What’s this all about?
The European F-Gas Regulation EC 517/2014 (amended 2018) aims to contain, prevent and thereby reduce emissions of HFC based refrigerants, which contribute to global warming if they are allowed to escape into the atmosphere. The new F-gas Regulation was published on June 9th, 2014 and has been effective since January 1st, 2015. Its a landmark regulation helping the European Union control emissions from fluorinated gases (F-gases) as part of its commitment to combat climate change. As set out in the regulation, part of the strategy to reduce our emissions was to implement both a phase down and a ban on usage of high GWP refrigerants.
From the 1st January 2020, it became prohibited to use virgin fluorinated greenhouse gases with a GWP of >2500 to service or maintain refrigeration equipment with a charge of 40 tonnes CO2 equivalent.
HFC Phase Down
The HFC 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. 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.
Refrigerant R404A replacement should now be a priority as warnings have been issued of the updated F-gas rules that now ban virgin high GWP refrigerants, like R404A, in systems of 40 tonnes CO2e or more from 1 January 2020.
So what does this actually mean?
Quite simply, under the European F-gas phase down timetable, it’s now illegal to service or refill refrigeration or freezer systems containing more than 10.2kg of virgin R404A. Smaller and hermetically sealed systems are not affected by this ban.
In addition to the commonly used R404A, the ban will also include R507 and the R22 replacement gas R422D, both of which have GWPs in excess of 2500. The ban applies across Europe.
Reclaimed or recycled refrigerant will still be able to be used until 2030. You might be thinking, aha! that’s how we can get around it, but the truth is, it’s not a justifiable option. The regulations have enforced a reduction in the quotas of refrigerant that can be both manufactured and imported into countries. This naturally impacts the volatility of the price of these refrigerants and generally makes them more expensive to purchase. But it’s not just the price that’s of immediate concern. In many countries throughout Europe, you cannot even buy R404A refrigerant anymore. So it’s imperative that you make plans now to replace this refrigerant with a lower GWP alternative refrigerant.
And what happens if you don’t?
DEFRA in the UK warns that operators who do not comply with the service ban are breaking the law and are liable for enforcement action. Regulators in England and Scotland can now issue civil penalties up to £200,000 to operators found to have breached the requirements of the regulation. Enforcement notices and possible fines can also be applied by enforcing authorities in Northern Ireland and Wales for breaches of F-gas provisions.
UK enforcement bodies, the Environment Agency (EA), Scottish Environment Protection Agency (SEPA) and Northern Ireland’s Department for Agriculture, Environment and Rural Affairs (DAERA) have jointly produced and endorsed a leaflet which provides guidance for businesses affected by the F-gas regulation. This can be downloaded here.
So what are your options?
- Do nothing and carry on as you are? This is not the best option. Yes you can continue to use recycled refrigerant until 2030 but these refrigerants are becoming more expensive and harder to obtain. There is also the moral obligation to protect our environment and use the lower GWP refrigerants whenever possible.
- Replace the refrigerant with a low GWP alternative: If the equipment is still in good condition (usually <10years old but depends on service history, application and environment), then the best option is usually to replace the refrigerant with a low GWP alternative. This can be a reasonably straight forward process.
- Replace the equipment: If the equipment is in very poor condition and has had multiple leaks in its history then it is recommended to replace the equipment completely. This might seem an expensive option at first, but if you were to add up all the refrigerant that it has lost through its lifetime and multiplied that by the cost of the refrigerant, then you will usually find replacing the equipment is a much more justifiable option. Not to mention less breakdowns.
Where can you get help with all of this:
Tradewinds specialise in marine and offshore surveys, consultancy and recommissioning of refrigeration equipment. We can be contacted at [email protected] or you can contact Stuart Ginbey directly on +447895904136 and he will be happy to talk you through the best way of moving forward.