Laws and Regulations

EU F-gases regulation

EU F-Gases Regulation No. 517/2014 Consequences for the refrigeration, air conditioning and heat pump industry

EU F-Gase regulation

Initial situation

The first version of the EU F-gas Regulation No. 842/2006, which has been in force since 2007, aimed for a significant reduction in F-gas emissions through improved plant tightness and the recovery of F-gases. These included u.a. Requirements for the regular leak-tightness control, special requirements for the training and certification of the personnel as well as reporting on the consumption of F-gases by the refrigerant manufacturers. No bans on use were made for stationary refrigeration systems.

The regulation also established an impact review by July 2011. The commissioned study came to the conclusion that the implementation of the measure is developing positively. However, it became clear that the mid- and long-term targets for reducing direct emissions that have since been defined by the EU can not be met with the original targets. As a result, a procedure for revising the regulation has been initiated.

Key elements of the revised F-gases regulation

Compared to the previous regulation no. 842/2006, there is a tightening up in essential elements, new requirements are added. Here is a list of the most important changes:

Reduction ("phase-down") of the total available F-gases (hydrofluorocarbons), which is defined in tonnes of CO2-AquivaIent - the product of the amount of refrigerant and the respective global warming potential (GWP) Reduced levels from 2015 to only 21% by 2030.

Quota system: To control the refrigerant consumption, quotas are allocated to manufacturers upon request. There is an obligation to report on actual consumption (CO2 equivalent).

For a number of applications, a maximum allowable GWP value of the refrigerant is specified. In various segments, this means a restriction on the use of refrigerants and technologies currently in use as early as 2020 (household appliances from 2015) - with further significant restrictions from 2022 (see Fig. 3).

Regulating the emission control (containment), tightness controls and marking are new rules Regular checks are mandatory from 2016 onwards for a refrigerant charge of 5 tonnes CO2 equivalent, for R134a ≥ 3.5kg, R404A ≥ 1.3kg

F-gas pre-filled systems (such as air conditioners, heat pumps, chillers) imported from outside the EU may only be placed on the market after a period of transition if they are included in the quota system. This is also a reporting obligation by the manufacturer or importer.

The explanations given below mainly refer to the phase-down of F-gases and the limitations of use in refrigeration, air-conditioning and heat pump systems of medium to high power, as well as solutions for the individual segments in terms of refrigerant as well as compressor and system technologies.

Stepped down ("phase-down") of F-gases

The quantity limitation (Figure 1) represents the greatest challenge of the new F-Gas Regulation. It describes the total consumption, ie refilling, leakage, losses due to breakdowns and maintenance, repairs and recycling refers to the average consumption from 2009 to 2012 ,

Abb. 1   Quantity limitation ("phase-down") until 2030


If one considers the average GWP value (around 2200 - 2300) of all HFCs currently used as refrigerants in the EU, then the volume limitation to 21% results in an average GWP of well below 500 (see Fig. 2). All currently available as an alternative refrigerant with GWP <500, except CO2, are flammable, sometimes toxic. Even the low average value suggests that a reduction in consumption due to the planned use restrictions (from 2020 and 2022) alone will not be enough to reach the quantity limits. This also from the perspective of a future increasing demand for refrigeration systems. As a result, alternative refrigerants and / or technologies will in future have to be used in application sectors that are not directly affected by the restrictions.

Abb. 2   Theoretical average GWP values by quantity limitation ("phase-down")


What distribution will result from the future quota regime and the actual demand for F-gases is currently pure speculation. As a result of a significant decrease in consumption of R134a in vehicle air conditioning systems from 2017 as well as a soon to be expected increase in "Low GWP" solutions, it will probably be possible in various applications to use previously used HFC refrigerants or their non-flammable alternatives.

Usage restrictions / prohibitions

As of 2020, the use of refrigerants with GWP over 2500 will be banned in the area of ​​stationary systems. This also applies to the maintenance of new refrigerant systems with more than 40 tonnes of CO2-AquivaIent. This corresponds with R404A and R507A to a capacity of about 10 kg. Exceptions are applications in the military sector and systems with storage temperatures below -50 ° C. Similarly, in existing plants, recycling refrigerants with GWP> 2500 may still be used until 2030 under certain conditions.

As of 2022, only refrigerants with a GWP <150 may be used in "Multi-Pack Centralized Refrigeration Systems", ie widely branched refrigeration systems with at least two compressors, several refrigeration points and more than 40 kW refrigeration capacity, with the exception of the upper level of cascades (with secondary circuit for normal cooling), where refrigerants up to GWP 1500 are allowed, eg R134a.

The following table (Fig. 3) shows a summary of the restrictions on use for commercial refrigerators, freezers and refrigeration systems, as well as an overview of the still permitted refrigerants for the individual application segments. Mobile air conditioners and mono-split air conditioners are also affected by the restrictions, but are not considered in this publication.

Abb. 3   Verwendungsverbote nach Produktgruppen und Kältemittel (Auszug)


Evaluation of refrigerants alternatives with reduced global warming potential

Favorable conditions regarding GWP and the later replacement by HFC / HFO mixtures are offered by R134a. The comparatively low GWP of 1430 allows the use of this refrigerant in the longer term. Its direct, non-flammable mixture alternatives (GWP approx. 600) also enable further optimization of current system solutions as well as a relatively simple conversion of existing systems in the future.

Another option is the HFO product line R1234yf (GWP 4). Volumetric cooling capacity and efficiency are very similar to R134a, but the refrigerant is flammable (A2L safety group). In addition to the special requirements for the system design, this may also require the use of a secondary circuit.

HFO R1234ze (GWP 7, safety group A2L) is sometimes referred to as R134a substitute, but is more than 20% lower in volumetric cooling capacity than R134a. The boiling point (-18 ° C) also limits the application at lower evaporation temperatures a strong. With positive displacement compressors, therefore, the preferred use is in high temperature applications.

Non-flammable alternatives to R404A / R507A (GWP 3922/3985) or R22 with comparable volumetric cooling capacity and efficiency have a GWP of approximately 1300 to 1400. The longer term uses, e.g. Commercial refrigeration systems with a refrigeration capacity of up to 40 kW depend on the actual volume reductions that can be achieved in other refrigeration and air-conditioning sectors.

Recently, non-flammable HFC / HFO blends with GWP approx. 1000 are also being offered as substitutes for R404A / R507A and. However, it should be noted that the volumetric cooling capacity is up to approx. 20% lower than with the reference medium.

Really long-term usable system alternatives are operated to a high degree with flammable refrigerants (HFO, HFC / HF0 mixtures, hydrocarbons, NH3 in large plants). It should be noted that HFO and HFC / HFO mixtures are classified in safety group A2L and therefore the safety requirements are correspondingly lower than for pure hydrocarbons, e.g. Propane, propene (A3). Nevertheless, in various applications with increased hazard potential, it may also be necessary for A2L refrigerants to use secondary circuit systems. Another long-term option is CO2 technology. Depending on the conditions of use, performance and climatic conditions, pure CO2 systems, hybrid systems (low-temperature refrigeration with CO2) and systems with CO2 secondary circuits will become more widespread.

R410A (GWP 2088) has become particularly popular in air conditioning and heat pump technology with rotary piston and scroll compressors. Due to its thermodynamic properties and the good heat transfer properties, R410A enables very cost effective and efficient system solutions.

The refrigerant itself and the products and equipment preferably operated therewith are not subject to any direct restrictions of use. However, here too, the longer-term application options depend on the realizable volume reductions in other sectors of refrigeration and air conditioning technology.

Non-flammable refrigerant alternatives with significantly lower GWP and comparable volumetric cooling capacity and efficiency are not available.

Substitutes with similar cooling capacity and lower GWP are R32 (GWP 675) and mixtures of R32 and HFO (GWP approx. 400 - 500). They have already been tested in different programs, whereby the basic suitability could be proven. Because of the flammability (safety group A2L), however, there are increased safety requirements compared to R410A. This possibly also requires the use of a secondary circuit.

If the specific safety requirements for A3 and B2 (L) products should be allowed, propane and propene (for systems with low refrigerant charge) and ammonia (for example for liquid chillers of higher capacity) are also possible as an alternative. However, the volumetric cooling capacity is significantly lower than with R410A and also the thermodynamic material data show great differences. In the case of ammonia (NH3), the corrosive effect against copper materials must be taken into account. In sum, this means that the compressors are designed differently and also the systems have to be completely rebuilt. This makes it clear that these refrigerants can only be used to a limited extent as direct substitutes.

Because of the already wide variety of alternative refrigerants, the following table contains only a simplified overview of the respective essential mixture components. In the meantime, refrigerant manufacturers are already offering refrigerants under various trade names for testing purposes. Some products are already in the AS

Abb. 3   

Refrigerant alternatives with reduced global warming potential


Die aktuellen Dokumente der revidierten F-Gase Verordnung Nr. 517/2014 können über folgende Web-Adresse heruntergeladen werden:

Mit freundlicher Freigabe von Bitzer Kühlmaschinenbau GmbH 


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