Fluorinated refrigerants: HFCs – phase-down of their use

Decree 2019-708 implements the Kigali Amendment to the Montreal Protocol, which aims to phase down HFCs—gases with a high climate impact that were used to replace ozone-depleting substances.

Marie Faucon
Consultante HSE
Publication : 
06.09.2019
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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Decree No. 2019-708, published on July 4, 2019, enacts the Kigali Amendment of October 15, 2016, to the Montreal Protocol (established on September 16, 1987) regarding substances that deplete the ozone layer. This amendment adds a goal to the Montreal Protocol for the gradual reduction of the production and consumption of hydrofluorocarbons (HFCs).

A look back at the 1987 Montreal Protocol

With the signing of the Montreal Protocol in 1987, the international community decided to ban the production and consumption of ozone-depleting substances (ODS) due to their impact on the ozone layer.

These substances include:

  • chlorofluorocarbons (CFCs) such as R-11 or R-12, also known as Freons;
  • hydrochlorofluorocarbons (HCFCs) such as R-22 or R-408A;
  • halons and other gases; …

These gases were gradually replaced by hydrofluorocarbons (HFCs), which have a lower impact on the ozone layer but contribute to global warming.

The Kyoto Protocol for combating fluorinated GHGs

The international community reached a new agreement in 1997 by signing the Kyoto Protocol to combat fluorinated greenhouse gases (F-gases), such as:

  • hydrofluorocarbons (HFCs);
  • perfluorocarbons (PFCs);
  • SF6;
  • NO2;
  • CO2;
  • CH4.

European and national regulations applicable to ozone-depleting substances and F-gases stem directly from these international commitments:

Regulation (EC) No 1005/2009 of 16 September 2009 on substances that deplete the ozone layer

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Ozone-depleting substances such as CFCs, HCFCs, carbon tetrachloride, methyl bromide, or halons are governed by Regulation (EC) No 1005/2009 of 16 September 2009.

This regulation imposes stricter measures on member states than the Montreal Protocol, such as:

  • the prohibition of producing and placing on the market the substances listed in the Montreal Protocol, as well as equipment containing them or dependent on them, particularly for the maintenance or servicing of equipment;
  • the prohibition of placing virgin, reclaimed, or recycled HCFCs on the market;
  • training for personnel maintaining equipment containing regulated substances;
  • the recovery of substances contained in equipment for the purpose of treatment.

Regulation (EU) No 517/2014 of 16 April 2014 on certain fluorinated greenhouse gases, known as "F-Gas II"

This regulation aims to contain, prevent, and reduce emissions of fluorinated greenhouse gases covered by the Kyoto Protocol: HFCs, PFCs, and SF66.

In fact, it is not limited to overseeing containment and periodic equipment inspections. Its goal is also to gradually reduce the placing of HFCs on the market so that users shift toward alternative solutions.

Preventing fluorinated greenhouse gas emissions relies on:

  • periodic leak checks;
  • maintaining records containing information on the quantities and types of fluorinated greenhouse gases installed, any quantities added, and the quantities recovered during maintenance and servicing;
  • training and certification for personnel working on the equipment;
  • labeling: products and equipment containing fluorinated greenhouse gases must bear a label indicating the name of the fluorinated gas and its quantity;
  • bans on the use of certain fluorinated greenhouse gases.

Deadlines for bans in France

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New measures to consider

Ultimately, the refrigeration equipment in question will no longer be able to be recharged with gas for maintenance, requiring 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 existing equipment: many of the HFCs on the market are used for the maintenance and recharging of existing equipment. Reduced availability and supply difficulties should encourage companies to pay closer attention to the proper containment of fluids in their installations to prevent fugitive emissions. Recycling and reclamation practices for HFC fluids are also expected to grow.
  • For future investments: various alternatives to fluorinated GHGs are already available to meet needs in refrigeration, air conditioning, or fire suppression. In addition to the development of new molecules like hydrofluoroolefins (HFOs), pre-existing technologies are making a comeback, such as those based on hydrocarbons (e.g., ammonia or carbon dioxide used as refrigerants / carbon dioxide, nitrogen, or argon used as extinguishing agents). Compared to fluorinated GHGs, natural gases like hydrocarbons present safety hazards (flammability, toxicity, or asphyxiation risks) that require special attention. Therefore, it is not acceptable for the substitution of fluorinated GHGs to transform an environmental risk into a risk to human safety.

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