The effect of this Regulation is compounded by the recently revised F-Gas Regulation, (EU) No 517/2014, which will come into effect the day after, on 1 January 2015. The revised F-Gas Regulation will have an impact on what alternatives can be used to retrofit existing R22/HCFC-based systems and also on the general use of HFCs in the RACHP sector.
The impact of these changes will be dramatic and, over the course of a decade or so, the phasing in of different parts of the F-Gas Regulation will change the way we design and use RACHP equipment that utilises HFC-based refrigerants. The F-Gas Regulation is a wide-ranging piece of legislation and covers many areas of industry that use F-Gases, not just the RACHP sector.
The following details the most important points that need to be followed to ensure compliance with both the ODS and revised F-Gas Regulation for those working in any area of the RACHP industry.
The Regulation (EC) 1005/2009 on Ozone Depleting Substances — Reclaimed R22, or any HCFC sale and usage, will be banned after 31 December 2014;
Existing equipment will not have to be decanted of its refrigerant but it can not be charged with reclaimed/recovered HCFCs as from the 1 January 2015 under any circumstances;
— Any HCFCs recovered after 31December 2014 MUST be sent for destruction;
— HCFCs recovered during servicing or maintenance after 31 December 2014 cannot be returned into the system and MUST be sent for destruction;
Caution — If retrofitting existing HCFC plant to a HFC-based alternative refrigerant, be very careful what retrofit alternative refrigerants you offer end users/customers. Do not recommend high GWP retrofit replacement refrigerants. Many of these products will be hit hard by the recently-amended F-Gas Regulation and future availability is likely to be a serious issue.
F-Gas Regulation (EU) No 517/2014 – the phase-down mechanism — The main plank to reduce the amounts of F-Gases (HFCs) both placed on the market and used in the EU will be governed by the phase-down mechanism. The Regulation introduces a phase-down in placement on the market involving a gradually-declining cap on the total amount of bulk HFCs (in tonnes of CO2 equivalent) placed on the market in the EU.
The 2015 baseline amount is determined by collecting manufacturing and sales data from manufacturers, importers and suppliers of bulk F-Gases between 2009 and 2012. The average of this period will be the maximum amount placed on the market on 1 January 2015. Over subsequent years between 2015 and 2030, the amount placed on the market will then be reduced on a phased basis.
The Regulation bans few, if any, F-Gases but the implication of the above phasedown is obvious in that if we carry on using HFC-based refrigerants at the current rate, then with only 21% of the amount available in 2030 than there was in 2015, there won’t be enough for people to use!
Another subtle effect of the legislation is that manufacturers and suppliers will be given an allocation quota based on CO2 tonnes equivalent. So, if for instance a manufacturer or supplier is given a one million tonnes CO2 equivalent quota, the can choose what refrigerants they want to manufacture/supply. If they choose to supply R404A, which has a high GWP (3920), then the million tonne quota would allow them to sell 255 tonnes of R404A. If they chose to supply R407A (GWP = 2107), then they could place 474 tonnes on the market. If they choose R134a (GWP = 1430) they could place 699 tonnes into the market.
Manufacturers and suppliers make money selling physical kgs of refrigerant, not CO2 kg equivalents, and obviously will choose to manufacture and supply refrigerants they can sell more of, i.e. lower GWP HFCs. So high GWP refrigerants, without being banned outright, will just wither on the vine, especially as time moves forward to 2030 with ever-decreasing amounts being allowed on the market, and the use of high GWP refrigerants in equipment being banned. NB: Article continued.
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