EU F-Gas Regulation Guidance Information Sheet 25: Understanding CO2 Size Thresholds
This information sheet is aimed all organisations that need to use the “CO2 size thresholds” that appear in several parts of the 2014 EU F-Gas Regulation. This includes end users, maintenance contractors and equipment manufacturers. It is also of relevance to F-Gas producers, importers and exporters.
This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases) including HFCs, PFCs and SF6. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of important new measures. The 2014 Regulation makes use of various thresholds, using “CO2 equivalent”. This Information Sheet provides guidance on how these new thresholds are defined and how they should be used.
A wide range of further guidance is available for other aspects of the EU F-Gas Regulation – see Information Sheet 30 for a full list and a glossary of terms.
2. Use of Size Thresholds in the F-Gas Regulation
Various rules in the F-Gas Regulation use a size threshold. Small equipment below a threshold might not be affected, but above a certain size a relevant rule starts to apply. Thresholds are important as it is not always cost effective or practical to apply certain rules to small equipment. The requirements in both the 2006 and 2014 EU F-Gas Regulations that make use of a size threshold are:
From 2017 product and equipment labels must show the amount of F-Gas in a system expressed in kg and in CO2 equivalent. This information must also be in instruction manuals and advertising material.
3. CO2 Equivalent (CO2e) Size Thresholds
In the 2006 Regulation, the thresholds were based on the quantity of F-Gas, measured in terms of the mass of fluid (in kilograms). For example, mandatory leak checks were required on all refrigeration and air-conditioning systems containing more than 3 kg of HFC refrigerant. The same kilogram threshold applied to all refrigerant types. Under the 2014 Regulation the thresholds have been changed to CO2 equivalent (CO2e). For example, the 3 kg leak checking threshold has been replaced with a threshold of 5 tonnes CO2e.
What is “tonnes CO2 equivalent”? Tonnes CO2 equivalent is calculated by multiplying the mass of gas (in tonnes) by the GWP (global warming potential) of that gas. GWP compares the global warming impact of a gas compared to that of CO2 (which has a GWP of 1). F-Gases have high GWPs.
For the purposes of the 2014 EU F-Gas Regulation, the GWPs to be used in these calculations are those from the UN IPCC 4th Assessment Report. For pure gases, these GWP values are listed in Annex I of the Regulation. Many refrigerant gases in common use are blends, and for these you can calculate the GWP from the proportions and GWPs of the component pure gases (see table 2).
Why has the change to tonnes CO2 equivalent been made? The use of CO2e thresholds creates a lower kg threshold for F-Gases with a high GWP. This penalises those organisations that use high GWP gases and will encourage them to select equipment that uses F-Gases with the lowest practical GWP. This supports the objective of the F-Gas Regulation which is to minimise the global warming impact of F-Gas emissions.
4. Comparison of old and new thresholds
Table 1 shows the 2006 kg thresholds, the new 2014 CO2 thresholds and kg equivalents for a high GWP and moderate GWP refrigerant (HFC 404A, GWP = 3,922; HFC 134a, GWP = 1,430).
Table 1: Size Threshold Used in the Regulations
* The lowest thresholds for mandatory leak testing and record keeping are doubled for hermetically sealed equipment, from 5 tonnes CO2 to 10 tonnes CO2
n/a Not applicable: these requirements were not in the 2006 Regulation
The size thresholds for the high GWP HFC 404A are considerably smaller under the 2014 Regulation than previously. The reporting thresholds for production, import and export of bulk product are more than 10 times lower than in the 2006 Regulation.
5. CO2 to kg Conversion Table
Table 2: Equipment Size Thresholds for Various F-Gases and Refrigerant Blends
This Information Sheet has been prepared by Gluckman Consulting in collaboration with the Defra (UK Department for Environment, Food and Rural Affairs) and Jacobs
This document contains the best information available to date and will be updated as more or different information is made available. It does not seek to provide a definitive view on the legal requirements; only the courts can provide such a view. If there are uncertainties you should always refer to the text of the Regulation and seek qualified legal advice.
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