Q&A from Industry Update webinar 16 September 2020

Q: Has there been a large number of sales in 2020 for reclaimed refrigerant over 2,500 GWP?

 

A: Demand for Reclaimed GWP>2500 Refrigerant has been stronger than expected. This suggests that there is still a lot of equipment running on these refrigerants that could be converted to lower GWP alternatives. We would recommend that systems continue to be converted so that sufficient reclaimed product continues to be available for harder to convert systems.

 

Q: What about maintenance such as coil cleaning and related servicing for energy savings and emissions reduction?

 

A: We mentioned during the presentation that regular maintenance and cleaning is important to keep equipment running efficiently. Our Frionett range of cleaning and maintenance products are well proven to be effective and easy to use.

 

Q: Any advice on CE to UK CA marking time scale with regard to protracted trade talks for BREXIT?

 

A: This probably is a question better answered by equipment manufacturers and trade associations. We understand that it will be possible to continue to use the CE mark next year and the UKCA mark from 1st January 2021. Below is some guidance and links that have been provided by BEIS:

 

The Government has published its guidance and standstill procedures regarding the introduction of the UKCA mark. We are aware that this is a clear concern for UK companies and there has been significant representations made to government to clarify the marks introduction.

 

The links are below with full details of the announcement – which covers the status of UK CABs at the end of the transition period.

 

https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain-from-1-january-2021

 

https://www.gov.uk/guidance/placing-manufactured-goods-on-the-eu-market-from-1-january-2021

 

https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021

 

https://www.gov.uk/guidance/conformity-assessment-bodies-change-of-status-from-1-january-2021

 

The top lines are essentially a 12 month period of continued recognition of CE marking and EU conformity assessment (more in a few OGD sectors such as medical devices and transportable pressure equipment) and a 24 month period (so 12 months beyond the end of recognition of CE marking) during which we are saying that the UKCA mark is mandatory but for a majority of goods can go on a sticker or accompanying document to help manufacturers with concerns about e.g. changing tooling.

 

However businesses will be encouraged to use the new UKCA mark and regime as soon as possible after 1 January 2021 and the expectation is businesses should start preparing now for its introduction.

 

Q: The government stated that they will follow Kigali and Kigali has no quota but a more flexible timeline which will counteract the illegal issue

 

A: Afraid this is not the case, whilst the Government have signed up to Kigali, the UK Government has said that the current F-Gas regulations will continue to apply in the UK after the end of the Brexit transition period on 1st January 2021. As mentioned in the Webinar, the UK is in the final stages of setting up its own quota system that will apply in the UK. Kigali also has HFC phase down steps just like F-Gas but they are at a different timeline which merge in 2030 and go further beyond 2030.

 

Q: The EU has confirmed the abuse they found with the quota? and will be revised by the end of this year. In reality, we in the UK will be better for us to follow the Montreal / Kigalli?

 

A: The EU are making big efforts to tackle illegal imports, which is starting to have an effect in countries most affected by illegal product. No changes are being made to the EU F-Gas Regulation at the end of this year. The EU Commission has just opened a public review period for the current F-Gas regulation. They are hoping to publish proposals for amendments in Q4 2021 with a view to having F-Gas mark 3 in place by 2023. As the UK will not be part of the EU, it will not be obliged to follow any amendments, although it is expected UK changes will be very close to those made by the EU.

 

Q: What is the short to medium term future for refrigerants such as R448A/R449A that are relatively high in GWP compared to HFO and natural refrigerants?

 

A: R-448A and R-449A have allowed us to be able to meet the phase down requirements of F-Gas by being able to easily move away from R-404A for both new and existing equipment. However, as we move through the phase down steps of F-Gas these two refrigerants should only be considered as retrofit options to replace higher GWP refrigerants or for use in new equipment where a non-flammable option is essential. For all other new equipment applications, where it is practical and follows standards such as EN378, much lower GWP refrigerants should be selected such as R-454A, R-454C or R-455A.

 

Q: Not so much a question but looking at heat pumps the suppliers all seem to still be using R410A which you have previously advised there is no retrofit and product we should be reducing. Very confusing to say the least

 

A: Heat pumps are coming to market using much lower GWP refrigerants such as R-454B and R-32. In the future they may also use R-1234ze, R-454C and R-455A and a heat pump using R-744 has just been launched. The use of R-410A with a GWP of 2088 going forward in new heat pumps is unsustainable in terms of their environmental credentials, but also from an F-gas point of view. In terms of retrofitting R-410A there is a product called R-470A which has the potential to be an option, but there is currently very limited field experience with this product.

 

Q: Do you think that the increased focus on energy efficiency and overall life cycle costs will impact further adoption of CO2 systems

 

A: In a number of applications the low GWP HFO blends demonstrate better energy efficiency and life cycle costs. Exactly how that will impact on the use of CO2 systems by those who have already chosen to go down that route remains to be seen. There is still a very large bank of equipment that was originally on R-404A that will be replaced over the next 10 years. We believe there will be a mix of both technologies used, although energy efficiency considerations will need to be taken into account.

 

The questions raised and answered on the day of the webinar can be viewed on the recording here.