EU F-Gas regulations – Fire Protection Systems

EU F-Gas Regulations - Fire Protection Systems

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 fire protection sector, the F-Gas Regulation affects the use of HFCs and PFCs as fire extinguishing fluids in various specialised building applications. 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 fire protection systems.

Sector description

EU F-Gas Regulations – Fire Protection Systems

The fire protection industry make use of HFC fire extinguishing products in certain specialised

There are 3 main categories of HFC equipment used in the fire protection sector:

a) Specialised building applications, where building contents have a high value and other fire
protection systems (e.g. water based) could cause too much damage. In the UK most systems
of this type use HFC 227ea (also referred to by trade names such as FM 200).
b) Small automatic extinguishers. Small automatic extinguishers based on HFCs can be used for
applications such as bus engine, small boat engine and motorsport fire protection.
c) Hand held extinguishers. Despite very few HFC portable fire extinguishers being used in the
UK, they are still permitted.

Purchase of new equipment

EU F-Gas Regulations – Fire Protection Systems


HFC Bans

The 2014 F-Gas Regulation includes certain bans applied to placing new fire protection systems on the
market in the EU from 1st January:
1 Fire protection systems containing PFCs 2007
2 NEW: Fire protection systems containing HFC 23 2016

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

When purchasing new fire protection equipment you should consider the HFC phase down.
This will reduce the quantity of virgin 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 fire
extinguishing fluids with the lowest practical GWP to minimise the future impact of the phase down

Product Labeling

EU F-Gas Regulations – Fire Protection Systems

All fire protection systems that contain F-Gases (including HFCs) shall not be placed on the market unless the F-Gases are identified with a label. The label shall indicate the following information:

1) A reference that the fire extinguishing agent contains an F-Gas
2) The accepted industry designation for the F-Gas concerned or, if no such designation is
available, the chemical name

HFC phase down

EU F-Gas Regulations – Fire Protection Systems

It is worth noting that recycled and reclaimed HFCs are not included in the phase down process. Within the fire protection sector the use of recycled and reclaimed HFCs may become important during the phase down.

NEW: From 1 January 2017, the quantity expressed in weight and in CO2 equivalent of F-Gas
contained in the fire protection system, and the global warming potential of the F-Gas used.

Operation of existing equipment

EU F-Gas Regulations – Fire Protection Systems


The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance
of existing fire protection systems containing HFC fire extinguishing fluids. The rules depend on the
type and size of fire protection systems 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

EU F-Gas Regulations – Fire Protection Systems


The intentional release of F-Gases into the atmosphere is prohibited and operators of all fire
protection systems 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.

Under the 2006 Regulation, the legal responsibility for preventing F-Gas releases was only given
to the operator 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 HFC recovery on
behalf of operators.

Mandatory leak checks are required on all stationary fire protection systems above certain size
thresholds. Under the 2006 F-Gas Regulation, the thresholds were set in terms of the physical quantity
of HFC 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 HFC fluid is
different. Fire extinguishing fluids with a high GWP (e.g. HFC 23) will have a lower size threshold than
fire extinguishing fluids with a lower GWP (e.g. HFC 227ea).

The Regulation recognises that most fire protection systems have regular maintenance and leak checks.
The leak checking obligations shall be considered to be fulfilled provided the following two conditions
are met:
• the existing inspection regime meets ISO 14520 or EN 15004 standards; and
• the fire protection equipment is inspected as often as shown in Table 2

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.

Automatic leak detection

EU F-Gas Regulations – Fire Protection Systems


NEW: For all fire protection 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 an impact on systems using high GWP fire extinguishing fluids. As shown in
Table 2, for HFC 227ea systems the new threshold for automatic leak detection systems is reduced
from 300 kg to 155 kg. For HFC 23 systems the threshold for automatic leak detection is even lower –
at just 34 kg. This rule applies from 1st January 2015. Most fire protection systems are already
provided with an automatic leak detection facility as standard.

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

EU F-Gas Regulations – Fire Protection Systems


Operators of fire protection systems 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 ‘operator’ for at least 5 years. Records collected by a contractor
on behalf of an operator must be kept 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.

Use of trained technicians

EU F-Gas Regulations – Fire Protection Systems


All HFC handling operations on fire protection systems containing HFC fire extinguishing fluids must
be carried out by suitably trained technicians holding an F-Gas ‘Competency’ certificate and working
for an F-Gas Certificated company. This includes plant installation, leak testing, maintenance and end of-life decommissioning. 

Requirements at end-of-life

EU F-Gas Regulations – Fire Protection Systems

Any fire protection systems containing HFCs that is being disposed of at end-of-life must undergo an HFC recovery process. Recovery must be carried out by a certificated technician.

All recovered F-Gases can either be:
a) given a basic cleaning process, to create “recycled HFC”.
b) sent to a specialist plant that can re-process the old HFC into a fluid with properties identical
to virgin HFC, to create “reclaimed HFC”
c) sent for destruction by incineration at a licenced waste facility

Given the HFC supply shortage that will be created by the phase down process, it is worth trying to
send the old HFC for reclamation as it may have a good residual value. If the old HFC 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 HFCs can be used in any equipment. Recycled HFCs must always be used with care as they
may be contaminated or of unknown composition.

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).