What’s your refrigerant strategy? It’s time to make your move

 

In the RACHP industry the legislative landscape for refrigerants has been changing on a regular basis since the adoption of the Vienna Convention for the protection of the ozone layer in 1988, and the introduction of the first regulation to control the use of chlorofluorocarbons (CFCs) in 1991. So why is the current round of legislative update causing a degree of concern and confusion? For the first time since refrigerant legislation was introduced, Great Britain (GB) will have different legislation to the European Union (EU). Even more confusing, due to the complexities of the Brexit agreement, Northern Ireland (NI) will have to follow the EU legislation. Whilst the EU has already drafted, agreed and implemented the next iteration of F-Gas legislation, all of us in GB are still waiting to see the draft proposal that will govern the decisions on how our industry will have to operate in the future.

 

There is already one certainty, the GB legislation will be different to the EU legislation!

How can we be so certain? Under the EU regulation 2024/573, from 1st January 2025 there is a reduction (in terms of carbon dioxide equivalents) of the quantity of HFCs that can be placed on the market (often referred to as ‘the quota’), a new category of equipment is defined as ‘self-contained’ and there are restrictions for new equipment that limit the refrigerant GWP to <150 in stationary refrigeration self-contained systems. Since there is no new legislation in GB, none of these measures will be introduced as GB is still following the EU 517/2014 retained legislation.

When there appears to be a lack of clarity it’s all too easy to kick the proverbial can down the road, however there is information available which does take away some of the guess work and should put you on the track of a sustainable future.

 

What do we know and how can that help us to make informed decisions?

 

HFC Quota Reduction

There is no reduction in GB quota in 2025. At least in theory, this means that within GB the same quantity of the same refrigerants that were available in 2024 should be available in 2025, but don’t let this lull you into a false sense of security. GB is still following a HFC phasedown, and this will eventually lead to a restriction in the availability of virgin high GWP (>1000) products, probably before the end of the useful lifetime of any new equipment installed today. Choosing a low GWP refrigerant option today would be a very wise decision and avoid the need to rely on uncertain future supplies of reclaimed refrigerant.

 

GB has already agreed to an extended HFC phasedown, in addition to continuing to follow the EU 517/2014, the Kigali amendment to the Montreal Protocol became UK law in 2019 and extends the phasedown to 2036. A report published in December 2022 by the Department for Environment Food & Rural Affairs (Defra) predicted that without a proactive move to low GWP refrigerants, the demand for refrigerants in GB is likely to exceed the quota allowance by the year 2027 (Figure 1), which could lead to availability issues for higher GWP refrigerants (>1000). Choosing a <1000 GWP refrigerant today would avoid any potential supply issues that may occur in the near future.

 

Will GB follow the EU HFC phase-out? At this point it’s difficult to know but there have been several comments attributed to Defra officials stating that the Kigali amendment is seen as an ambitious phasedown, so it’s very possible that GB will follow its own HFC phasedown.

 

 

Figure 1- Possible phasedown scenarios from December 2022 Defra assessment report

 

Placing on the Market Prohibitions

In the main, placing on the market prohibitions affect new equipment that is manufactured in or imported into GB. 1st January 2025 saw the last of the EU 517/2014 prohibitions introduced (<3kg split air conditioning (AC) must use <750 GWP) but the EU regulation has many new restrictions covering stationary refrigeration, split AC and heat pumps (HP), self-contained AC/HP and chillers. The first of these come into effect in the EU on 1st January 2025 but they do not apply to GB unless a manufacturer is exporting to the EU or NI, in which case the equipment will have to be EU compliant.

 

As with the phasedown, there is no confirmed information on what new prohibitions may be introduced for the GB market but there have been comments from Defra officials indicating that the phasedown is the preferred method of controlling HFC use in GB, with a recognition that the EU placing on the market prohibitions may be necessary as the UK market will be impacted directly.

 

Training

Within the current GB legislation there is only a requirement to obtain certification if you are handling F-Gases. The EU legislation has recognised this deficiency and has stipulated that training and certification is also mandatory when handling non-F-Gas refrigerants. In addition, refresher training and certification must be taken at least every 7 years. These measures have been broadly welcomed by the industry and many British industry associations, via the Air Conditioning and Refrigeration Industry Board (ACRIB), are encouraging the government to ensure any new legislation in GB also addresses the training needs for the industry.

 

Be Prepared

Although there is still no confirmed detail of what the new GB F-Gas legislation will contain, the direction of travel is very clear. Even if GB stays with the current EU 517/2014 and subsequent Kigali Amendment phasedown schedules, the industry must move to <1000 GWP refrigerant options within the next few years. In addition, any equipment which is either imported from the EU or exported to the EU or NI markets will need to be compliant with the EU F-Gas legislation, which over the next 10 years will practically exclude >750 GWP refrigerants from most applications, including the use of virgin refrigerants for maintenance requirements.

 

Table 1 - Some examples of commercially available low GWP refrigerants

Low GWP Refrigerant

GWP (AR4)

Alternative to

Typical applications

R-1234yf

4

R-134a

Plug-in cabinets, chillers, MT refrigeration, transport, heat pumps

R-1234ze(E)

7

R-134a

Chillers, MT refrigeration, heat pumps

R-290

3

R-404A/R407C

Plug-in cabinets, chillers, heat pumps

R-32

675

R-410A

Air conditioning, chillers, heat pumps

R-450A

605

R-134a

MT refrigeration, heat pumps

R-454A

239

R-404A

Direct expansion MT/LT refrigeration

R-454B

466

R-410A

Air conditioning, chillers, heat pumps

R-454C

148

R-404A

Direct expansion MT/LT refrigeration, heat pumps

R-455A

148

R-404A

Direct expansion MT/LT refrigeration

R-513A

631

R-134a

Chillers, MT refrigeration, heat pumps

R-515B

293

R-134a

Chillers, MT refrigeration, heat pumps

R-717

0

R-134a/R-404A

Industrial refrigeration

R-744

1

R-404A

Commercial and Industrial refrigeration

 

There is already a wide range of low GWP refrigerant options available, and the availability of suitable equipment is growing rapidly, so why is the switch to low GWP taking so long? Many of the low GWP options either have a degree of flammability, very high pressure or are toxic. For those in the industry that have been only dealing with non-flammable low toxicity refrigerants this can be quite daunting, but there is a lot of support and training available to those who need it or for those who just want the reassurance that their knowledge and skills are adequate.

 

Many of those who have already set off on this journey to low GWP have found it less difficult than they imagined with many of the requirements needed, e.g. EN 378, PE(S)R, DSEAR, just being an extension of what was already required with the current refrigerants. If you are still sitting on the fence then help is always available from refrigerant experts like Climalife who can provide refrigerant performance comparisons, EN 378 guidance, PE(S)R and of course the latest F-Gas updates.

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