European cooling body critical of ‘unrealistic’ F-Gas reform plans
EPEE favours keeping the existing F-Gas phasedown schedule in place until 2030 to provide more time to research and develop low GWP systems.
The European Commission’s proposals to revise F-Gas regulations from 2024 onwards have been declared ‘unrealistic’ by cooling body EPEE. The commission’s draft amendments, which are undergoing consultation, back introducing a stricter HFC phasedown schedule. This would serve to accelerate the need to adopt systems designed specifically for higher flammability, toxic or high pressure refrigerants.
EPEE said, “According to the proposal, all new equipment from 2027 would need to immediately use near zero GWP refrigerant, such as hydrocarbons or HFOs, which is an unrealistic timeline both in terms of technological development and in terms of the needed number of installers trained and certified to handle the new refrigerants, many of which are flammable.”
“In addition, if new equipment is now purchased using low GWP HFCs then maintenance possibilities would be greatly reduced considering the currently expected lifetime of equipment is more than 10 years. Having to replace relatively new equipment for lack of HFCs would go against the recently announced EU’s Sustainable Products Initiative.”
The organisation said it favoured keeping the existing phase down schedule in place until 2030 in a bid to ensure a sufficient amount of refrigerant is available to meet the needs of both the cooling and heating sector to move towards lower GWP products
A statement from EPEE said that the current phasedown targets were expected to ensure that the EU was already on course to meet its emissions obligations under the Montreal Protocol. However, the latest series of reforms propose introducing a stricter phasedown schedule to reduce HFC use from 2024 that would put a range of pressures on the RACHP sector around training and capability.
The group stated, “The assumptions and projections made to sustain this scenario are not realistic. Contrary to the assertions of the study, individual sectors require much more than four years to transition to new refrigerants – from R&D development until the market reaches full production and mass deployment, installation and adoption by consumers.”
“It should be noted that each model change is not only a change of refrigerant but also requires compliance with other EU legislation such as Ecodesign regulations (which are currently being revised for the RACHP sector as well), the Low Voltage Directive, Machinery Directive, or Pressure Equipment Directive.
EPEE said that it held several concerns about an impact study used by the European Commission to inform its f-Gas revision plans. These concerns include an expectation by the study’s authors that the majority of split air conditioning systems and heat pumps with a capacity of below 12kW would adopt the highly flammability refrigerant propane (R290) by 2024.
It warned “This means that thousands of air-to-air and hydronic heat pump models would need to be redesigned and changed to a new flammable refrigerant in less than 3 years.”
“In addition, the supply chain would need to be ready to deliver the adequate compressors and other components, and the new models would need to be accepted by consumers and installers to be trained and certified for flammable refrigerants.”
No information around the feasibility of moving to use propane for multi-split system was also provided in the research. These systems account for 15 per cent of all total split sales in the market, the research added.
Concerns were also raised by the organisation about the practicality of the stricter phasedown for small and large-scale chillers that would require industry to move to systems designed for natural refrigerant in a much more condensed period of time.
It said, “The study assumes that, by 2024, respectively more than 50 per cent of small chillers and 70 per cent of large chillers will rely on water/ammonia as a refrigerant, rather than on HFCs or HFOs, while today to our knowledge only a limited number of units have been placed on the market using water as a refrigerant.”
EPEE said that it did welcome many of the European Commission’s proposals for the F-Gas regulations that would introduce new requirements around how refrigerant is managed in systems. These proposals included new requirements about leaks checks and containment policy, as well as revised requirements on reporting, certification and engineer training for handling lower GWP refrigerants that are expected to replace HFCs in the longer-term.