29/07/2024

On March 11, 2024, the amendment to EU Regulation No. 2024/573 on fluorinated greenhouse gases (F-Gas Regulation) came into force. The new version was adopted by the EU Parliament in January 2024 following approval by the EU Council.

The long-term aim is to completely eliminate the use of fully fluorinated hydrocarbons (HFCs) and partially fluorinated hydrocarbons (PFCs) in the operation of stationary refrigeration systems. In order to achieve this goal, the “phase-down” agreed in the EU regulation from 2014 to 2032 to 21% has now been tightened even further and extended to 2050.

Mr. Henrici, why has the F-Gas Regulation now been updated again?

Rainer Henrici: We have had an F-Gas Regulation since 2006, which was originally linked to the bans on ozone-depleting substances such as CFCs in the 1990s. The replacement solution for CFCs was chlorine-free fluorocarbons, which, however, did not solve the problem of greenhouse effect either.

The first regulation of F-gases, derived from the Kyoto Protocol, therefore followed in 2006. Initially, operators of refrigeration systems were required to improve the sealing of their systems in order to reduce emissions.

Objectives of the amendment to the F-Gas Regulation:

• Complete phase-out of F-gases as refrigerants for stationary refrigeration systems by 2050,
• accelerated phase-down compared to the 2014 EU regulation,
• more sustainability by reducing greenhouse gas emissions.

From January 1, 2015, Regulation (EU) 517/2014 came into force, which already contained some refrigerant bans and formulated the phase-down, i.e. a steady reduction in the quantities of F-gases that may be available on the market. In addition, there were restrictions on various applications - for example, the low-temperature refrigerants R-404a and R507 with high GWP values of around 3,900 kg CO2 had to be withdrawn from the market. Most other refrigerants could still be used under the old regulation.

This is where the new F-Gas Regulation, which has been in force since March 11, 2024, comes in. This includes a much more drastic phase-down for products that are available on the market: Previously, the aim was to phase down hydrofluorocarbons (HFCs) by 21% by 2032. Now the political goal is to have no more HFC products on the market by 2050 at the latest. Even under the new regulation, not all F-gases are regulated in the phase-down, but the aim is now to reduce hydrofluorocarbons, which are mainly used as refrigerants, initially to 5% by 2030 and to zero by 2050.

Which consequences of the new regulation will affect the operators of refrigeration systems most directly?

Rainer Henrici: You can see that there will be a very sharp decline in the amount of HKFW refrigerants available on the market from as early as 2027 - and this will indirectly lead to clear restrictions in almost all applications. The quantities that will then still be available are those that are already in circulation on the market, but here too the question arises as to how long they will still be available. It is now still possible to recycle refrigerants from existing systems and then reuse them if necessary.

For which applications does the new F-Gas Regulation pose particular challenges?

Rainer Henrici: Ultimately, the aim is to get rid of fluorocarbons completely. We also need to consider that most of the fluorinated refrigerants belong to the group of polyfluorinated chemicals. Additional restrictions are expected in the coming years. The amendment to the F-Gas regulation now also takes into account medical applications such as metered dose inhalers for asthmatics, for which there are still no replacement options in the medium term.

However, the trend is clearly moving away from fluorocarbons towards “natural” refrigerants. These include substances such as CO2 or propane. The technologies previously used in refrigeration systems will therefore become obsolete and will have to be replaced by new ones. This will not only mean new investments for operators, but also process-related and bureaucratic challenges.

How is the amendment to the F-Gas Regulation already making itself felt on the market?

Bastian Kleinhenz: Of course, the shortage of refrigerants is also having an impact on their price. Many operators are now switching to importing their refrigerants from abroad because they are still much cheaper there.

Rainer Henrici: The reduction in the quantities that are coming onto the market is also problematic with regard to the growing importance of heat pumps. There are still inconsistencies in the relevant regulations. Heat pumps with fluorocarbons are still being sold, and customers hope that they won't have to replace them in the next few years because they may no longer be serviced.

The deadlines for bans and restrictions on various fluorocarbons are regulated in the new F-Gas Regulation in tables that differentiate between stationary refrigeration systems, chillers (“chillers” - liquid chillers), air conditioning systems and heat pumps. The list is so complex that it poses a challenge even for experts.

Ultimately, the new regulation is no longer intended to encourage users to use fluorocarbons as refrigerants and instead prefer to look at possible alternatives now - including flammable refrigerants such as propane or CO2, for example. However, building refrigeration systems for these products can be more complex, and in the case of propane, the fire safety aspect also needs to be given special consideration.

What could alternative solutions to existing refrigerants and technologies look like in the near future?

Rainer Henrici: I think planners will come up with creative solutions in some cases. For example, with heat pump monobloc units, the entire heat pump unit with the refrigeration components is moved from the cellar to outside the house. This also makes it possible to use propane as a refrigerant. Such solutions naturally require the necessary space and are not suitable for apartment buildings with many parties. There are also units in the refrigeration sector that work with CO2, which can be used where propane would be problematic due to flammability and safety technology.

Bastian Kleinhenz: Another question in this context is how to deal with old refrigeration systems when switching to new refrigerants. Will it still be possible to offer service for them? This question has not yet been definitively answered either.

But simply replacing the refrigeration systems is certainly not enough ...

Rainer Henrici: The transition to new technologies with higher safety requirements naturally also requires the appropriate manpower. Both the service personnel and the operators of the new systems must be trained accordingly.

In addition to consulting and training, new risk assessments also need to be conducted - and that's where Infraserv Höchst's experts come into play again. In the existing buildings, we also need to check whether the fire protection concepts are tailored to the new refrigeration systems - possibly with the involvement of experts from the fire department. The need to carry out regular leak checks also remains in place with the new F-Gas Regulation and has been extended to refrigeration systems with HFO (from a filling quantity of 1 kg) - however, there are still uncertainties on the part of the legislator as to how leak tests should be handled for refrigerant mixtures.

What challenges will operators of refrigeration systems face?

• Rapid shortage of F-gases available on the market,
• Increasing cost of refrigerants,
• Gradual changeover from fluorinated hydrocarbons to alternative refrigerants such as CO2 or propane,
• Conversion to new refrigeration system technologies that are suitable for the permitted refrigerants,
• Selection of the appropriate technology for the respective area of application, also with regard to service and maintenance options,
• Carrying out risk assessments,
• personnel training.

How can Infraserv help refrigeration system operators make the switch?

Bastian Kleinhenz: First, we look at the existing system on site in its specific area of application, including all existing documentation, evaluate it and then develop a concept for a future-proof, energy-efficient solution with the optimal refrigerant.

Infraserv energy consultants can also point out ways to apply for subsidies for the conversion, for example through BAFA.

Rainer Henrici: Infraserv Höchst's consulting and service offerings for the new F-Gas Regulation are closely aligned with practical requirements. It provides operators with comprehensive guidance and assistance to help them comply with the requirements of the complex F-Gas Regulation.