Fgas, the clash between ideas and reality

Headquarters of the European Parliament in Brussels
Headquarters of the European Parliament in Brussels

On March 1st, ENVI Commission voted on a series of amendments that further force the already further restricted margins of use of gases with GWP lower than 750 or 150 contained in the text under examination by stakeholders since April 5th 2022, the submission date of the first revision of the Fgas Regulation.
The Commission’s initiative is very neat: the amendments proposed are fundamentally intended for giving up the use of fluorinated gases quickly, generating the preliminary conditions for a transition to non-patented alternative gases that is very excited from both the industrial point of view and of installed machines’.

List of the expected deadlines
Starting from January 1st 2024
– Forbidden use of fluorinated gases for new refrigerators and new commercial stationary built-in freezers (in all other built-in refrigeration appliances starting from January 1st 2025);
– Forbidden use of fluorinated greenhouse effect gases with a GWP equal to or higher than 2,500, also for the appliances intended for applications aimed at cooling products at temperatures under – 50°C. The current exemption is not justified from the environmental point of view, according to the Supervisor and discourages these sectors from using HFC with low GWP and non-fluorinated alternatives.

Starting from January 1st 2025
– Forbidden use of fluorinated gases in new appliances for the domestic refrigeration
– Forbidden use of fluorinated gases in new residential air conditioning appliances and plug-in built-in heat pumps. In the opinion of the Supervisor, many manufacturers of these appliances are already oriented to the safe efficient use of propane in the European Union’s market and moreover dozens of models are available on the European market: some big manufacturers are planning to increase the production
– Forbidden use of fluorinated gases in mono-split systems containing less than 3 kg of greenhouse-effect fluorinated gases.

Starting from January 1st 2027
– Forbidden use of fluorinated gases with GWP equal to or higher than 750 in split systems with nominal capacity ranging from 12 to 200 kW, except when required to satisfy safety standards
– Forbidden use of fluorinated gases in split systems with nominal capacity exceeding 200 kW. Exceptions are admitted when it is necessary to satisfy safety standards. The Supervisor states that with the recent adoption of the IEC-60335-2-40 regulation, which increases flammable refrigerants’ charge limits, all requisites for split systems up to 12kW can be satisfied by propane. In split systems with power exceeding 200 kW, ammonia and CO2 are available alternatives.
– Forbidden use of fluorinated gases for the refrigerated transport in vans, trucks and trailers, ships and refrigerated containers. According to the Supervisor, refrigeration units for transport are affected by high loss rates and a scarce recovery of the refrigerant at life end, making this sector important for a urgent action to face the emissions of fluorinated gases. Alternatives already exist on the market, but their adoption has been slow.

The appeal of the supply chain
However, the vote was preceded by numerous cries of alarm, which merged into a joint initiative of twelve associations whose acronyms have the undisputed capability of giving floor to the whole supply chain, involving almost all interlocutors in a co-signed letter that intended to summarize the substantial and articulated fears caused by the further tightening that the ENVI Commission wanted to impose to the Regulation.
The outcry was plenary: Eurovent, EPEE, AREA, Applia, Japan Business Council in Europe, ASERCOM, EFCTC, EHPA, EPFA, Sme United, Jraia and Agoria have signed an appeal to the Commission to take into account the impact that proposed amendments, in particular those corresponding to the numbers 10, 11, 13, 14 and 21 to the F-gas regulation in processing phase might generate on the market and on the whole system, in a global vision that encompasses aspects connected with gases, the overall environmental impact, energy efficiency and safety. In this letter, some particularly problematic elements have already been underlined and might be summarized as follows:
• The corrections to the text propose percentage levels for HFC that cannot support the service requirements of the existing appliances or the introduction of new high energy efficiency heating and cooling appliances;
• The demand for banning Fgas is submitted “in unfeasible way”, without a proper consideration of key aspects such as safety, applicability, energy efficiency and costs;
• The proposed text does not consider the critical essential requisites of training and certification for installation and service technicians, the majority of them coming from small enterprises;
• The setup includes quota schemes that will disincentivize the production within the EU;
• The text authorizes the Commission to adapt the modifications to the regulation without crossing the whole legislative process.
The letter has been accompanied by highly concerned declarations by outstanding names, who intended to emphasise the state of extreme difficulty in which is realistic to position the market if the definitive Regulation will make room for these amendments.