As of January 1st 2020, a new ban, introduced by EU Regulation 517/2014 – aka F-Gas Regulation – has become effective. It concerns refrigerants with GWP of 2500 or higher (essentially: R404A, R507, R422D) and deliberates:
- the RESTRICTION OF USE in NEW SYSTEMS, i.e. the prohibition to market new refrigeration equipment containing such refrigerants. The ban applies to commercial refrigerators and freezers (hermetically sealed) and stationary refrigeration systems (except uses at below 50 °C)
- the BAN for MAINTENANCE, i.e. the prohibition to use these virgin refrigerants for maintenance or assistance in existing systems with a refrigerant charge greater than 40 ton CO2. Below this limit (e.g. for circuits containing less than approx. 10 kg of 404A), the ban does not exist. The ban on using virgin R404A still holds, for the first charge (see 1).
With respect to the maintenance of systems over 40 tons CO2 eq., this means that stocks already accumulated cannot be used, even if purchased prior to January 1, 2020.
The maintenance of equipment that are in operation and use such refrigerants can ONLY and EXCLUSIVELY be done using recycled or regenerated refrigerants (until 2030). Basically, high GWP refrigerants will be disappearing from the market and this process has already started.
The ban is one of the stages foreseen by EU Regulation no. 517/2014, which entered into force on 1 January 2015 and is implemented by the European Commission to achieve 79% reduction in the use of HFC by 2030 (compared to the reference period 2009-2012). This regulation is part of a wider framework of measures adopted by the European Commission to achieve the European Union’s climate objectives of reducing greenhouse gas emissions by 80-95% compared to 1990 levels by 2050, in order to limit climate change and an average temperature rise of 2 °C compared to pre-industrial levels.
The Tools of the F-Gas Regulation
To achieve its objectives, the F-Gas Regulation adopts the following measures:
- measures regarding the containment, use, recovery and destruction of fluorinated greenhouse gases and related ancillary measures;
- measures that limit the marketing of products and equipment that contain or whose operation requires fluorinated greenhouse gases;
- measures that regulate specific uses of fluorinated greenhouse gases;
- measures that limit the quantities to market hydrofluorocarbons.
It is worth noticing that the new regulation emphasizes the concept of GWP i.e. the impact of the refrigerant in terms of greenhouse effect. This becomes the basis for the prohibitions imposed by the Regulation and for the calculation of the quantities of refrigerant, not as kg mass but as ton of CO2 equivalent.
What to do?
When it comes to maintaining systems that are currently in operation and use R404A/R507A:
- for small power plants with a refrigerant charge smaller than 40 equivalent CO2 (i.e. about 10 kg of R404A/R507A), it is possible to continue as it is done today, while taking into consideration the limited availability and high price of the coolant;
- in all other cases, after January 1, 2020, one is to choose between:
- replacing the equipment with new ones that use natural refrigerants or other synthetic refrigerant that meets the GWP limits;
- modifying/adapting the equipment, if technically possible, so as to use a refrigerant with a GWP smaller than 2500; replacing it entirely and disposing of it, following to the law;
- keeping the equipment while operating and servicing it exclusively with regenerated refrigerant (the use of which will be provided until 31.12.2029).