F-Gas regulation

Overview

The F-Gas Regulation has been implemented in UK legislation since 2006. The original F-Gas Regulation which was an EU Member State wide adopted piece of regulation focussed primarily on two main areas:

i. Containment

ii. Equipment prohibition measures

The regulation is a living document and periodic reviews are carried out to ensure the efficacy of the measures put in place are achieving the required objectives.

2015 saw the implementation of what is colloquially referred to as F-Gas II. This revised regulation maintained and strengthened the core principle of containment and expanded the prohibition list of equipment containing F-Gases that can be placed on the market in the EU. It’s main plank of enforcement however was a new F-Gas quota system. This was based upon the concept of the CO2 tonne equivalent as related to the GWP value of any particular F-Gas. The quota gave a fixed starting value for the maximum CO2 tonne eq. that could be placed upon the EU market place in any one calendar year. This baseline amount was then decreased incrementally over the course of 15 years up until 2030. It did not restrict the placing on the market of any particular refrigerant but obviously the higher the GWP of the refrigerant the more of the quota is used up. This meant that in real (kg) terms, the quota goes further (in kg terms) if a lower GWP refrigerant (such as R449A) is supplied rather than a higher GWP refrigerant (such as R404A).

As stated above the F-gas Regulation is a living document and in currently under review for its third iteration.
The F-Gas III Regulation is supposed to commence 1st January 2024.

Until the current regulation is repealed and the new one brought into force, the current version (F-Gas II) and all its articles remain in force.

What main changes are being suggested?

The final revision of F-Gas III will be significantly more severe than the current regulation in terms of availability of F-Gases and the uses/application in which they can be used.
The following sections detail the main current proposals being discussed:

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The above chart shows the current (F-Gas II) phase down (in blue) and the EU Commission proposed revised phasedown (in brown). The revised phase down proposal has two striking features, namely;

The existing three steps, 2024, 2027 & 2030 have greatly enhanced quota cuts which means that by 2030, for the whole of the EU, there will be less than 1⁄4 of what was originally sanctioned under F-Gas II.
F-Gas II’s phase down steps stopped at 2030, which meant there would be circa 38 million CO2 tonnes eq. available for all EU member states to use. As the chart illustrates, the proposal means the cuts will continue beyond 2030 and up until 2048. By the time of the final cut in 2048 there will be only 4.2 million CO2 tonnes eq. available for all EU member states to use.
Talking about millions of tonnes of anything sounds like a lot but what does it mean in reality?

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The above table clearly illustrates that if the proposal is adopted, by 2048, with a maximum of 4.2 million CO2 tonnes eq. available for all EU member states to use, if all that quota was used to supply R410A, then there would be a maximum for all of the EU of 2011 metric tonnes. This is clearly insufficient to meet anywhere near the demand. It can also clearly be seen that the lower the GWP, the greater the amount (metric tonnes) of refrigerant that can be supplied. Hence the drive towards lower GWP refrigerants such as R32 and more importantly, ultra-low GWP alternatives such as A2Ls.

The effect on market pricing is obvious and prices will rise sharply as demand vastly outstrips supply. Given that by 2027, the proposed reduced quota would mean that what is available is just over 1/3 of what was to be available under the F-Gas II Regulation, it is envisaged that pricing will increase significantly in the next couple of years.

In summary:

Prices will increase as demand outstrips supply
The market will have to move to ultra-low GWP alternatives such as A2Ls or non F- Gas alternatives such as hydrocarbons, ammonia or CO2, although all of these have some undesirable characteristics such as flammability, toxicity or extremely high operating pressures.

2. Equipment prohibitions
The proposed equipment prohibition list details various types of equipment and the maximum GWP value of refrigerant that can be used in them. The list expands with each iteration of the regulation. In the 2015 regulation, the most striking ban was that on the use of R404A primarily in larger refrigeration systems. The commission has proposed the following equipment bans for F-Gas III.

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Implications for the UK post Brexit

The UK is no longer a member of the EU and as such the EU F-Gas Regulation is not part of UK legislation. However, post Brexit, the UK government has adopted in near totality the EU F- Gas Regulation and simply implemented it into UK legislation. So in effect we are no longer a member of the EU but we follow the F-Gas Regulation, calling it the The Ozone-Depleting Substances and Fluorinated Greenhouse Gases (Amendment etc.) (EU Exit) Regulations 2019. This simply implements all of the main planks of the EU F-Gas Regulation under UK legislation.

The UK is also outside of the EU quota system. Therefore the UK has embarked on endowing itself a pro-rata share of the EU quota based upon historical usage in the UK. This UK quota is for UK use only and is not transferrable for use or sale in other EU Member States.

Summary

Under the current phase down F-GasII, the quota for 2022 and 2023 at 45% of the 2015 baseline. 2024 will see a drop to 31%. Availability and prices will be affected.
If the proposed or similar amendments are adopted in the UK it will mean drastic cuts to the availability of F-gas based refrigerants.
The reduction will fall far short of demand and pricing will correspondingly rise.
Design & installation contractors should choose wisely the type of new equipment offered to clients as ill-chosen systems may be subject service and maintenance issues and certain flavours of refrigerants simply disappear from the market.
Brexit: The UK Government has made it clear that even after the UK left the EU they have no intention of reducing or minimising the existing environmental regulations currently in place relating to reducing and minimising emissions of ozone depleting and fluorinated greenhouse gases.

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