The Review

The European Commission has stated that a recast of the F-gas Regulation is likely by end of 2021, in line with the climate law proposal, which requires the Commission to review, and where necessary propose to revise by June 2021, all relevant policy instruments to achieve the additional 2030 emission reductions.

Refining the implementation of the current regulation

Areas where the current Regulation can be refined to improve implementation
To help combat illegal trade
To improve data reporting reliability
To support Enforcement
To improve the New Entrant Reserve process

How F-Gas Review relates to Climate Law and Green Deal

EFCTC believes that lower GWP HFCs, HFC/HFO blends and HFOs have an important role to play in the longer term to deliver safe energy efficient applications with improved containment recovery and recycle.  Read more

Key Considerations

Good availability of HFCs for some important applications such as heat pumps

The amount of aerothermal, geothermal or hydrothermal energy captured by heat pumps is considered to be energy from renewable sources for the purposes of the renewable energy directive (RED). There is growth in heat pump installations, with extensive continuing HFC use according to BSRIA “80% of heat pumps sold in 2019 contained R-410A refrigerant with R-134a being the second most common”. It is expected that lower GWP HFCs, HFC/HFO blends and HFOs/HCFOs will be used more widely for heat pumps.

Availability and supply of high quality HFCs and HFC blends from legitimate well-established suppliers

HFCs, HFC/HFO blends and HFOs are supplied in approved tested containers appropriate for liquified compressed gases. The system of supply enables the containers to be returned to avoid emissions and ensure containers are tested as required. Suppliers also provide containers for the recovery of refrigerants from systems for return for reclaim or destruction. This well-established system underpins the whole of the HFCs and HFOs supply and return.  Providing supply and return routes for very small importers may also be a challenge.

Evidence shows that illegal imports may be of lower quality, contaminated with substances that degrade performance or safety, or may even be completely different substances. Illegal imports are widely shipped in disposable cylinders (DACS) that do not comply with ADR requirements, are banned by the F-Gas Regulation and are disposed without recovering residual HFCS leading to higher emissions.

Recycling and Reclamation of HFCs

Recycling of HFCs occurs locally and is undertaken by service and maintenance companies and is used in systems typically on the same site. Recycling is the reuse of a recovered fluorinated greenhouse gas following a basic cleaning process; contaminants are reduced through oil separation and filtration processes. Recycled refrigerant is not as pure as reclaimed refrigerant.

Reclamation reprocesses recovered HFCs in order to match the equivalent performance of a virgin substance, taking into account its intended use. During reclamation, filtering, drying, distillation, and chemical processes strip the refrigerant of impurities.  According to the EEA 2019 F-gas Reportin 2018, reclaimed HFCs now make up 9 % of the produced amount, or 3 % of the EU supply of virgin HFCs (or 13 % and 4 %, respectively, as CO2e).

Reclaimed HFCs are being used in new equipment. Reclaimed R-410A with the same quality as virgin refrigerant is being mixed with virgin R-410A for use in VRV air-conditioning systems. With a large potential of R-410A available in existing installations, re-use contributes to creating the circular economy and this approach can be used for other refrigerants in future. The demand of reclaimed R-404 is expected to increase as it can be widely used until 2030.

Montreal Protocol HFC Phase-down

In 2018, HFC consumption was already 46 % below the first limit for the EU under the Montreal Protocol Kigali Amendment (which was to be achieved in 2019). Measuring the progress of this phase-down relies on the metric of ‘consumption’, which is similar, but not identical, to ‘placing on the market’ (POM) used for the EU HFC phase-down. [EEA 2019 F-gas report].
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