Fluorinated greenhouse gases: the challenges of the new regulation

The 2014 European "F-Gas" regulation aims to reduce fluorinated GHGs via restrictions and bans, forcing manufacturers to adapt their equipment and investments.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
17.09.2019
Contents
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From January 1, 2015, the new European regulation on fluorinated greenhouse gases (GHGs) will come into force (Regulation (EU) n°517/2014 of April 16, 2014 -JOUE of May 20, 2014). The main aim of this "F-Gas Regulation" is to impose a gradual reduction in the quantities of fluorinated GHGs implemented in the European Union through restrictions on marketing and use.

Today, fluorinated GHGs are used in a wide range of industrial applications (mainly as refrigerants, insulating agents, solvents and fire extinguishing agents), and their global warming potential is very high, despite the fact that alternative technologies with equivalent efficiency and little or no environmental impact already exist or are currently being developed. The measures set out in the new F-Gas regulation are designed to accelerate the deployment of these alternative technologies and gases. In the same way as their suppliers and service providers, companies using processes operating with fluorinated GHGs will have to adapt quickly to these new EHS constraints as part of their future investments, but also for the maintenance and control of their current equipment.

Background

Fluorinated GHGs include :

  • HFCs - Hydrofluorocarbons. They are used as refrigerants in refrigeration and air-conditioning systems (e.g. HFC134a, HFC407c, HFC410a>), as fire-inhibiting gases (e.g. HFC227ea marketed under the name FM200®, HFC23 marketed under the name FR13®), as expanding agents in foams and as solvents.
  • PFCs - Perfluorocarbons. They are mainly used as fire extinguishing agents (e.g. PFC31-10 marketed under the name CEA410®) and as solvents.
  • SF6 - Sulfur hexafluoride. This gas is used as an insulator in high-voltage electrical equipment (circuit breakers, switches, metal-enclosed cells).

Targeted by the Kyoto Protocol, like carbon dioxide and methane, fluorinated GHGs represent only 2% of the 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 impact on the climate as 1430 kg ofCO2, equivalent to driving a car 10,000 km.

Fluorinated GHGs are released into the atmosphere when used in the open air (e.g. aerosol cans or solvents), but also when equipment containing them leaks. According to the French Ministry of Ecology, over 6,000 tonnes of refrigerants escape from air conditioning, refrigeration and heat pump equipment in France every year! That's an impact on global warming equivalent to the annualCO2 emissions of 6,900,000 cars!

In addition, the production and use of fluorinated GHGs has risen sharply since the early 1990s. Manufacturers have massively favored the use of HFCs to replace ozone-depleting substances (ODS) such as CFCs (e.g.: R12), HCFCs (e.g.: R22) and halons, previously used as refrigerants and fire extinguishers, and scheduled to be phased out under the 1987 Montreal Protocol.

While the reduction of ODS has halted the depletion of the ozone layer, the concomitant development of fluorinated GHGs is not conducive to the fight against global warming.

Against this backdrop, the European Union has decided to adopt a new F-Gas Regulation aimed at reducing the quantities of fluorinated GHGs, in particular HFCs, and encouraging their replacement by substances with a low impact on the climate. The requirements already set out in the previous F-Gas Regulation[2] to prevent degassing and fugitive emissions of fluorinated GHGs have been retained, with a few adjustments.

Main changes introduced by the new F-GAS regulation

1) New measures to restrict the marketing and use of fluorinated GHGs

Firstly, gas producers and 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 overall quantity of HFCs that can be placed on the market will be progressively reduced over 2 or 3 years. The aim is to reduce this quantity by 79% by 2030, compared with the 2009-2012 average. The reduction will already be 37% in 2018!

Secondly, new bans on the marketing of equipment are also defined. These prohibitions concern in particular :

  • As of January 1, 2016, fire protection equipment containing HFC23
  • A compter du 1er janvier 2020, les équipements de réfrigération fixes contenant des HFC dont le PRP est ≥ 2 500 (Ex.: HFC404a), sauf applications conçues pour refroidir des produits à une température < -50 °C
  • From January 1, 2025, bi-block air-conditioning systems containing less than 3 kg of fluorinated GHGs with GWP ≥ 750 (e.g. HFC134a, HFC407c, HFC410a).

The new F-Gas regulations still prohibit the use of :

  • From January 1, 2020, any virgin fluorinated GHG (= not previously used) with GWP ≥ 2,500 for the servicing or maintenance of refrigeration equipment with a charge greater than or equal to 40 TeqCO2 (i.e. approximately 10 kg of HFC404A, for example).
  • From January 1, 2030, any fluorinated GHG (even regenerated or recycled) with GWP ≥ 2,500 for the servicing or maintenance of refrigeration equipment with a charge ≥ 40 TeqCO2.

Eventually, the refrigeration equipment concerned will no longer be able to be recharged with gas for maintenance purposes, and will have to be converted to a new fluid or replaced. Manufacturers will have to adapt quickly to these new restrictions and take them into account:

  • For the maintenance of existing equipment => A significant proportion of HFCs on the market is used for the maintenance and recharging of existing equipment. The reduction in the quantities available on the market and the likely difficulties of future supply should therefore encourage companies to pay even greater attention to the proper containment of fluids in their installations, with a view to preventing fugitive emissions. Recycling and regeneration practices for HFC fluids are also set to expand.
  • For future investments => Various alternatives to fluorinated GHGs are already available for refrigeration, air-conditioning and fire-extinguishing applications. The advantages/disadvantages of the various technological options in terms of cost, efficiency, safety and environmental impact (see Environmental regulatory watch) have been the subject of comparative studies to help companies make the right choices[3]. In addition to the development of new molecules such as HFOs[4], there has also been a revival of pre-existing hydrocarbon-based technologies (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 with fluorinated GHGs, however, natural gases, like hydrocarbons, have hazard characteristics (flammability, toxicity or asphyxiant power) that require particular attention from a safety point of view. In fact, it is inconceivable that the substitution of fluorinated GHGs would result in transforming a risk to the environment into a risk to people.

2) Adaptation of provisions for the containment of fluorinated GHGs

Under the new F-Gas regulations, the frequency of leak tests to be carried out on refrigeration and air-conditioning equipment, as well as fire protection systems, is no longer based on actual gas load (in kg), but on CO2 equivalent content. As a result, tightness checks will now be carried out :

  • tous les 12 mois lorsque la charge en fluide est ≥ à 5 TeqCO2 mais < 50 TeqCO2
  • tous les 6 mois lorsque la charge en fluide est ≥ 50 TeqCO2 mais < 500 TeqCO2
  • every 3 months when the fluid load is ≥ 500 TeqCO2.

As a reminder, until now, these 3 control frequencies applied respectively from an actual fluid load of :

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

To calculate the CO2 equivalent content, multiply the quantity of gas by its GWP. For example, the GWP of HFC134a is set at 1430, so the threshold of 5 TeqCO2 subject to annual inspection is equivalent to 3.5 kg of HFC134a. The equivalence table below, drawn up by the French Ministry of Ecology, identifies the new inspection frequencies for the main fluorinated GHGs, based on their actual fluid load:

This table shows that certain equipment containing less than 2 kg of HFC23 or HFC404a will have to undergo leak testing, whereas they were previously exempt. Conversely, certain equipment containing slightly more than 2 kg of HFC134a, HFC407c or HFC410a may now be exempt from this obligation.

Remarque : Le nouveau règlement F-Gas soumet également à contrôle d'étanchéité les disjoncteurs et commutateurs électriques contenant du SF6 suivant les mêmes critères, sauf s'ils contiennent moins de 6 kg de gaz (charge réelle), s'ils présentent un taux de fuite < 0,1% et/ou s'ils sont munis d'un dispositif de contrôle de la pression ou de la densité.

Who is responsible for French refrigerant regulations?

National regulations on refrigerants[5], including HFCs and PFCs, will have to evolve to bring them into line with the new F-Gas regulations. In particular, the French Ministry of Ecology plans to update the provisions governing leak checks on refrigeration and air-conditioning equipment by :

  • aligning inspection frequencies with the new TeqCO2 load criterion
  • creating a regulatory mark attesting to whether or not the equipment has been leak-tested.

What actions are needed?

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

  • Identify equipment containing fluorinated GHGs
  • Record the type and quantity of fluid for each piece of equipment
  • Calculate TeqCO2 content from PRPs to determine new leak test frequencies
  • Integrate all these new constraints 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 with 1 kg of CO2.

[2] Regulation (EC) no. 842/2006 of May 17, 2006

[3] See 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. HFO-1234yf could therefore replace HFC-134a in the same systems, as its pressure and temperature characteristics are virtually identical.

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

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