Fluorinated gases used in refrigeration and air conditioning equipment have a global warming potential that exceeds CO2 by up to 25,000 times. Moreover, some of these gases could remain in the atmosphere for thousands of years. Therefore, due to their high environmental impact, they are included in the category of greenhouse gases (GHGs). Taking into account these factors, the European Union implemented the first fluorinated gas or F-Gas regulation in 2006. This regulation focused on preventing leaks during operation and at the end of the lifespan of fixed equipment. However, it also included prohibitions on the use of these gases in a limited number of applications.
In 2015, Regulation (EU) No 517/2014 on fluorinated gases came into effect, replacing and expanding the scope of the 2006 Regulation. Thanks to this legal framework, emissions of fluorinated gases have been decreasing since 2016, with a significant 12.2% reduction from 2019 to 2020. Currently, fluorinated gases represent 2.5% of total GHG emissions in the EU. However, aware of the need to adapt and strengthen environmental measures, the European Commission presented a proposal for revision in April 2022. This initiated a significant process that deserves our attention and understanding.
European Commission Proposal for the Revision of the Fluorinated Gas Regulation
On April 5, 2022, the European Commission proposed an ambitious plan aimed at further reducing emissions of fluorinated gases. The most notable change is the gradual reduction of the supply of hydrofluorocarbons (HFCs) to the Union market, reaching a modest 2.4% of 2015 levels by 2048. This measure is a direct response to the disproportionate global warming potential of these gases and their contribution to climate change.
In addition to the supply reduction, the proposed revision of the fluorinated gas or F-Gas regulation includes specific prohibitions in various applications. It also incorporates substantial updates to standards related to best practices, leak control, record-keeping, training, waste treatment, and penalties. This comprehensive approach aims to address not only the direct emission of fluorinated gases but also related aspects affecting their environmental impact.
Objectives of the Proposal and Anticipated Benefits
The Commission’s proposal has several key objectives. Firstly, it seeks to align EU legislation with the Montreal Protocol. Recall that this agreement focuses on a net reduction of GHG emissions by 55% by 2030 and climate neutrality by 2050. This condition, in addition to meeting international commitments, also reinforces the Union’s leadership position in environmental matters.
The proposal is expected to result in a significant reduction in fluorinated gas emissions, approximately 40 million tonnes of CO2 equivalent by 2030 and 310 million by 2050. These figures are crucial for surpassing reductions from the current Regulation and addressing illegal activities through changes in the existing quota system.
European Parliament Response to the Proposal for the Revision of the Fluorinated Gas Regulation
Upon receiving the proposal, the European Parliament, through its Committee on Environment, Public Health and Food Safety, issued a report on March 1, 2023. This report, approved with sixty-four votes in favor, eight against, and seven abstentions, reflects the Parliament’s commitment to stricter measures and decisive action.
Among the key amendments, the report reinforces requirements for marketing products containing fluorinated gases, emphasizing the prohibition of their use in sectors where viable alternatives exist both technologically and economically. This restriction extends even to the heat pump sector, demonstrating the Parliament’s determination to explore and favor more sustainable options.
The report also establishes stricter dates for the discontinuation of marketing certain fluorinated gases and products containing them. Starting in 2039, the pace of the gradual reduction in the marketing of HFCs will be faster, reaching zero by 2050. Additionally, the Commission is required to continuously monitor technological developments and the market related to the use of fluorinated gases and natural alternatives.
As an additional step, the report proposes the introduction of minimum administrative fines for non-compliance from the implementation of these measures. Apart from setting higher standards, the aim is also to ensure their effective enforcement.
Provisional Agreements on the Revision of the Fluorinated Gas Regulation
According to the provisional agreement reached in October 2023, there will be a gradual phase-out of the production and consumption of HFCs. In the case of production, the reduction will be in terms of production rights assigned by the Commission. Simultaneously, HFC consumption will follow a downward trajectory based on a strict schedule that establishes decreasing quota allocations. These measures, stricter than the Commission’s initial proposal, reflect the commitment of European lawmakers to urgently address climate change.
The agreement also introduces higher quota allocations for the first two periods compared to the Commission’s proposal. This adjustment aims to balance the transition towards more sustainable alternatives and ensure a gradual adaptation of the industry.
Schedule for the Reduction of Production Rights and HFC Marketing Quotas
Specifically, the percentage reductions in the production rights of hydrofluorocarbons for each producer are set in comparison to the annual average of their production between 2011-2013. The reduction schedule, with its quotas, is as follows:
- Between January 1, 2025, and December 31, 2028: 60% reduction.
- From January 1, 2029, to December 31, 2033: 30% reduction.
- For the period between January 1, 2034, and December 31, 2035: 20% reduction.
- From January 1, 2036, onwards: 15% reduction.
While the maximum quantities of HFC marketing quotas on the market will decrease as follows:
|Maximum Quantity in Tonnes of CO2 Equivalent
|2025 – 2026
|2030 – 2032
|2033 – 2035
|2036 – 2038
|2039 – 2041
|2042 – 2044
|2045 – 2047
|2048 – 2049
It is important to note that, despite the firmness of these agreements, strategic exemptions have been introduced. Semiconductors, for example, will be exempt from the HFC quota allocation system, offering flexibility in sectors where the viability of alternatives may require a more detailed assessment.
Furthermore, the progressive elimination of HFC consumption and the need for HFCs in specific sectors will be reviewed in 2040. This review will consider technological advances and the availability of alternatives, allowing adjustments according to the evolution of the environmental and technological landscape.
Prohibitions on Marketing in the Updated Fluorinated Gas Regulation
At the same time, the provisional agreement introduces a total ban on the marketing of various categories of products and devices containing HFCs. This includes domestic refrigerators, coolers, foams, and aerosols. Additionally, some deadlines for the ban are advanced, and they are extended for products using fluorinated gases with lower atmospheric warming potential.
Exemptions to the ban are considered in cases where safety issues exist, demonstrating the legislators’ prudence in addressing the complexities of the shift to more ecological technologies.
On the other hand, the agreement in question establishes specific prohibitions for heat pumps and air conditioning equipment. For heat pumps and small monoblock air conditioning equipment (<12 kW) with fluorinated gases of high atmospheric warming potential, a total ban will be implemented from 2027, with complete elimination in 2032. For two-block systems, the total ban will come into effect in 2035. However, deadlines will be earlier for certain types of systems with higher atmospheric warming potential.
Exemptions will be granted in cases where the equipment is necessary to meet safety requirements. Additionally, the agreement also considers the possibility of releasing additional quotas related to heat pumps to avoid negative impacts on the implementation goal of heat pumps within the framework of the REPowerEU program.
Regarding medium and high voltage switchgear dependent on fluorinated gases, a gradual prohibition is established until 2032. This is made possible through the introduction of a cascade use principle that allows exceptions based on the bidding of alternatives without fluorinated gases. High-voltage switchgear could use SF6 – a powerful GIS – as a last resort under this principle, with safeguards in place to prevent the prohibitions from affecting the operation of electrical networks.
At Intersam, we are ahead of the revision of the fluorinated gas regulation
For business owners and executives, adapting to the new restrictions resulting from provisional agreements is critical. With the total prohibition of the marketing of products and devices containing HFCs, including domestic refrigerators and heat pumps, companies must reassess their product lines and explore more environmentally friendly alternatives. Anticipation is key. Identifying and adopting technologies and products that meet emerging environmental requirements will ensure business continuity and position companies at the forefront of sustainable industrial refrigeration.
For all these reasons, at Intersam, we are ahead of the F-Gas review. We have been using environmentally friendly refrigerants with low atmospheric warming potential, such as A2L and CO2, in the industrial and commercial refrigeration systems we develop. If your company or project needs to adapt its refrigeration and/or air conditioning structure to the updated fluorinated gas regulation, contact us now. We are capable of handling large-scale projects within and outside of Spain.