical GWP. This supports the objective of the F-Gas Regulation which is to minimise the global warming impact of F-Gas emissions.

4. Comparison of old and new thresholds

Table 1 shows the 2006 kg thresholds, the new 2014 CO2 thresholds and kg equivalents for a high GWP and moderate GWP refrigerant (HFC 404A, GWP = 3,922; HFC 134a, GWP = 1,430).

Table 1: Size Threshold Used in the Regulations

* The lowest thresholds for mandatory leak testing and record keeping are doubled for hermetically sealed equipment, from 5 tonnes CO2 to 10 tonnes CO2

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

The size thresholds for the high GWP HFC 404A are considerably smaller under the 2014 Regulation than previously. The reporting thresholds for production, import and export of bulk product are more than 10 times lower than in the 2006 Regulation.

5. CO2 to kg Conversion Table

Table 2: Equipment Size Thresholds for Various F-Gases and Refrigerant Blends 

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 6: Mobile Air Conditioning

This information sheet is aimed at organisations that are operators (usually the owner) of mobile air-conditioning systems, including those used in cars, larger road vehicles, trains and other forms of transport. It is also useful for those organisations that manufacture, sell, maintain and dispose of mobile air-conditioning systems. 

1. Background

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014) and the 2006 MAC Directive (40/2006). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6. The MAC Directive defines further controls related to cars and other small road vehicles.

In the mobile air-conditioning sector, the F-Gas Regulation affects the use of HFCs as refrigerants. The 2014 EU F-Gas Regulation replaces the 2006 F-Gas Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures. The 2006 MAC Directive remains in force.

The F-Gas Regulation and MAC Directive are important pieces 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 over one 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 mobile air-conditioning. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms. 

2. Sector description

The mobile air-conditioning (MAC) sector is a major user of HFCs. Most MACs are small systems using HFC 134a as the refrigerant. MACs in cars are usually driven via a belt drive to the engine. In larger vehicles (e.g. buses, trains) the MAC can be electrically driven or powered by a dedicated engine. There are 3 main categories of vehicles using MACs:

  • a)  Cars and light vans, including M1 and N1 Class vehicles, as defined in Section B of Annex II of Directive 70/156/EEC.
  • b)  Larger road vehicles, including buses, coaches, lorries and specialist vehicles such as tractors.
  • c)  Other transport air-conditioning, including trains, ships and aircraft.

Only cars and light vans fall under the scope of both the MAC Directive and the F-Gas Regulation.

Other vehicles are only affected by the F-Gas Regulation.

3. Purchase of new equipment

HFC Bans

Under the MAC Directive the use of HFC 134a (the standard refrigerant for MACs in cars and light vans) will be banned in new MAC systems used in cars and light vans. The ban takes place in two steps:

  • The use of HFCs with a GWP above 150 was banned in the MACs of new vehicle types placed on the market in the EU after January 1st 2013. New vehicle types are new models that need to undergo a process of “type approval”.
  • The use of HFCs with a GWP above 150 will banned in the MACs of all new vehicles placed on the market in the EU after January 1st 2017.

There are no HFC bans for MACs in any other types of vehicle.

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

When purchasing new mobile air-conditioning equipment in all vehicle types you 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. It makes sense to always purchase equipment using refrigerants with the lowest practical GWP to minimise the future impact of the phase down.

4. Operation of existing equipment

The 2014 F-Gas Regulation states that: “The intentional release of fluorinated greenhouse gases into the atmosphere shall be prohibited where the release is not technically necessary for the intended use. Operators of equipment that contains fluorinated greenhouse gases shall take precautions to prevent the unintentional release (‘leakage’) of those gases. They shall take all measures which are technically and economically feasible to minimise leakage of fluorinated greenhouse gases”. 

Organisations that use, install or maintain MAC equipment using F-Gases should ensure compliance with this requirement. F-Gases must be used with care and efforts made to avoid unintentional release.

5. Use of trained technicians

All refrigerant recovery operations on mobile air-conditioning equipment containing HFC refrigerants must be carried out by suitably trained technicians. See Information Sheet 22 for details of all training and certification requirements.

6. Requirements at end-of-life

Any mobile air-conditioning equipment containing HFCs that is being disposed of at end-of-life must undergo an HFC recovery process, carried out by a trained technician.

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 can be used in any refrigeration equipment. Recycled refrigerant must always be used with care as it may be contaminated or of unknown composition.

7. Reporting of imports

NEW: Any products and equipment containing F-Gases from outside the EU need to be reported to the Commission on an annual basis. The first report covers the calendar year 2014 and must be submitted to the Commission by March 31st 2015. Reports for future calendar years must be made by March 31st of the following year.

Details of import reporting requirements are given in Information Sheet 20. All imported vehicles that have MAC systems pre-charged with HFC or HFO refrigerants must be included in annual reports. 

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 5: Stationary Air-conditioning and Heat Pumps

This information sheet is aimed at organisations that are operators (usually the owner) of stationary air-conditioning and heat pump equipment used in buildings of all types. It is also useful for those organisations that manufacture, sell, maintain and dispose of stationary air-conditioning and heat pump equipment. 

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.

In the stationary air-conditioning and heat pump sectors, the F-Gas Regulation affects the use of HFCs as refrigerants. 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 stationary air-conditioning and heat pumps. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms. 

2. Sector description

The stationary air-conditioning and heat pump sector is a major user of HFCs. The majority of end user applications are in domestic, commercial and public sector buildings. There are 5 main categories of equipment used in the stationary air-conditioning and heat pump sector:

  • a)  Single split systems. These consist of an indoor cooling unit connected to an outdoor condensing unit (compressor and condenser). HFC 410A is dominant in new systems and refrigerant charge is typically between 1 kg and 5 kg.
  • b)  Large split systems and packaged units. This includes a range of direct expansion air- conditioning systems including multi-splits, VRF systems and rooftop packaged plants. HFC 410A is dominant in new systems and refrigerant charge is typically between 5 and 50 kg.
  • c)  Chiller systems. These are usually used to cool large buildings, using chilled water as a secondary refrigerant. Large chillers often use HFC 134a and have typical refrigerant charges between 50 kg and 500 kg. Smaller chillers might use HFC 410A or HFC 407C and have charges between 5 kg and 50 kg.
  • d)  Heating only heat pumps. This includes air source, ground source and water source heat pumps for building heating. Domestic systems often use HFC 410A and typically have a refrigerant charge between 3 kg and 5 kg. Larger systems using various refrigerants are used in commercial, industrial and public buildings.
  • e)  Hermetically sealed movable air-conditioning systems. Small integral air-conditioning units that can be moved between different rooms in a building. These usually use HFC 134a or HFC 410A and have refrigerant charges of well under 1 kg.

Many stationary air-conditioning systems are “reversible”, meaning that they can operate as cooling systems in hot weather and heat pump heating systems in cold weather.

VRF systems are usually designed to operate simultaneously in cooling and heating modes, for different parts of a building.

3. Purchase of new equipment

NEW: HFC Bans

The rules for purchase of new equipment depend on the type and size of equipment. There are two bans on the use of HFCs in new stationary air-conditioning and heat pump systems:

  • Ban 1: Use of HFCs with a GWP above 150 will be banned in all new hermetically sealed movable air-conditioning equipment placed on the EU market after January 1st 2020
  • Ban 2: The use of HFCs with a GWP above 750 will be banned in single split systems containing less than 3 kg of refrigerant placed on the EU market after January 1st 2025

There are no HFC bans that apply to larger air-conditioning systems (including chillers and larger split systems) or to heating only heat pumps. 

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

When purchasing new air-conditioning and heat pump equipment you 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.

4. Operation of existing equipment

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

Leak prevention and mandatory leak checks

The intentional release of F-Gases into the atmosphere is prohibited and operators of all stationary air-conditioning and heat pump equipment must take all measures that are technically and economicallyfeasibletominimiseleakage. Whereleaksaredetectedoperatorsmustcarryoutrepairs without undue delay.

NEW: Under the 2006 Regulation, the legal responsibility for preventing F-Gas releases was only given to the operator (usually the owner) of the equipment. In the 2014 Regulation there is a similar legal responsibility given to third party contractors carrying out installation, maintenance, leak checking or refrigerant recovery on behalf of operators.

Mandatory leak checks are required on all stationary air-conditioning and heat pump 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 (CO2e) size thresholds mean that the kg threshold for each refrigerant is different. Refrigerants with a higher GWP (e.g. HFC 410A) will have a lower size threshold than refrigerants with a lower GWP (e.g. HFC 134a). Table 1 shows leak testing requirements under both Regulations. Example thresholds are given for HFC 410A 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 1, the size threshold for HFC 410A is only 2.4 kg. Operators should check which of their systems 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. However, for systems with less than 3 kg, the 5 tonnes CO2e threshold only applies from 1st January 2017.

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. 

Table 1: 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

Mandatory automatic leak detection

NEW: For all stationary air-conditioning and heat pump systems containing over 500 tonnes CO2e 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 plants using higher GWP refrigerants. For HFC 410A the threshold for automatic leak detection systems is reduced from 300 kg to 240 kg. This rule applies from 1st January 2015. However, for lower GWP refrigerants it is possible that the new size threshold is higher than the old threshold of 300 kg. For HFC 134a, which is commonly used in large chillers, the new threshold is 350 kg.

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 every 12 months to ensure proper functioning.

Record keeping

Operators of stationary air-conditioning and heat pump equipment 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 plant operator for at least 5 years. Records collected by a contractor on behalf of an operator must 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. 

Service Ban

For refrigeration equipment using high GWP refrigerants there is a new Service Ban. It is important to note that the Service Ban does not apply to stationary air-conditioning and heat pump systems.

Use of trained technicians

All refrigerant handling operations on stationary air-conditioning and heat pump 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, maintenance and end-of-life decommissioning.

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

5. End-of-life requirements

Any stationary air-conditioning and heat pump equipment containing HFC refrigerants being disposed of at end-of-life must undergo an HFC recovery process.

The HFC 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.

For hermetically sealed movable air-conditioning systems the refrigerant can be recovered before the plant is sent for disposal. Alternatively the whole unit can be sent to a specialist recovery facility where HFCs can be 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. 

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 4: Transport Refrigeration

This information sheet is aimed at organisations that are operators (usually the owner) of transport refrigeration equipment, including vans, trucks and trailers. It is also useful for those organisations that manufacture, sell, maintain and dispose of transport refrigeration equipment. 

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.

In the transport refrigeration sector, the F-Gas Regulation affects the use of HFCs as refrigerants and as blowing agents for the insulation foam used for vehicle bodies. 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 transport refrigeration. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms. 

2. Sector description

The transport refrigeration sector is a significant user of HFCs. The majority of transport refrigeration is for road vehicles including vans, trucks and trailers. The refrigerated transport sector also includes shipping containers and specialised systems used for rail freight, ships and aircraft. Note, this sector does not include mobile air-conditioning (MAC) – see Information Sheet 6 for details of MAC systems.

Under the 2006 F-Gas Regulation there were few specific requirements in the transport refrigeration sector. The main requirement was for refrigerant recovery during plant maintenance and at end-of- life. Under the 2014 Regulation the transport sector is treated in a similar way to stationary refrigeration, with various new requirements including mandatory leak checks and use of trained technicians. Some of the new requirements apply to all transport systems, but some are specifically aimed at:

  • a)  Refrigerated trucks: motor vehicles above 3.5 tonnes and equipped with a refrigeration unit.
  • b)  Refrigerated trailers: vehicles designed to be towed by a tractor or truck and equipped with a refrigeration unit.

3. Purchase of new equipment

HFC Bans

There are no bans on the use of HFCs in new refrigerated transport systems.

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

When purchasing new transport refrigeration equipment you should carefully consider the impact of the HFC phase down which is a key feature of the 2014 F-Gas Regulation. The phase down 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. It is important to always purchase equipment using refrigerants with the lowest practical GWP to minimise the future impact of the phase down. HFC 404A is widely used in transport refrigeration systems and it has an especially high GWP. Various alternatives are becoming available for new equipment, as a response to the new F-Gas Regulation.

4. Operation of existing equipment

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

Leak prevention and mandatory leak checks

NEW: The intentional release of F-Gases into the atmosphere is prohibited. Operators of all transport refrigeration equipment must take all measures that are technically and economically feasible to minimise leakage. Where leaks are detected operators must carry out repairs without undue delay.

NEW: Under the 2006 Regulation, the legal responsibility for preventing F-Gas releases was only given to the operator (usually the owner) of the equipment. In the 2014 Regulation there is a similar legal responsibility given to third party contractors carrying out installation, maintenance, leak checking or refrigerant recovery on behalf of operators.

NEW: Mandatory leak checks are required on refrigerated trucks and trailers above a certain size threshold. The size thresholds are defined in terms of the quantity of refrigerant in each refrigeration unit, measured in tonnes CO2 equivalent.

The use of CO2 equivalent (CO2e) size thresholds means 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 1 shows leak testing requirements. Example thresholds are given for HFC 404A and HFC 134a. A comprehensive table of thresholds is given in Information Sheet 25.

The key size threshold for refrigerated trucks and trailers is 5 tonnes CO2e. Table 1 also shows the thresholds that apply to larger systems. These should not be relevant to trucks and trailers unless they have an unusually large refrigeration system.

Table 1: Size Thresholds for Mandatory Leak Checks of Refrigerated Trucks and Trailers

* The threshold for annual leak checks of hermetically sealed equipment is 10 tonnes CO2e

For refrigerated trucks and trailers with a refrigeration system containing more than 3 kg, the mandatory leak checks apply from 1st January 2015.

For systems with less than 3 kg but more than 5 tonnes CO2e (e.g. an HFC 404A system between 1.3 and 3 kg) the mandatory leak checks apply from 1st January 2017.

It should be noted that vehicles not defined as refrigerated trucks and trailers (e.g. a truck or van that is less than 3.5 tonnes in weight or a refrigerated container) are not subject to mandatory leak checks even if they contain a quantity of refrigerant above the 5 tonnes CO2e threshold. However, there is still the “catch all” requirement described above, to avoid intentional F-Gas release. It is recommended that all refrigerated transport systems are regularly checked for leakage to meet this obligation. This is particularly important for transport systems as they are often subject to harsh conditions such as heavy vibration.

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. 

NEW: Record keeping

Operators of refrigerated trucks and trailers must keep records for each piece of equipment subject

to a mandatory leak check (i.e. above the 5 tonnes CO2e threshold). The records to be kept include:

  • a)  quantity and type of F-Gas installed
  • b)  quantities of F-Gas added during installation, maintenance or when repairing a leak
  • c)  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)  for equipment decommissioned, the measures taken to recover and dispose of the F-Gases.

Records must be kept by the vehicle operator for at least 5 years. Records collected by a contractor on behalf of an operator must 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

A new feature of the 2014 F-Gas Regulation is the Service Ban, affecting existing equipment:

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

In the transport refrigeration sector this could affect systems that use HFC 404A. However, the size threshold of 40 tonnes CO2 is equivalent to 10.2 kg of HFC 404A. Most refrigerated trucks and trailers, vans and containers will be unaffected by the Service Ban as long as they are below this size threshold.

Large transport refrigeration systems (Including all transport types such as rail and ships) that are above the 40 tonnes CO2e threshold (10.2 kg for HFC 404A) must comply with the Service Ban. It will be legal to continue operating such systems, but you will not be allowed to top up any leaks with virgin refrigerant. Owners of equipment affected by the Service Ban have 3 main options:

  • a)  You 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)  You can “retrofill” the plant, replacing the HFC 404A with a lower GWP alternative such as HFC 407A, HFC 407F or HFC 452A. In the refrigerated transport sector the retrofill option may be problematic because of Regulations related to the transport of refrigerated food products (ATP Regulations - the Agreement on the international carriage of perishable foodstuffs).
  • c)  You can use reclaimed or recycled HFC 404A for plant maintenance until 1st January 2030.

NEW: Use of trained technicians

All refrigerant handling operations on refrigerated trucks and trailers using refrigeration 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, maintenance and end-of-life decommissioning. See Information Sheet 21 for details of all training and certification requirements.

5. End-of-life requirements

Any transport refrigeration 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.

For refrigerated trucks and trailers there is an explicit mandatory requirement for recovery.

For other transport refrigeration there is a “catch-all” requirement for the recovery of F-Gases “to the extent that it is technically feasible and does not entail disproportionate costs”. Under the 2006 Regulation the same catch-all requirement applied to all refrigerated transport. It is considered technically feasible and cost-effective to recover refrigerant from transport systems, so all operators of transport refrigeration equipment should ensure that F-Gases are recovered.

F-Gas refrigerant must be recovered by a certificated technician before the refrigeration system 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 in truck bodies) 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 can be used in any refrigeration equipment. 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 3: Industrial Refrigeration

This information sheet is aimed at organisations that are operators (usually the owner) of industrial refrigeration equipment. It is also useful for those organisations that manufacture, sell, maintain and dispose of industrial refrigeration equipment. 

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.

In the industrial refrigeration sector, the F-Gas Regulation affects the use of HFCs as refrigerants and as blowing agents for the insulation foam used for cold stores and pipe / vessel insulation. 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 industrial refrigeration. Further guidance is available – see Information Sheet 30 for a full list and for a glossary of terms. 

2. Sector description

The industrial refrigeration sector is a significant user of HFCs. Industrial refrigeration systems are used in a wide range of industry sectors. The most important are food and drink manufacturing and the chemicals / petrochemicals / pharmaceutical sectors. Other industry sectors such as printing and plastic moulding also require refrigeration. Industrial refrigeration systems are also used in non- industrial sectors such as cold storage, ice rinks and ski centres. There is a wide range of different industrial refrigeration requirements both in terms of size and temperature level. Examples include:

  • 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.

3. Purchase of new equipment

NEW: HFC Bans

For all industrial refrigeration equipment there is a ban on very high GWP refrigerants from 2020 – this will mainly affect the use of HFC 404A and HFC 507:

  • Ban 1: The use of HFCs with a GWP above 2,500 will be banned in all new industrial refrigeration equipment placed on the EU market after January 1st 2020

This ban applies to all sizes of industrial equipment. There are 2 exemptions from the ban:

  • a)  For equipment that cools a product to below -50 oC (note the Regulation refers to a product temperature, not to the refrigerant evaporating temperature).
  • b)  For military equipment – this exemption refers to specialised military equipment e.g. cooling in a tank or a military aircraft. It does not apply to non-specialised applications such as refrigeration for a military barracks kitchen.

Any foam insulation used in industrial systems, such as pipe and vessel insulation or insulated panels used for cold and chill stores, is subject to 2 further bans:

  • Ban 2: The use of HFCs with a GWP above 150 will be banned in extruded polystyrene foam (XPS) placed on the EU market after January 1st 2020
  • Ban 3: The use of HFCs with a GWP above 150 will be banned in other foams, including polyurethane foam (PU) placed on the EU market after January 1st 2023

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

Purchasers of new 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. To avoid future problems you should select only refrigerants with a GWP below 2,500, with immediate effect. The service ban is discussed in detail below. 

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

When purchasing new industrial refrigeration equipment you 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.

4. Operation of existing equipment

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, (c) the Service Ban and (d) the use of trained technicians. These requirements are described below.

Leak prevention and mandatory leak checks

The intentional release of F-Gases into the atmosphere is prohibited and operators of all industrial refrigeration equipment must take all measures that are technically and economically feasible to minimise leakage. Where leaks are detected, operators must carry out repairs without undue delay.

NEW: Under the 2006 Regulation, the legal responsibility for preventing F-Gas releases was only given to the operator (usually the owner) of the equipment. In the 2014 Regulation there is a similar legal responsibility given to third party contractors carrying out installation, maintenance, leak checking or refrigerant recovery on behalf of operators.

Mandatory leak checks are required on all industrial refrigeration equipment above certain size thresholds. It is likely that almost all industrial systems are well above the minimum size threshold for mandatory leak tests.

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 (CO2e) 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 kg size threshold than refrigerants with a lower GWP (e.g. HFC 134a). Table 1 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 1, the size threshold for HFC 404A is only 1.3 kg. Operators should check which of their systems 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. However, for systems with less than 3 kg, the 5 tonnes CO2e threshold only applies from 1st January 2017. 

Table 1: 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

NEW: For all industrial refrigeration systems containing more than 500 tonnes CO2e there is a mandatory requirement for an automatic leak detection system to be fitted. 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 industrial systems as they often contain more than 127 kg. Table 2 shows the size threshold for automatic leak detection for a number of refrigerants used in industrial systems. For most industrial refrigerants, the new size threshold is lower than the 300 kg threshold in the 2006 Regulation.

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.

Table 2: 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 of industrial refrigeration equipment 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 plant operator for at least 5 years

NEW: Records collected by a contractor on behalf of an operator must 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, affecting existing systems:

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

For industrial refrigeration this will mostly affect systems that use HFC 404A. The size threshold of 40 tonnes CO2e is equivalent to 10.2 kg of HFC 404A. The size thresholds for various other refrigerants used in industrial systems are given in Table 2. Almost all industrial systems are above these size thresholds and hence will be affected by the Service Ban. Refrigeration systems intended to cool products to temperatures below – 50 °C and military equipment are exempt from the Service Ban. .

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 2 (e.g. HFC 4343A, HFC 438A, 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. Operators of equipment affected by the Service Ban have 3 main options:

  • a)  You 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)  You 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). This option is a good one for younger equipment. There is good evidence that retrofilling HFC 404A with 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. 

Use of trained technicians

All refrigerant handling operations on industrial refrigeration 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, maintenance and end- of-life decommissioning.

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

5. Requirements at end-of-life

Any industrial refrigeration 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.

For industrial systems 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 can be used in any refrigeration equipment. 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 2: Commercial Refrigeration

This information sheet is aimed at organisations that are operators (usually the owner) of commercial refrigeration equipment, including food and drink retailers and food service companies. It is also useful for those organisations that manufacture, sell, maintain and dispose of commercial refrigeration equipment. 

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.

In the commercial refrigeration sector, the F-Gas Regulation affects the use of HFCs as refrigerants and as blowing agents for the insulation foam used for retail displays and storage equipment. 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 commercial refrigeration. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms. 

2. Sector description

The commercial refrigeration sector is a major user of HFCs. The majority of commercial end users are in retail (e.g. supermarkets, petrol stations, small shops) and in food service (e.g. pubs, hotels, restaurants). There are 3 main categories of equipment used in the commercial refrigeration sector:

  • a)  Small hermetically sealed systems, e.g. ice cream freezers, bottle coolers, stand-alone retail displays. These systems have similarities with domestic refrigerators and typically contain between 0.1 and 0.5 kg of refrigerant. HFCs 134a and 404A are widely used in these systems.
  • b)  Condensing units, used in small shops, convenience stores and food service. These are medium sized systems with one or two retail displays cooled by a remote “condensing unit” comprising a compressor and a condenser, located at the back of the shop or outdoors. They typically contain between 2 and 10 kg of refrigerant, with HFC 404A being dominant.
  • c)  Central pack systems, used in supermarkets and other large stores. Numerous display cases are connected to a compressor pack at the back of the store (with several compressors) and to an externally located condenser. Central packs are large systems often containing in excess of 100 kg of refrigerant, with HFC 404A being dominant.

3. Purchase of new equipment

NEW: HFC Bans

The rules for purchase of new equipment depend on the type and size of equipment. For all new commercial refrigeration equipment there is a ban on very high GWP refrigerants from 2020 – this will mainly affect the use of R404A:

  • Ban 1: The use of HFCs with a GWP above 2,500 will be banned in all new commercial refrigeration equipment placed on the EU market after January 1st 2020

For hermetically sealed commercial refrigerators and freezers there is an additional ban:

  • Ban 2: The use of HFCs with a GWP above 150 will be banned in new hermetically sealed commercial refrigeration equipment placed on the EU market after January 1st 2022

For central pack systems and other large commercial refrigeration systems there is an additional ban:

  • Ban 3: The use of HFCs with a GWP above 150 will be banned in new commercial refrigeration systems with a rated capacity of 40 kW or more placed on the EU market after January 1st 2022. The primary circuit of a cascade system can use an HFC with a GWP below 1,500.

The size threshold of 40 kW in Ban 3 refers to cooling capacity. Smaller pack systems and condensing units with a cooling capacity below 40 kW are only subject to Ban 1.

See Information Sheet 25 for more information on GWP.

For hermetically sealed commercial refrigerators and freezers Ban 1 and Ban 2 apply to both the refrigerant and the foam blowing agent. Ban 1 will mainly affect the use of HFC 404A as a refrigerant. Ban 2 will also prevent the future use of HFC 134a as the refrigerant and it will ban HFCs 245fa and 365mfc as the foam blowing agents (as these all have GWPs well above 150).

Any foam insulation used in retail displays or cold rooms served by condensing units or central pack systems is subject to 2 further bans that apply to different types of insulating foam:

  • Ban 4: The use of HFCs with a GWP above 150 will be banned in extruded polystyrene foam (XPS) placed on the EU market after January 1st 2020
  • Ban 5: The use of HFCs with a GWP above 150 will be banned in other foams, including polyurethane foam (PU) placed on the EU market after January 1st 2023

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

Purchasers of new commercial refrigeration equipment must be aware that a “Service Ban” will affect certain existing systems using HFCs with a GWP above 2,500 from 2020. To avoid future problems you should select only refrigerants with a GWP below 2,500, with immediate effect. The service ban is discussed in detail below.

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

When purchasing new commercial refrigeration equipment you 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.

4. Operation of existing equipment

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

Leak prevention and mandatory leak checks

The intentional release of F-Gases into the atmosphere is prohibited and operators of all commercial refrigeration equipment must take all measures that are technically and economically feasible to minimise leakage. Where leaks are detected operators must carry out repairs without undue delay.

NEW: Under the 2006 Regulation, the legal responsibility for preventing F-Gas releases was only given to the operator (usually the owner) of the equipment. In the 2014 Regulation there is a similar legal responsibility given to third party contractors carrying out installation, maintenance, leak checking or refrigerant recovery on behalf of operators.

Mandatory leak checks are required on all commercial refrigeration 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 (CO2e). These new CO2e 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 1 shows leak testing requirements under both Regulations. Example thresholds are given for HFC 404A and HFC 134a.

A comprehensive table of thresholds for all refrigerants is given in Information Sheet 24.

Table 1: Size Thresholds for Mandatory Leak Checks

EU F-Gas Regulation Size Thresholds for Mandatory Refrigerant Leak Checking

* 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 CO2

The new CO2e thresholds will require some systems below the old 3 kg threshold to be regularly leak tested. As shown in Table 1, the size threshold for HFC 404A is only 1.3 kg. Operators should check which of their systems 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. However, for systems with less than 3 kg, the 5 tonnes CO2e threshold only applies from 1st January 2017.

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 commercial refrigeration 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 a significant impact on plants using high GWP refrigerants.

For HFC 404A refrigeration systems, the new threshold for automatic leak detection 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 central pack systems as they often contain more than 127 kg.

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 commercial refrigeration equipment 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 plant operator for at least 5 years
NEW: Records collected by a contractor on behalf of an operator must 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, affecting existing systems:

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

In the commercial refrigeration sector this will mostly affect systems that use HFC 404A. The size threshold of 40 tonnes CO2 is equivalent to 10 kg of HFC 404A. Small systems, including hermetically sealed units and many condensing units will be unaffected if they are below this size threshold.

All existing central pack systems and larger condensing units (with more than 10 kg of HFC 404A) will need to comply with the 2020 Service Ban. It will be legal to continue operating such systems, but you will not be allowed to top up any leaks with virgin HFC 404A. Owners of equipment affected by the Service Ban have 3 main options:

  • a)  You 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)  You can “retrofill” the plant, replacing the HFC 404A with a lower GWP alternatives such as HFC 407A, HFC 407F, HFC 448A and HFC 449A. This option is a good one for younger equipment. There is good evidence that retrofilling with 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 HFC 404A for plant maintenance until 1st January 2030.

Use of trained technicians

All refrigerant handling operations on commercial refrigeration 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, maintenance and end-of-life decommissioning.

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

5. End-of-life requirements

Any commercial refrigeration 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.

For central pack systems and condensing units 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 in retail displays and small cold rooms) should be sent to a specialist recovery facility, where the foam can be crushed and the HFCs recovered.

For hermetically sealed commercial refrigerators and freezers any HFC refrigerant or HFCs in insulating foam must be recovered. The whole unit can be sent to a specialist recovery facility where HFCs from both the refrigeration circuit and the insulating foam can be recovered. Alternatively, the refrigerant can be recovered in situ and then the unit sent to a specialist facility for foam recovery.

All recovered HFC refrigerants 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 can be used in any refrigeration equipment. 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 1: Domestic Refrigeration

This information sheet is aimed at organisations that purchase and use domestic refrigeration equipment. It is also useful for those organisations that manufacture, sell, maintain and dispose of domestic refrigeration equipment. 

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.

In the domestic refrigeration sector, the F-Gas Regulation affects the use of HFCs as refrigerants and as blowing agents for the insulation foam. 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 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. Sector description

The domestic refrigeration sector includes refrigerators, freezers and fridge/freezers. The majority are used in domestic dwellings, although they are also used in commercial and public sector organisations (e.g. in offices and canteens). This type of equipment might use HFCs as the refrigerant (usually HFC 134a) and as a foam blowing agent (usually HFC 245fa or HFC 365mfc).

The majority of domestic refrigeration equipment sold in the UK uses hydrocarbons for the refrigerant and blowing agent. Hydrocarbons are completely outside the scope of the F-Gas Regulation. However, a small proportion of new appliances use HFCs – these are usually larger refrigerators and freezers, often being “American-style” fridges imported from outside the EU. The quantity of refrigerant used in a domestic refrigerator is very small – typically between 0.05 and 0.25 kg.

3. Purchase of new equipment

NEW: The use of HFCs with a GWP above 150 will be banned in new equipment placed on the EU market after January 1st 2015. This ban applies to both the refrigerant and the foam blowing agent. It will prevent the future use of HFC 134a as the refrigerant and HFCs 245fa and 365mfc as the foam blowing agents (as these all have GWPs well above 150).

See Information Sheet 25 for more information on GWP.

It is likely that the majority of domestic refrigeration equipment will use hydrocarbons as refrigerant and foam blowing agents. Some manufacturers may use a new family of ultra-low GWP alternatives called HFOs. Hydrocarbons and HFOs have GWPs well below 150, hence are not affected by this ban.

See Information Sheet 29 for guidance on low GWP HFC alternatives.

It is important to note that hydrocarbons are highly flammable and HFOs are mildly flammable. This may have an impact on the use of domestic refrigeration equipment in some circumstances.

See Information Sheet 27 for guidance on flammability issues.

4. Operation of existing equipment

The 2014 F-Gas Regulation does not create any special requirements for the normal operation of domestic refrigeration equipment.

5. Training and certification

If domestic refrigeration equipment that contains an HFC refrigerant requires maintenance, then the technician carrying out the work must have an F-Gas handling qualification and must work for an F-Gas certificated company. See Information Sheet 21 for details of the certification requirements that apply to technicians working on domestic refrigerators and freezers.

6. End-of-life requirements

Any domestic refrigeration equipment containing HFCs in either the refrigeration circuit or the insulating foam that is being disposed of at end-of-life must undergo a proper recovery process.

Most local authorities operate refrigerator collection schemes and send old units to specialist waste handling plants, where the refrigerant is recovered and the insulation is then crushed and the blowing agent is also recovered. 

Commercial and public sector users of domestic refrigeration equipment should ensure that their old equipment is also sent to a specialist recovery facility.

7. Reporting of imports

NEW: Any imported products and equipment containing F-Gases need to be reported to the Commission on an annual basis. The first report covers the calendar year 2014 and must be submitted to the Commission by March 31st 2015. Reports for future calendar years must be made by March 31st of the following year.

Details of import reporting requirements are given in Information Sheet 20.

For domestic refrigeration there could be a requirement for reporting data if you are an importer that imported domestic refrigeration equipment containing HFCs from outside the EU during 2014.

It is important to note that use of HFCs with a GWP above 150 is banned in new domestic refrigerators and freezers from January 2015 – this applies to imports as well as equipment manufactured in the EU. This means that from 2015 onwards there should be no imports of refrigerators using HFC 134a.

The reporting requirements also refer to equipment containing HFO refrigerants – so if you import refrigerators and freezers using HFOs, these must be reported annually. 

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

UK:  The latest in BITZER's renowned series of Refrigerant Reports is now available. The 18th edition includes vital information on all current refrigerants including HFC and HFO refrigerants, refrigerant blends, alternative halogen free refrigerants and R22 as a transitional refrigerant. The report once again underlines BITZER'S commitment to providing thoroughly researched and unbiased information to assist specifiers, refrigeration engineers and end users in their selection of refrigerants.

Refrigerant Report 18 reflects the fact that since the early 1990s there have been major changes in refrigeration technology, mainly due to environmental concerns and the need to develop refrigerants that would not contribute to ozone layer depletion. This has resulted in the emergence of many different new refrigerants, blends and alternatives. These are examined in detail and the report shows how system designs can be developed around a refrigerant of choice.

More generally, Refrigerant Report 18 offers the reader important guidance on the concept of TEWI (Total Equivalent Warming Impact) to calculate the environmental impact of the operation of individual refrigeration plants. It also describes the meaning of Eco Efficiency to express the operation of a plant as a consideration of all economic and ecological factors.

Download or view the Bitzer Refrigerant Report 18 here

 

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