EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors

EU F-Gas Regulations - Refrigeration, Air-Conditioning & Heat Pump Contractors

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. Contractors play a major role supporting operators of refrigeration, air-conditioning and heat pump (RACHP) equipment. They have to comply with a number of requirements under the F-Gas Regulation.

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 RACHP contractors.

Sector description

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

The RACHP sector covers a wide range of equipment and end users, ranging from small domestic and
commercial systems to large industrial plant. Key sectors of the RACHP market include
1. Domestic refrigeration
2. Commercial refrigeration
3. Industrial refrigeration
4. Transport refrigeration
5. Stationary air-conditioning and heat pumps
6. Mobile air-conditioning

Most operators of RACHP equipment in these sectors make use of specialist contractors for
installation and maintenance work. There are over 5,000 RACHP contractors in the UK, ranging from
large companies with UK-wide capability to very small businesses working in a small geographic area.

The skill and expertise of the RACHP contracting industry is crucial, providing operators with various
services through the life cycle of RACHP equipment.

The F-Gas Regulation places legally binding obligations on contractors to ensure that they help end
users minimise the use and emissions of high GWP1 refrigerants. It is important that contractors
comply with the Regulations that apply to them and also that they are aware of other relevant parts
of the F-Gas Regulation so that they can provide their clients with appropriate advice.

Advice regarding purchase of new equipment

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

Contractors often provide important advice to their clients about purchase of new equipment. In the
2014 F-Gas Regulation there are 3 important new requirements that will change the advice that
contractors give to their clients. These are:
a) Various specific bans, that will require lower GWP refrigerants to be used
b) The impact of the HFC phase down, that will encourage use of low GWP refrigerants
c) The impact of the service ban, which affects the purchase of new systems using high GWP
refrigerants such as HFC 404A

NEW: HFC Bans

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


The 2014 Regulation includes a number of HFC bans as summarised in Table 1. Contractors should be aware that these bans “do not tell the full story”. You must make clients aware of the phase down
and the service ban (see below) – these also have a significant influence on selecting new plant.
NEW: Impact of the Service Ban on purchase of new equipment

Purchasers of new commercial and 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. The ban
applies to systems containing more than 40 tonnes CO2 equivalent (10 kg for HFC 404A). To avoid
future problems you should advise clients purchasing plants above this size threshold to select only refrigerants with a GWP below 2,500, with immediate effect.

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

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

When purchasing new RACHP equipment your clients 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

Contractor training and certification requirements

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


All refrigerant handling operations on RACHP 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, refrigerant recovery, maintenance and end-of-life decommissioning. The training and certification requirements are based on those already specified in the 2006 F-Gas Regulation.

Existing individual F Gas qualification certificates remain valid in accordance with the conditions under
which they were originally issued. This means that those who hold certificates with an expiry date
(CITB J11-J14) will need to be re-assessed and an updated assessment is now available.

  • All start dates are January 1st of year specified
  • This ban includes both refrigerant and foam blowing agent
  • Exemption for equipment cooling products below -50oC
  • The primary circuit of cascade systems can use an HFC with a GWP up to 1,500

 

NEW: The certification requirements have been extended to include technicians working on
refrigerated trucks (>3.5 tonnes) and refrigerated trailers.

NEW: Qualified technicians must also be given “information on relevant technologies to replace or to
reduce the use of fluorinated greenhouse gases and their safe handling”. No further assessments are
required, but all technicians should be aware of relevant information about the use of alternatives. It
is expected that standard information will be prepared and then circulated via Certification Bodies.

Company Certification is required by all contractors carrying out installation and maintenance work.
This applies to sole traders as well as limited companies. The process is unchanged from the 2006
Regulation. 

Contractor responsibilities to minimise refrigerant emissions

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


Under the 2006 F-Gas Regulation the legal responsibilities related to F-Gas emissions from RACHP
equipment were held only by the plant operator (usually the owner).

NEW: In the 2014 Regulation there is an explicit legal requirement for contractors to share this
responsibility. Article 3 of the Regulation states that “The intentional release of F-Gases into the
atmosphere shall be prohibited where the release is not technically necessary for the intended use.”

The Regulation then states that contractors “carrying out the installation, servicing, maintenance,
repair or decommissioning of RACHP equipment shall be certified and shall take precautionary
measures to prevent leakage of F-Gases”.

This is an important new requirement about which contractors may need to inform a client, if they are
being asked to do something that does not comply with the Regulation.

Contractor responsibilities during plant installation

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

All contractor staff carrying out installation work related to refrigerant handling must hold the
appropriate F-Gas handling certificate and must make precautionary measures to prevent leakage.
Engineers carrying out unrelated installation activities (e.g. electrical work) do not need a refrigerant
handling qualification. However, anyone doing work that could affect the refrigerant circuit and give
rise to possible leakage must be qualified – e.g. an engineer setting a high pressure cut-out device
should be qualified – if this was set incorrectly it could give rise to a leak.

Product Labeling

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


All RACHP products 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 RACHP system contains F-Gases
2) The accepted industry designation for the F-Gas concerned or, if no such designation is
available, the chemical name
3) NEW: From 1 January 2017, the quantity expressed in weight and in CO2 equivalent of F-Gas
contained in the equipment, and the global warming potential of the gas
4) If applicable, a reference that the F-Gases are contained in hermetically sealed equipment

For some pre-charged RACHP equipment the label will be provided by the equipment manufacturer.
However, for all RACHP systems that are filled or topped up with refrigerant during installation, it is
the responsibility of the installation contractor to ensure that a suitable label is attached, stating the
total amount of refrigerant in the system.

Contractor responsibilities during maintenance activities

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance
of existing industrial refrigeration equipment containing HFC refrigerants. The rules depend on the
type and size of industrial refrigeration equipment being used. The regulations affecting existing
equipment relate to

(a) leak prevention,

(b) record keeping and

(c) the Service Ban.

These requirements are described below.

Mandatory automatic leak detection

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

For all RACHP systems containing over 500 tonnes CO2e there is a mandatory requirement for an
automatic leak detection system to be fitted. 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”.

NEW: Mandatory automatic leak detection 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 systems the new threshold
for automatic leak detection systems 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 large
refrigeration systems as they often contain more than 127 kg. Table 3 shows the size threshold for
automatic leak detection for a number of refrigerants used in RACHP systems. For most refrigerants,
the new size threshold is lower than the 300 kg threshold in the 2006 Regulation.

Automatic leak detection systems must be tested every 12 months to ensure their proper functioning.

Record keeping

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

Operators must ensure records are kept for each piece of equipment that is subject to a mandatory
leak check (i.e. above the 5 tonnes CO2e threshold). The records 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. Where a contractor prepares
records for the operator, the records should also 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

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

An important new feature of the 2014 F-Gas Regulation is the Service Ban:
• From 1st January 2020 the use of F-Gases with a GWP above 2,500 to maintain refrigeration
systems with a charge size of 40 tonnes CO2e or more shall be prohibited.
In the refrigeration sector this will mostly affect systems that use HFC 404A. The size threshold of 40
tonnes CO2e is equivalent to 10 kg of HFC 404A.

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. Some of these are listed in Table 3 (e.g. HFC 434A,
HFC 422D).

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. Contractors should advise operators of equipment affected
by the Service Ban that they have 3 main options:

a) They 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) They can “retrofill” the plant, replacing the refrigerant with a lower GWP alternative (for HFC
404A you can use alternatives such as HFC 407A, HFC 407F, HFC 448A and HFC 449A for most
applications). This option is a good one for younger equipment. There is good evidence that
retrofilling HFC 404A with one of 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 refrigerant for plant maintenance until 1st January 2030.

Purchase of bulk refrigerant and pre-charged systems

EU F-Gas Regulations – Refrigeration, Air-Conditioning & Heat Pump Contractors


 

NEW: HFC refrigerants shall only be sold to and purchased by certified undertakings or undertakings that employ certificated personnel. This means that refrigerant suppliers will require evidence that contractors are certified or qualified to make the purchase. You should contact your refrigerant suppliers to confirm what new requirements they plan to introduce – it is likely to be evidence based on your Company F-Gas Certificate.

NEW: Non-hermetically sealed equipment pre-charged with HFCs (e.g. split system air-conditioning
units) can only be sold to end-users where evidence is provided that the installation will be properly
carried out by a suitably qualified contractor.

 

Any RACHP 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.

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 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 may be used in any refrigeration equipment, by any qualified person.

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).