Provisional F-gas deal agreed

A provisional deal has been reached to cut fluorinated gas (F-gas) emissions in the EU. The European Parliament and Council provisional agreement will reduce hydrofluorocarbons (HFCs) use to zero by 2050. This will be achieved by reducing both consumption and production. The EU consumption quota will gradually be phased out from specific sectors by defined dates. Production rights allocated by the European Commission (EC) will also be reduced to 15% by 2036.

Changes for commercial refrigeration cover a ban on F-gases with a global warming potential (GWP) of above 150 for self-contained equipment from 2024. This does not change the current legislation (which is already in place) except to include all F-gases (rather than specifically just HFCs). Stationary self-contained equipment has a ban on greenhouse-gases with GWP of 150 or more from 2025 which expands the current regulation that only covers HFCs and refrigerants with a GWP of above 2,500. For stationary equipment designed to cool products to temperatures below – 50°C, F-gases with a GWP of above 2,500 are banned from 2024 which again adds to the current regulation which covers HFCs only. The ban on refrigerants with a GWP of above 150 in stationary equipment (that cools product temperatures above -50°C) is probably the most significant change that affects a number of commercial and industrial systems. For example, the regulation will now cover smaller (<40 kW) commercial systems and cold stores.

The revised regulation will include new bans on domestic heat pumps and some air conditioners that use HFCs with a GWP of greater than 150. This includes a ban on F-gases with a GWP of above 150 in monobloc heat pumps and air conditioning systems with a capacity of under 12 kW from 2027. The ban extends to all products in this category from 2032. The provisional agreement does include the potential to release additional quotas for heat pumps if the bans should affect the heat pump deployment targets required under REPowerEU. For split air conditioning systems and heat pumps a full ban is imposed from 2035 for products with a refrigerant with a GWP of above 150. Exemptions are applied for equipment where safety requirements could restrict usage of refrigerants with a GWP of less than 150.

Dates for future implementation of prohibitions are shown in the table below (excluding prohibitions already in place):

Products and equipment		Date of prohibition
(3) Fire protection equipment	(c) that contain or rely on other fluorinated greenhouse gases listed in Annex I, except when required to meet safety standards requirements.	1 January 2024
(11) Refrigerators and freezers for commercial use (self-contained equipment)	(c) that contain other fluorinated greenhouse gases with GWP of 150 or more.	1 January 2024
(12) Any stationary self-contained refrigeration equipment that contains fluorinated greenhouse gases with GWP of 150 or more, except when required to meet safety requirements.		1 January 2025
(13) Stationary refrigeration equipment that contains, or whose functioning relies upon, except equipment intended for applications designed to cool products to temperatures below – 50°C	(b) other fluorinated greenhouse gases with GWP of 2,500 or more.	1 January 2024
(16) Self-contained room air-conditioning and heat pumps	b) Plug-in room and other self-contained air-conditioning and heat pumps (including all heat pumps in monobloc construction) with a maximum rated capacity of 50 kW that contain fluorinated greenhouse gases with GWP of 150 or more except when required to meet safety requirements. When safety requirements would not allow using fluorinated greenhouse gases with GWP of 150 or less, the GWP limit is 750.	1 January 2027
	(c) Other self-contained air-conditioning and heat pumps that contain fluorinated greenhouse gases with GWP of 150 or more except when required to meet safety requirements. When safety requirements would not allow using fluorinated greenhouse gases with GWP of 150 or less, the GWP limit is 750.	1 January 2030
(18) Stationary split air-conditioning and split heat pumps	(a) Single split systems containing less than 3 kg of fluorinated greenhouse gases listed in Annex I, that contain, or whose functioning relies upon, fluorinated greenhouse gases listed in Annex I with GWP of 750 or more.	1 January 2025
	(b) Split air-to-air systems of a rated capacity of up to and including 12 kW containing, or whose functioning relies upon, fluorinated greenhouse gases listed in Annex I with GWP of 150 or more, except when required to meet safety requirements.	1 January 2029
	(ba) Split air-to-water systems of a rated capacity of up to and including 12 kW containing, or whose functioning relies upon, fluorinated greenhouse gases listed in Annex I with GWP of 150 or more, except when required to meet safety requirements.	1 January 2027
	(c) Split systems of a rated capacity of more than 12 kW containing, or whose functioning relies upon, fluorinated greenhouse gases listed in Annex I with GWP of 750 or more, except when required to meet safety requirements standards.	1 January 2029
	(d) Split systems of a rated capacity of more than 12 kW containing, or whose functioning relies upon, fluorinated greenhouse gases listed in Annex I with GWP of 150 or more, except when required to meet safety requirements.	1 January 2033
(19) Foams that contain HFCs with GWP of 150 or more, except when required to meet national safety standards	(b) Other foams (than Extruded polystyrene (XPS))	1 January 2023
(21) Personal care products (i.e. e.g. mousse, creams, foams, liquids, sprays) containing fluorinated greenhouse gases.		1 January 2024
(22) Equipment used for cooling the skin that contain, or whose functioning relies upon, fluorinated greenhouse gases with GWP of 150 or more except when used for medical applications.		1 January 2024

Annex 1 contains the GWP of fluorinated greenhouse gases, hydrofluorocarbons, perfluorocarbons and other perfluorinated compounds.

As well as the phase out of HFC refrigerants in new equipment, the deal also covers the use of F-gases in service and maintenance. From 2025 (2026 for air conditioning and heat pump equipment) servicing equipment that uses high GWP refrigerants will be banned unless the gases are reclaimed or recycled. Use of reclaimed of recycled refrigerant for servicing will be allowed until 2030 (2032 for air conditioning and heat pump equipment). For equipment that is designed to cool products to temperatures below -50°C a servicing ban will be applied from 2032 with a permanent derogation for the use of recycled or reclaimed gases.

The deal will now be submitted to the member states representatives within the Council and to the Parliament environment committee for endorsement and potentially final approval. The new regulation is specifically an EU regulation and may not be replicated in the UK. Whether the UK will mirror these changes or not is still not clear. DEFRA published an F-gas Assessment Report at the end of 2022(https://www.gov.uk/government/publications/assessment-of-the-f-gas-regulation-in-great-britain) where it was suggested that the technical feasibility to mirror EU legislation may not be practical for the UK. Nevertheless, many UK companies will trade with the EU and so for goods entering the EU, the new proposed legislation will apply, which may well make the UK legislation less relevant for many companies.

If you are interested in how to transition to lower GWP refrigerants and would like any advice, then please contact Judith Evans (j.a.evans@rdandt.co.uk) at RD&T.

---