Fluorinated GHGs: the challenges of the new regulation

As of January 1, 2015, the new European regulation on fluorinated greenhouse gases (GHGs) came into effect (Regulation (EU) No 517/2014 of April 16, 2014 - OJEU of May 20, 2014). The primary objective of this "F-Gas regulation" is to impose a gradual reduction in the quantities of fluorinated GHGs placed on the European Union market through restrictions on their sale and use.

Currently used in numerous industrial applications (primarily as refrigerants, insulating products, solvents, or fire extinguishing agents), fluorinated GHGs have a very high global warming potential, even though alternative technologies with equivalent efficiency and lower—or even zero—environmental impact already exist or are currently being developed. The measures included in the new F-Gas regulation are intended to accelerate the deployment of these substitute techniques and gases. Along with their suppliers and service providers, companies that use processes involving fluorinated GHGs will need to adapt quickly to these new HSE constraints, both for future investments and for the maintenance and monitoring of their existing equipment.

Context Overview

Fluorinated GHGs include:

• HFCs - Hydrofluorocarbons. These are used as refrigerants in refrigeration and air conditioning systems (e.g., HFC134a, HFC407c, HFC410a), as fire suppression gases (e.g., HFC227ea marketed as FM200®, HFC23 marketed as FR13®), as blowing agents in foams, and as solvents.
• PFCs - Perfluorocarbons. These are primarily used as fire extinguishing agents (e.g., PFC31-10 marketed as CEA410®) and as solvents.
• SF6 - Sulfur hexafluoride. This gas is used as an insulator in high-voltage electrical equipment (circuit breakers, switches, gas-insulated switchgear).

Targeted by the Kyoto Protocol, like carbon dioxide or methane, fluorinated GHGs account for only 2% of greenhouse gases emitted in the European Union, but they have a much higher global warming potential (GWP)[1] than carbon dioxide. For example, releasing 1 kg of HFC134a into the atmosphere has the same climate impact as 1,430 kg of CO₂, which is equivalent to driving a car for 10,000 km.

Atmospheric emissions of fluorinated GHGs occur during open-air use (such as aerosol sprays or solvents), but also through leaks that can occur in equipment containing them. According to the Ministry of Ecology, more than 6,000 tons of refrigerants escape from air conditioning, refrigeration, or heat pump equipment in France every year! This has a global warming impact equivalent to the annual CO₂ emissions of 6,900,000 cars!

Furthermore, the production and use of fluorinated GHGs have increased sharply since the early 1990s. Manufacturers have heavily favored the use of HFCs to replace ozone-depleting substances (ODS), such as CFCs (e.g., R12), HCFCs (e.g., R22), and halons, which were previously used as refrigerants and fire extinguishing agents and were being phased out under the 1987 Montreal Protocol.

However, while the reduction of ODS has successfully halted the depletion of the ozone layer, the concurrent development of fluorinated GHGs does not support the fight against global warming.

In this context, the European Union has decided to adopt a new F-Gas regulation aimed at reducing the quantities of fluorinated GHGs, particularly HFCs, and promoting their replacement with substances that have a lower climate impact. The requirements previously established by the former F-Gas regulation[2] to prevent leaks and fugitive emissions of fluorinated GHGs are also being maintained, with some adjustments.

Key changes introduced by the new F-GAS regulation

1) New restrictions on the placing on the market and use of fluorinated GHGs

First, gas producers, as well as importers of gas or pre-charged equipment, are subject to a new quota system designed to reduce the quantities of HFCs available on the market. The total quantity of HFCs that can be placed on the market will decrease gradually in 2- or 3-year increments. The goal is to reduce this quantity by 79% by 2030 compared to the 2009-2012 average. The reduction will already reach 37% by 2018!

Second, new bans on placing equipment on the market have also been defined. These bans include:

• As of January 1, 2016, fire protection equipment containing HFC-23
• As of January 1, 2020, stationary refrigeration equipment containing HFCs with a GWP ≥ 2,500 (e.g., HFC-404A), except for applications designed to cool products to temperatures below -50 °C
• As of January 1, 2025, single-split air conditioning systems containing less than 3 kg of fluorinated GHGs with a GWP ≥ 750 (e.g., HFC-134a, HFC-407c, HFC-410a).

The new F-Gas regulation also prohibits the use of:

• As of January 1, 2020, any virgin (previously unused) fluorinated GHG with a GWP ≥ 2,500 for the servicing or maintenance of refrigeration equipment with a charge size of 40 tonnes of CO2 equivalent or more (approximately 10 kg of HFC-404A, for example)
• As of January 1, 2030, any fluorinated GHG (including reclaimed or recycled) with a GWP ≥ 2,500 for the servicing or maintenance of refrigeration equipment with a charge size ≥ 40 tonnes of CO2 equivalent.

Ultimately, the affected refrigeration equipment will no longer be able to be recharged with gas for maintenance, which will necessitate conversion to a new fluid or replacement. Consequently, industrial operators must quickly adapt to these new restrictive measures and take them into account:

• For the maintenance of their existing equipment => A significant portion of HFCs sold is used for the maintenance and recharging of existing equipment. The reduction in quantities available on the market and the likely supply difficulties ahead should therefore encourage companies to pay even closer attention to the proper containment of fluids in their facilities to prevent fugitive emissions. Recycling and regeneration practices for HFC fluids are also expected to grow.
• For future investments => Various alternatives to fluorinated GHGs are already available to meet the needs of refrigeration, air conditioning, and fire suppression applications. The pros and cons of different technological options in terms of cost, efficiency, safety, and environmental impact (see environmental regulatory monitoring) have been the subject of comparative studies to help companies make informed decisions[3]. In addition to the development of new molecules such as HFOs[4], there is also a resurgence of pre-existing technologies based on hydrocarbons (e.g., isobutane (HC-600a) or propane (HC-290) used as refrigerants) or "natural" gases (e.g., ammonia or carbon dioxide used as refrigerants / carbon dioxide, nitrogen, or argon used as extinguishing agents). Compared to fluorinated GHGs, however, natural gases like hydrocarbons present safety hazards (flammability, toxicity, or asphyxiation risks) that require special attention. Consequently, it is not acceptable for the substitution of fluorinated GHGs to replace an environmental risk with a risk to human safety.

2) Adaptation of provisions regarding the containment of fluorinated GHGs

Under the new F-Gas regulation, the frequency of leak checks for refrigeration and air conditioning equipment, as well as fire protection systems, is no longer based on the actual gas charge (in kg), but on the CO2 equivalent content. Leak checks must therefore be performed:

• every 12 months when the fluid charge is ≥ 5 tCO2e but < 50 tCO2e
• every 6 months when the fluid charge is ≥ 50 tCO2e but < 500 tCO2e
• every 3 months when the fluid charge is ≥ 500 tCO2e.

As a reminder, until now, these 3 inspection frequencies applied based on an actual fluid charge of:

• 2 kg, 30 kg, and 300 kg for refrigeration and air conditioning equipment
• 3 kg, 30 kg, and 300 kg for fire suppression systems.

To calculate the CO2 equivalent content, multiply the quantity of gas by its GWP. For example, the GWP of HFC-134a is 1430. The 5 tCO2e threshold that triggers the annual inspection requirement is therefore equivalent to 3.5 kg of HFC-134a. The equivalence table below, established by the Ministry of Ecology, helps identify the new inspection frequencies for the main fluorinated GHGs based on their actual fluid charge:

Looking at this table, it is clear that some equipment containing less than 2 kg of HFC-23 or HFC-404a will now require leak checks, whereas they were previously exempt. Conversely, some equipment containing slightly more than 2 kg of HFC-134a, HFC-407c, or HFC-410a may now be exempt from this requirement.

Note: The new F-Gas regulation also subjects electrical switchgear containing SF6 to leak checks based on the same criteria, unless they contain less than 6 kg of gas (actual charge), have a leakage rate < 0.1%, and/or are equipped with a pressure or density monitoring device.

What actions need to be taken?

In anticipation of the new F-Gas regulation coming into effect on January 1, 2015, industrial companies must, in summary:

• Inventory their equipment containing fluorinated GHGs
• Record the type and quantity of fluid for each piece of equipment
• Calculate the CO2 equivalent content based on GWP to determine the new leak check frequencies
• Integrate all these new requirements into their purchasing and maintenance procedures for the equipment concerned.

[1] GWP = Global Warming Potential over 100 years of 1 kg of a given gas compared to 1 kg of CO2

[2] Regulation (EC) No 842/2006 of 17 May 2006

[3] See in particular the study published by ADEME, AFCE, and UNICLIMA on "Alternatives to HFCs in refrigeration and air conditioning applications": http://www.afce.asso.fr/en-france/etude-sur-les-alternatives-aux-hfc-a-fort-gwp

[4] Hydro-Fluoro-Olefins: these are unsaturated HFC molecules with a very short atmospheric lifetime and therefore a very low GWP. For example, HFO-1234yf could replace HFC-134a in the same systems because the pressure and temperature characteristics are almost identical.

[5] Articles R. 543-75 et seq. of the Environmental Code, supplemented by the decree of May 7, 2007

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