The F-Gas Regulation and its requirements for operators

The previous F-Gas Regulation (EU) No. 517/2014 reduced the maximum quantity and the corresponding quota for the placing on the market of F-gases in accordance with Article 15 (1) to 31 % from 2024. From 2025, there will be a further reduction to 24.3% due to the current successor regulation. This will lead to a further significant shortage of F-gases.

The amended version of the F-Gas Regulation (German only) was published in the Official Journal of the European Union on February 20, 2024 (Regulation (EU) 2024/573 of the European Parliament and of the Council of February 7, 2024). The amended F-Gas Regulation enters into force on the 20th day after its promulgation, i.e. on March 11, 2024. This regulation is binding in all its parts and applies directly in every Member State. Its key points include an accelerated phase-down of F-gases to zero in 2050 and a ban on the placing on the market of stationary refrigeration systems with F-gases with a GWP above 150 from 2030. Special regulations apply to chillers (liquid chillers), air conditioning systems and heat pumps (including split systems).

This basically replaces the F-Gas Regulation (EU) No. 517/2014.

Among other things, this regulation:

• Establishes rules for the containment, use, recovery and destruction of fluorinated greenhouse gases and related ancillary measures
• Imposes restrictions and prohibitions on the marketing of specific products and equipment that contain, or whose functioning relies upon, fluorinated greenhouse gases
• Imposes usage restrictions for certain fluorinated greenhouse gases, e.g. during maintenance and service
• Establishes further quantitative limits for the marketing of hydrofluorocarbons (“phase down”). Gradual reduction to 24.3 % from 2025, 12.3 % from 2027, 5.2 % from 2030, then further reductions to 0 % from 2050 (compared to the reference value from 2015 in tons of CO₂ equivalents).

The new regulation establishes a raft of restrictions and bans for designers, manufacturers, importers and operators of commercial and industrial air-conditioning, refrigeration and heat pump equipment that uses fluorinated refrigerants. Some of the provisions in the regulation were implemented several years ago, while other provisions will be phased in over the next few years.

This article provides an overview of the most important provisions of the new regulation. It is designed to help you comply promptly and effectively with the F-Gas Regulation provisions that apply to you.

What is the significance of the F-Gas Regulation?

The F-Gas Regulation (EU) 517/2014 came into force on January 1, 2015 and is stricter than the previous F-Gas Regulation of 2006. It applies in all European Union member states and is part of the European roadmap to a low-carbon economy. Its central goal is to significantly reduce fluorinated greenhouse gases in order to protect the climate and environment.

Key content of the Regulation

The revised regulation is essentially aimed at gradually reducing the emissions of the available newly used hydrofluorocarbons and/or their global warming potential (GWP) in the EU to the target value of 0 % from 2050.

In particular, the regulation is intended to create an incentive to use alternatives instead of F-gases.

Three main regulatory approaches will be followed to reduce F-gas emissions:

1. Introducing a phase-down of the quantities of hydrofluorocarbons (HFCs) available in the market.
2. Phased-in bans on the use and marketing of F-gases.
3. Retaining or supplementing regulations on leak checks of refrigeration, air conditioning systems and heat pumps, certification, disposal and labeling.

• To the table of contents

What gases are covered by the F-Gas Regulation?

The F-Gas Regulation generally covers the following classes of fluorinated greenhouse gases: HFCs (hydrofluorocarbons), PFCs (perfluorocarbons) and SF6 (sulfur hexafluoride) as well as HFOs (hydrofluoroolefins). However, the new regulation’s measures do not apply to all F-gases. The all-important phase-down, for instance, applies to HFCs but not to PFCs and SF6, which are covered by other provisions in the regulation.

Synthetic refrigerants based on HFCs covered by the regulation and used in refrigeration, air-conditioning and heat pump equipment and systems include the refrigerants:

• R-134a (GWP 1,430)
• R-407c (GWP 1,744)
• R-410a (GWP 2,088)
• R-404a (GWP 3,922)
• R-507 (GWP 3,990)
• R-32 (GWP 675)
• R-449A (GWP 1,397)
• R-513A (GWP 631)
• R-452B (GWP 698)
• R-454C (GWP 148)

HFO-based refrigerants (such as R-1234yf) are now also covered by the F-Gas Regulation. The expert knowledge requirements according to Art. 10 and the obligations for regular leak checks according to Art. 5 also apply to systems with HFO refrigerants.

• To the table of contents

The phase-down: gradual reduction of refrigerant quantities

A key component of the previous and revised F-Gas Regulation is the phase-down, a detailed roadmap that requires EU member states to gradually reduce available virgin synthetic refrigerants by 79 percent each year from 2015.

The current F-Gas Regulation now provides for a complete phase-out of hydrofluorocarbons (HFCs) by 2050, including a timetable for reducing the EU consumption quota between 2024 and 2049.

Specifically, the goal is to reduce the F-gases used and/or their global warming potential (GWP) in the EU - starting from the 2015 baseline of around 176 million tons of CO₂ equivalent - to 24.3 % from 2025, 12.3 % from 2027 and gradually down to the target value of 0 % from 2050. “CO₂ equivalent” is the unit of measure for the calculation: The reduction in new F-gases is not quantified in metric tons but in a number that describes the F-gases’ global warming potential (GWP). The GWP number is specified in kilograms of CO₂ equivalents.

Each refrigerant has a specific GWP value. For example, “x kg CO₂ equivalents” means: The increase in the greenhouse effect from emitting one kilogram of refrigerant is equal to the increase from emitting x thousand kilos of CO₂ from burning oil or gas in a heating system.

Calculate the GWP value now:

• How GWP values are calculated

The phase-down affects the industry’s entire value chain, from manufacturers to users. First, equipment manufacturers, importers and distributors (wholesalers) have to report the previous quantities of refrigerants that they have used to the EU. This information is then used to allocate certain restricted quantities of refrigerants (measured in metric tons of CO₂ equivalents) to companies in future years.

These phase-down-compliant quantities may then be put into equipment or given to certified professionals performing service and maintenance work on equipment and systems. This drastic new measure will force manufacturers and users to switch to lower-GWP refrigerants

• To the table of contents

¹ Base value 2015: 176,700,479 t CO2 equivalent
² Reference value: annual average 2009-2012

Maximum HFC consumption – CO₂ equivalent (in %)

The 100% baseline represents the estimated average GWP in 2015 and corresponds to the average consumption between 2009 and 2012.

The phase-down will affect plant operators in various ways, too. It will reduce the amount of HFCs available in the market in the future, which will likely increase prices significantly. Also, alternative refrigerants will probably be used more, especially in systems operated with refrigerants that are slated to be banned.

However, most of these alternative refrigerants are flammable and/or have other properties that require special consideration. Users and operators will thus have to face new requirements and regulations designed to ensure the safe, efficient and compliant handling of these substances in the foreseeable future.

• To the table of contents

Key duties for refrigeration system operators

The F-Gas Regulation imposes numerous obligations on system operators, including leak checks and proper record-keeping and recovery. In addition, operators must only employ certified personnel for installation and commissioning as well as operation, maintenance, repair and decommissioning. The operator’s obligation to verify that the companies and individuals it hires have the necessary expertise to work on refrigerant-containing systems is one of the key provisions of the F-Gas Regulation.

Operators should take care to only hire refrigeration system designers and builders who can advise them on all the implications of the F-Gas Regulation from the start.

• To the table of contents

Leak checks

Operators of systems containing a certain amount of CO₂ equivalents of fluorinated greenhouse gases (that are not included in foams) have been required to have their systems checked for leaks in specific intervals. The specific number of leak checks depends on the refrigerant charge in the equipment. Systems must be checked for leaks in the following intervals depending on the CO₂ equivalents per refrigeration cycle.

Operators of stationary refrigeration systems, air conditioning systems and heat pumps that contain refrigerants based on HFCs and/or HFOs are generally affected. The revision of the F-Gas Regulation now also obliges operators and manufacturers of mobile equipment (e.g. refrigerated trucks, refrigerated containers, refrigerated wagons, air conditioning systems in commercial vehicles, machines, trains, subway trains, streetcars) to carry out regular leak checks (in some cases only from 13.03.2027).

For systems with HFC refrigerants (fluorinated greenhouse gases according to Annex I of the Regulation):

• from 5 to < 50 metric tons (or 10 to 50 metric tons for hermetic systems) of CO₂ equivalents per refrigeration cycle: every 12 months, or every 24 months if a leak detection system is installed
• from 50 to < 500 metric tons of CO₂ equivalents per refrigeration cycle: every six months, or every 12 months if a leak detection system is installed
• from 500 metric tons of CO₂ equivalents per refrigeration cycle: every three months, or every six months if a leak detection system is installed

For systems that contain F-gases in accordance with Annex II of the Ordinance (including HFO refrigerants), the current revision of the F-Gas Ordinance has set limits for filling quantities:

• from 1 to < 10 kg (or from 2 kg to < 10 kg for hermetic systems) per refrigeration circuit: every 12 months, or every 24 months if a leak detection system is installed (in hermetic systems in residential buildings, the obligation only applies from 3 kg of fluorinated greenhouse gases)
• from 10 to 100 kg per refrigeration circuit: every six months, or every 12 months if a leakage detection system is installed
• from 100 kg per refrigeration circuit: every three months or every six months if a leakage detection system is installed

From 500 tons CO₂ equivalent for HFCs or from 100 kg HFO, leakage detection systems are mandatory.

• To the table of contents

Record-keeping obligations

The F-Gas Regulation requires refrigeration system operators to keep records of legally mandated leak checks. The records must be retained by the system operator and the personnel or company performing the checks for at least five years.

Records are generally required for systems that require leak checks. They must contain the following information:

• Quantity and type of F-gases
• All quantities of F-gases added during activities such as installation, maintenance, servicing or leak response
• Name and address of the recycling or reclamation facility (with certificate number, if applicable) if recycled or reclaimed F-gases are used
• All quantities removed and reclaimed
• The company that worked on the equipment (with certificate number, if applicable)
• Times and results of leak tests, inspections (retesting), repairs
• If the system is decommissioned: measures taken to recover and dispose of the fluorinated greenhouse gases

• To the table of contents

Recovery obligations

Operators of stationary equipment that holds fluorinated greenhouse gases not contained in foam shall ensure that the gases are properly recovered by certified individuals or entities prior to system disposal and, where necessary, during system service and maintenance. This ensures that the gases are recycled, reclaimed or destroyed.

Conclusion

The new F-Gas Regulation leads to current provisions and introduces new ones on the manufacture and operation of refrigeration, air-conditioning and heat pump equipment. However, the most important change is the drastic reduction in available CO₂ equivalents, which will result in serious changes in the use of refrigerants in refrigeration, air conditioning and heat pump equipment. The quota system (gradual reduction of marketed quantities each year to 24.3 % in 2025, 12.3 % in 2027) will likely produce a noticeable shortage of GWP-relevant refrigerants in upcoming years. The higher the GWP value of a refrigerant, the more tons of CO2 equivalent of the permitted annual quota are required. One kg of the refrigerant R 410A (GWP 2088) corresponds to 2.088 tons of CO2 equivalent, while 1 kg of R 32 (GWP 675) corresponds to 0.675 tons.

For this reason, operators should not wait until the last minute to have their systems professionally maintained and/or modified to accept alternative refrigerants under the F-Gas Regulation. Certain refrigerants will be completely banned in new systems in the future. For example, the production of systems that use R-404a/R-507 has been banned since 2020.

• To the table of contents

Your message to us

Do you have any questions? If so, simply fill out our contact form. We look forward to hearing from you!