EU F-Gas-Marine Applications

Marine Applications

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. Marine applications might also be affected by the 2009 EU Ozone
Regulation (1005/2009) if HCFC refrigerants such as R-22 are still in use.

In the marine sector, the F-Gas Regulation mainly affects the use of HFCs as refrigerants for
refrigeration and air-conditioning systems. It may also impact the use of insulation foam and fire
protection equipment. 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 marine applications of F-Gases.

Sector description

EU F-Gas Regulations – Marine Applications


 

The marine sector is a significant user of HFCs and HCFCs. The main uses of these fluids is as
refrigerants in refrigeration and air-conditioning (RAC) systems. Refrigeration is used for storage of
certain types of cargo and for storage of food and drink products required by passengers or crew.
Air-conditioning is used for comfort cooling of areas occupied by passengers or crew. Some types of
ship require specialised refrigeration systems such as fishing vessels and factory ships.

Other applications could include:

(1) foam insulation that is manufactured using HFC or HCFC blowing
agents and
(2) fire protection systems based on HFC fire suppression fluids.

Mobile applications

EU F-Gas Regulations – Marine Applications


 

This Information Sheet is targeted at marine applications in ships that move on a regular basis. The
F-Gas Regulation makes a distinction between stationary and mobile applications. Mobile is defined
as “normally in transit during operation”. This applies to any equipment filled with F-Gases used in a
ship that moves on a regular basis.

Some marine applications are used in the offshore hydrocarbons industry, in offshore installations
such as fixed / floating platforms and mobile facilities e.g. mobile drilling units and floating production,
storage and offloading units. All fixed and mobile facilities that are involved in hydrocarbon operations
are treated as stationary applications under the F-Gas Regulation because the units normally operate
in fixed locations and are generally only in transit for the purpose of moving from one fixed location
to the next. This Information Sheet does not deal with offshore hydrocarbons installations. Specialist
guidance for such installations is available.

Movement in and out of the EU

EU F-Gas Regulations – Marine Applications


 

The marine sector can be considered a special case in relation to the EU F-Gas Regulation due to the
movement of ships in and out of the EU. The rules described in this Information Sheet:
– apply to all ships that are in EU territories (e.g. in an EU port)
– do not apply to a non-EU registered ship that is outside the EU
– the Regulation does not specify whether the rules apply to an EU registered ship operating
outside the EU; as the F-Gas Regulation is intended to protect the environment, it is
recommended that EU registered ships should apply the rules in this Information Sheet
irrespective of the ship’s location.

See UK Guidance at: https://www.gov.uk/oil-and-gas-legislation-on-emissions-and-releases#fluorinatedgreenhouse-gases-regulations-2015

Purchase of New Equipment

EU F-Gas Regulations – Marine Applications


 

HFC Bans

There are no bans on the use of HFCs in new RAC equipment being installed on a ship.
Foam insulation is affected by bans on new foam that is manufactured with a blowing agent with a
GWP3 above 150. The ban applies to extruded polystyrene (XPS) foam from January 2020 and to other
foams (e.g. polyurethane) from January 2023.

New fire protection equipment is affected by bans on use of PFCs (banned in 2007) and HFC-23
(banned from January 2016).

NEW: Impact of the HFC phase-down on the purchase of new equipment

EU F-Gas Regulations – Marine Applications


 

When purchasing new marine RAC equipment you should carefully consider the impact of the HFC
phase-down which is a key feature of the 2014 F-Gas Regulation

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 compared to 2015. 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 HFC phase-down. HFC-404A is widely used in marine refrigeration
systems and it has an especially high GWP. A wide range of low GWP alternatives are becoming
available for new equipment, as a response to the new F-Gas Regulation.

NEW: Impact of the Service Ban on purchase of new equipment

EU F-Gas Regulations – Marine Applications


 

Purchasers of new marine refrigeration equipment must be aware that a “Service Ban” will affect
certain existing systems using HFCs with a GWP above 2,500 from January 2020. To avoid future
problems, it is recommended that you select only refrigerants with a GWP below 2,500, with
immediate effect. The service ban is discussed in detail below.

End-of-life requirements

EU F-Gas Regulations – Marine Applications


Any marine refrigeration equipment or foam insulation containing HFCs that is being disposed of at end-of-life must undergo an HFC recovery process. For stationary RAC equipment there is an explicit mandatory requirement for recovery. For mobile RAC equipment 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”. It is considered technically feasible and cost-effective to recover refrigerant from marine RAC systems, so all operators should ensure that F-Gases are recovered.

F-Gas refrigerant must be recovered by “an appropriately qualified” technician before the system is
dismantled. The training required for technicians that work on stationary RAC is not mandatory for
marine RAC, but would be considered “appropriate”. Modern refrigerant recovery machines should
be able to remove well over 95% of the refrigerant in an old system. Any insulating foam containing
HFCs 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. From 2020 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.

NEW: Service Ban for High GWP HFCs

EU F-Gas Regulations – Marine Applications


 

From January 2017 RAC equipment pre-charged with HFCs cannot be placed on the market unless the
HFCs are accounted for within the EU HFC phase down quota system

This rule that affects all pre-charged RAC equipment (including equipment manufactured in the EU and equipment that is imported).

Examples of equipment affected includes:
a) Hermetically sealed systems (e.g. for refrigerators and freezers used to store food)
b) Split system and VRV air-conditioning systems
c) Chillers

Companies that import pre-charged RAC equipment into the EU for installation in ships and other
marine applications must comply with these rules.

NEW: Pre-charged RAC equipment

EU F-Gas Regulations – Marine Applications


From January 2017 RAC equipment pre-charged with HFCs cannot be placed on the market unless the
HFCs are accounted for within the EU HFC phase down quota system

This rule that affects all pre-charged RAC equipment (including equipment manufactured in the EU and equipment that is imported).

Examples of equipment affected includes:
a) Hermetically sealed systems (e.g. for refrigerators and freezers used to store food)
b) Split system and VRV air-conditioning systems
c) Chillers

Companies that import pre-charged RAC equipment into the EU for installation in ships and other
marine applications must comply with these rules.

Operation of existing equipment

EU F-Gas Regulations – Marine Applications


 

The 2014 F-Gas Regulation includes an important general requirement to avoid the intentional release
of F-Gases from any equipment, including RAC on ships. Article 3 of the Regulation states:

a) The intentional release of F-Gases is prohibited where the release is not technically necessary
for the intended use8
b) Operators must take precautions to prevent leakage, taking all measures that are technically
and economically feasible to minimise leakage
c) Where leakage is detected the equipment must be repaired without undue delay.
For stationary applications the Regulation provides significant detail about mandatory requirements
that would support compliance with these general rules. In particular, there are rules related to:
– regular leak checking
– record keeping
– the use of trained technicians.

These requirements are not mandatory for applications used on ships. However, a ship operator
should consider how compliance with the Article 3 requirements listed above can be assured. Much
of the RAC equipment used on a ship is very similar to that used in stationary applications in buildings
and industrial facilities.

If a ship operator follows the rules that apply to similar stationary equipment it is reasonable to expect that you are in compliance with Article 3. The key rules that apply to stationary applications are summarised below. It must be stressed that these are not mandatory for RAC systems on ships, but that they represent a reasonable framework for compliance with Article 3 and for responsible use of refrigerants.

Regular leak checks

EU F-Gas Regulations – Marine Applications


 

For stationary equipment mandatory leak checks are required above a certain size threshold. A leak
check must be carried out with an appropriate leak detection device (e.g. a hand-held electronic
sniffer) in all parts of the systems that might leak. For small systems the mandatory leak checks are
annual and for larger systems the checks must be done every 6 months.

This allows release from an application such as an aerosol but would not allow release from RAC equipment.
The size thresholds used to define leak test frequency 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 kg size threshold than those
with a lower GWP (e.g. HFC-134a). Table 1 shows leak testing requirements. Example thresholds are
given for HFC-404A and HFC-134a. For other refrigerants, see Information Sheet 25.
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.

Implications for RAC on ships: Use of the leak checking rules that apply to stationary systems is a good way to ensure that intentional release of F-Gases is not occurring.

Automatic leak detection

EU F-Gas Regulations – Marine Applications


 

For all stationary RAC systems containing 500 tonnes CO2e or more there is a mandatory requirement
for an automatic leak detection system to be fitted. For HFC-404A refrigeration systems this means
any plant containing more than 127 kg.

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.

Implications for RAC on ships: It is good practice to consider fitting automatic leak detection on larger
pieces of RAC equipment, although it is not mandatory for ships under the F-Gas Regulation. Early
warning of leakage is good for the environment and also reduces the risk of a ship suffering a major
refrigeration system failure that could lead to the spoilage of goods being transported.

Record keeping

EU F-Gas Regulations – Marine Applications


For stationary equipment, operators 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 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 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 Member State competent authority or to the Commission.
Implications for RAC on ships: It is impossible to comply with the Article 3 requirements if you have
no records of the HFC equipment installed and the use of HFCs for maintaining that equipment.
Keeping records in a similar format to those required for stationary applications will enable operators
to review their F-Gas equipment and take the necessary steps to minimise leakage.

Use of trained technicians

EU F-Gas Regulations – Marine Applications


 

For stationary applications, all refrigerant handling operations on 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.

Implications for RAC on ships: To minimise leakage it is important that technicians working on RAC
systems have adequate training. Using F-Gas certificated technicians (i.e. with the appropriate
training for similar stationary equipment) is a good way of ensuring this, although other forms of
training (e.g. in-house) may also be considered adequate if they are of an equal standard.

NEW: Service Ban for High GWP HFCs

EU F-Gas Regulations – Marine Applications


 

From January 2017 RAC equipment pre-charged with HFCs cannot be placed on the market unless the
HFCs are accounted for within the EU HFC phase down quota system

This rule that affects all pre-charged RAC equipment (including equipment manufactured in the EU and equipment that is imported).

Examples of equipment affected includes:
a) Hermetically sealed systems (e.g. for refrigerators and freezers used to store food)
b) Split system and VRV air-conditioning systems
c) Chillers

Companies that import pre-charged RAC equipment into the EU for installation in ships and other
marine applications must comply with these rules.

Use of trained technicians

EU F-Gas Regulations – Marine Applications


 

A new feature of the 2014 F-Gas Regulation is the Service Ban, affecting existing equipment on ships:
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 marine refrigeration sector this affects systems that use HFC-404A if they have a charge above
10.2 kg. The service ban also affects other refrigerants with a GWP above 2,500 such as HFC-507A
and HFC-422D. 
From 2020 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 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, HFC-448A, HFC-449A or HFC-452A.
c) You can use reclaimed or recycled HFC-404A for plant maintenance until 1st January 2030.
Service Ban for HCFCs
Under the Ozone Regulation there is now a complete ban on the servicing of HCFC equipment (e.g.
HCFC-22). This ban came into force at the start of 2015 and it applies to both virgin and reclaimed
HCFCs. It is still legal to use RAC equipment that contains HCFCs, but no refrigerant can be added to
a system during maintenance.

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).