EU F-Gas Regulations – Aerosols

EU F-Gas Regulations - Aerosols

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 aerosol sector, the F-Gas Regulation affects the use of HFCs as propellants and solvents. 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
can be 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 aerosol products.

Sector description

EU F-Gas Regulations – Aerosols 


All aerosols require a propellant to force product through the aerosol nozzle. Historically CFC
propellants were widely used. Since the phase out of CFCs under the EU Ozone Regulations, many
aerosol types moved away from fluorocarbon propellants to alternatives such as hydrocarbons (HCs)
and dimethyl ether (DME). Where flammability is a key issue HFCs are used, including HFC 134a and
to a lesser extent HFC 152a.

All domestic aerosols (e.g. for personal hygiene or household products) have switched to use of HCs
and DME. A wide range of “technical aerosols” use HFCs, mainly because of the importance of a nonflammable propellant; examples include pressure dusters, aircraft insecticide spray, mould release sprays, cryogenic freeing sprays and industrial lubricants. Metered dose inhalers (MDIs) are specialist aerosols used for drug treatments (e.g. asthma inhalers). All MDIs sold in the UK use HFC propellants.

The 2006 F-Gas Regulation banned one component foam (OCF) and novelty aerosols that used HFCs
with a GWP above 150. The OCF market has mostly switched to HC propellants. Flammability remains
an important issue for novelty aerosols and that sector has made use of a new propellant, HFO 1234ze.

Placing on the market of new aerosol products

EU F-Gas Regulations – Aerosols 


 

NEW: HFC Bans

A key impact of the 2014 F-Gas Regulation on new aerosols is a ban on the use of HFCs with a GWP of
more than 150 in technical aerosols from 2018.
NEW: Impact of the HFC Phase Down on selecting an aerosol propellant

When selecting an aerosol propellant it is very important to consider the HFC phase down that is a key feature of the 2014 F-Gas Regulation. 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.

The phase down is likely to lead to an increase in the price of HFCs. Irrespective of the bans described above, it makes sense to always use propellants with the lowest practical GWP to minimise the future impact of the phase down

New: Product Labeling

EU F-Gas Regulations – Aerosols 


 

From January 1st 2015 all aerosol products that contain F-Gases (including HFCs) shall not be placed
on the market unless the F-Gases are identified with a label indicating the following information:

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

Use of existing aerosols

EU F-Gas Regulations – Aerosols 


 

The 2014 F-Gas Regulation does not create any special requirements for the use of existing insulating foams.

Requirements at end-of-life

EU F-Gas Regulations – Aerosols 


 

The 2014 F-Gas Regulation requires operators of products and equipment that contain F-Gases to
arrange for the recovery of the gases, “to the extent that it is technically feasible and does not entail
disproportionate cost”.

Recovery of propellants from used or discarded aerosols requires a specialist facility that can extract
the remaining contents from the aerosol. Where discarded aerosols can be collected together in
sufficient numbers this may be considered as technically feasible and cost effective. However, endof-life recovery is unlikely to be cost effective for fully used technical aerosols.

Full or part-full aerosols should be captured and disposed of as hazardous waste.

Recovery must be carried out by trained technicians. 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 propellant into a gas with properties
identical to virgin fluid, to create “reclaimed propellant”.

It is estimated that in 2012 the residual HFCs in the approximately 20 million technical aerosols used in the UK totaled less than 20 tonnes. Several studies conducted on recycling of empty aerosols have found that only 1-2 % of the original contents remain in an aerosol at the end of life.

Reporting of imports

EU F-Gas Regulations – Aerosols 


NEW: Any aerosols containing HFCs and HFOs8 imported 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.

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).