EC Regulation No517/2014 came into force on 1st January 2015 and was enacted in UK law as ‘The Fluorinated Greenhouse Gases Regulations 2015 No 310’. The intention of the Regulations is to reduce F-Gas emissions as part of the fight against global warming.
They achieve this primarily by restricting the amount of refrigerant produced or imported. This restriction is based on the CO2 equivalent of the gas. The table below shows how it is proposed to be reduced over the next 13 years. Of course, this might alter as the F-Gas Regulations are reviewed in the future.
So far we have seen very little impact on the availability of refrigerants but from this year the reduction will become increasingly noticeable. There will be 7% less gas available this year compared with last year and the requirement for refrigeration is still growing year on year.
In less than 2 years’ time the amount of F-Gas refrigerant available will have been cut by 37% CO2eq and in 5 years’ time the amount available will be reduced to less than half the CO2eq quantity currently available. As the refrigerants become scarce be prepared for some very serious increases in refrigerant prices!
From 2020 sales of R404A will be banned entirely and it will be illegal to charge virgin R404A into a system. Well before then, it is highly likely that R404A will be extremely hard to obtain and consequently very expensive.
From 2020 it will be illegal to fill new plants with refrigerants with a GWP higher than 2500.
From 2022 it will be illegal to fill new plants >40kW with refrigerants with a GWP higher than 150.
There are other parts of the Regulations that increase leak testing requirements and the increased requirement for leak detection systems, but the cost of refrigerants will make these highly desirable anyway.
Effects of the Regulations
The reduction in ‘placing on the market’ will mean that refrigerant producers and importers are very likely to either stop producing or severely limit production of the high GWP refrigerants so they can produce more of the lower GWP alternatives. This is likely to dramatically increase the cost of existing high GWP refrigerants such as R404A, R507A etc. which in turn will drive a need to retrofit the huge number of existing R404A systems to use one of the lower GWP alternatives. This is likely to use up a significant proportion of the quota of refrigerant CO2eq available and increase prices further.
The cost of ‘topping up’ to replace lost gas will also drive an increase in work to find and repair leaks.
There will be a general move away from installing new systems using HFCs. The alternatives choices will depend largely on the application, with industrial plants continuing to use ammonia and supermarkets probably using CO2 more extensively. The HFO refrigerants are also likely to become more widespread in smaller systems, in chillers and a/c splits. Hydrocarbon – glycol systems may also find favour with some users.
Unfortunately, there are still many within our industry who as yet do not have the skills and qualifications to work with these refrigerants. That situation must change.
There is bound to be a large number of both end users and contractors who are reluctant to change or think they cannot afford to. They may try to find ways around the legislation by using smaller plants so that the GWP 150 limit is avoided and by ‘re-building’ existing systems to avoid the 40kW limit on new installations, and then later there may be a change of evaporators and piped services.
"It will be the massively reduced availability of HFC gases that will, in the end, make these systems impossible to maintain."
Over the next 5 to 10 years the Regulations will effectively make most existing systems unserviceable due to unavailability of refrigerant. Many of these will need replacing anyway due to their age. It would be very short-sighted to replace them with new HFC systems as the new systems will almost certainly need to be replaced before the end of their useful life.
This will inevitably lead to the need to replace or very heavily modify virtually all existing refrigeration plant that do not use ‘natural’ refrigerants.
Implications for Plant Owners and End Users
These changes are also likely to pose a problem for our industry through having insufficient manpower, skills and capacity to cope with the changes.
Interesting times are coming!