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Stationary air-condition and heat pumps

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

Transport Refrigeration: Compliance Checklist for EU F-Gas Regulation

Purchase of new equipment

NEW: Take account of HFC phase down when selecting refrigerants

Operation of existing equipment

NEW: Mandatory leak checks and repairs for refrigerated trucks and trailers
NEW: Use new CO2 equivalent size thresholds for mandatory leak checks
NEW: Keep records about refrigeration equipment using HFC refrigerants
NEW: Use qualified technicians for leak checking and refrigerant handling operations
NEW: For large refrigerated transport systems, a service ban affecting maintenance of
existing high GWP systems (e.g. HFC 404A)

End-of-life requirements

Mandatory recovery of refrigerant by qualified technician

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-oflife.
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.

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 Regulation1. 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

 

 

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.

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.

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.

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).