Understanding CO2 Size Thresholds
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. 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 2014 Regulation makes use of various thresholds, using “CO2 equivalent”. This Information Sheet
provides guidance on how these new thresholds are defined and how they should be used.
A wide range of further guidance is available for other aspects of the EU F-Gas Regulation
Use of Size Thresholds in the F-Gas Regulation
Various rules in the F-Gas Regulation use a size threshold. Small equipment below a threshold might
not be affected, but above a certain size a relevant rule starts to apply. Thresholds are important as
it is not always cost effective or practical to apply certain rules to small equipment. The requirements
in both the 2006 and 2014 EU F-Gas Regulations that make use of a size threshold are:
a) Mandatory leak checks
b) Automatic leak detection systems
c) Record keeping
d) The refrigeration equipment Service Ban (2014 Regulation only)
e) Reporting on production, import and export of bulk F-Gases
From 2017 product and equipment labels must show the amount of F-Gas in a system expressed in kg
and in CO2 equivalent. This information must also be in instruction manuals and advertising material.
CO2 Equivalent (CO2e) Size Thresholds
In the 2006 Regulation, the thresholds were based on the quantity of F-Gas, measured in terms of the
mass of fluid (in kilograms). For example, mandatory leak checks were required on all refrigeration
and air-conditioning systems containing more than 3 kg of HFC refrigerant. The same kilogram
threshold applied to all refrigerant types. Under the 2014 Regulation the thresholds have been
changed to CO2 equivalent (CO2e). For example, the 3 kg leak checking threshold has been replaced
with a threshold of 5 tonnes CO2e.
What is “tonnes CO2 equivalent”?
Tonnes CO2 equivalent is calculated by multiplying the mass of gas (in tonnes) by the GWP (global warming potential) of that gas. GWP compares the global warming impact of a gas compared to that of CO2 (which has a GWP of 1). F-Gases have high GWPs.
For the purposes of the 2014 EU F-Gas Regulation, the GWPs to be used in these calculations are those from the UN IPCC 4th Assessment Report. For pure gases, these GWP values are listed in Annex I of the Regulation. Many refrigerant gases in common use are blends, and for these you can calculate
the GWP from the proportions and GWPs of the component pure gases.
Why has the change to tonnes CO2 equivalent been made?
The use of CO2e thresholds creates a lower kg threshold for F-Gases with a high GWP. This penalises those organisations that use high GWP gases and will encourage them to select equipment that uses F-Gases with the lowest practical GWP. This supports the objective of the F-Gas Regulation which is to minimise the global warming impact of F-Gas emissions. The size thresholds for the high GWP HFC 404A are considerably smaller under the 2014 Regulation than previously. The reporting thresholds for production, import and export of bulk product are more than 10 times lower than in the 2006 Regulation.
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).