EU f gas regulations – industrial refrigeration

Commercial refrigeration

This is EU f gas regulations – industrial refrigeration guidance 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 Index & glossary for a full list and a glossary of terms.

Industrial Refrigeration: Compliance Checklist for EU F-Gas Regulation

Purchase of new equipment

NEW: Comply with a ban on the use of high GWP HFCs in new industrial equipment.
NEW: Take account of service ban when selecting refrigerants
NEW: Take account of HFC phase down when selecting refrigerants

Operation of existing equipment

Mandatory leak checks and repairs
NEW: Use new CO2 equivalent size thresholds for mandatory leak checks
NEW: Use new CO2e size thresholds for automatic leak detection (from 1st Jan 2015)
Keep records about all refrigeration equipment using HFC refrigerants
NEW: Service ban, affecting maintenance of existing high GWP systems (e.g. HFC 404A)
Use qualified technicians for leak checking and refrigerant handling operations

End-of-life requirements

Mandatory recovery of refrigerant by qualified technician

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 nonindustrial 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.

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 GWP1 above 2,500 will be banned in all new commercial 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.

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)5. 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 the ‘Training and Certification for High Voltage Electrical Switchgear’ section.

The new CO2e thresholds will require some systems below the old 3 kg threshold to be regularly leak tested. 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 industrial 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. 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.

Record keeping

Operators of industial 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 industrial refrigeration sector this will mostly affect systems that use HFC 404A. Almost all industrial systems are above the 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.

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 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 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 ‘Training and Certification for Refrigeration, Air-conditioning and Heat Pumps’ for details of all training and certification requirements.

End-of-life requirements

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 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.

The SRAC industry and the world as a whole, now understand that fluorinated gases have a potentially devastating global warming effect when released into the atmosphere.

F Gas regulations have been implemented in order to contain, prevent and thereby reduce emissions of fluorinated greenhouse gases.

On 2nd April 2008, the Commission Regulation 303/2008 set out the requirements for a company certification scheme.

This scheme is specifically for businesses working with F Gas refrigeration, air-conditioning and heat pump equipment containing or designed to contain fluorinated greenhouse gases.

These F Gas Certification requirements are in accordance with Article 5.1 of EC Regulations 842/2006 on certain fluorinated greenhouse gases (the EC F Gas Regulation).