EU F-Gas Regulation Guidance Information Sheet 2: Commercial Refrigeration
This information sheet is aimed at organisations that are operators (usually the owner) of commercial refrigeration equipment, including food and drink retailers and food service companies. It is also useful for those organisations that manufacture, sell, maintain and dispose of commercial refrigeration equipment.
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.
In the commercial refrigeration sector, the F-Gas Regulation affects the use of HFCs as refrigerants and as blowing agents for the insulation foam used for retail displays and storage equipment. 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 F-Gas Regulation is an important piece of legislation that will result in significant reductions in the emissions of F-Gases. These are very powerful greenhouse gases, with global warming impacts that are several thousand times higher than CO2 (per kg of gas emitted). All EU Member States agree that it is important to reduce emissions of these gases.
This Information Sheet describes the requirements that apply to commercial refrigeration. Further guidance is available – see Information Sheet 30 for a full list and a glossary of terms.
2. Sector description
The commercial refrigeration sector is a major user of HFCs. The majority of commercial end users are in retail (e.g. supermarkets, petrol stations, small shops) and in food service (e.g. pubs, hotels, restaurants). There are 3 main categories of equipment used in the commercial refrigeration sector:
3. Purchase of new equipment
NEW: HFC Bans
The rules for purchase of new equipment depend on the type and size of equipment. For all new commercial refrigeration equipment there is a ban on very high GWP refrigerants from 2020 – this will mainly affect the use of R404A:
For hermetically sealed commercial refrigerators and freezers there is an additional ban:
For central pack systems and other large commercial refrigeration systems there is an additional ban:
The size threshold of 40 kW in Ban 3 refers to cooling capacity. Smaller pack systems and condensing units with a cooling capacity below 40 kW are only subject to Ban 1.
For hermetically sealed commercial refrigerators and freezers Ban 1 and Ban 2 apply to both the refrigerant and the foam blowing agent. Ban 1 will mainly affect the use of HFC 404A as a refrigerant. Ban 2 will also prevent the future use of HFC 134a as the refrigerant and it will ban HFCs 245fa and 365mfc as the foam blowing agents (as these all have GWPs well above 150).
Any foam insulation used in retail displays or cold rooms served by condensing units or central pack systems is subject to 2 further bans that apply to different types of insulating foam:
NEW: Impact of the Service Ban on purchase of new equipment
Purchasers of new commercial refrigeration equipment must be aware that a “Service Ban” will affect certain existing systems using HFCs with a GWP above 2,500 from 2020. To avoid future problems you should select only refrigerants with a GWP below 2,500, with immediate effect. The service ban is discussed in detail below.
NEW: Impact of the HFC Phase Down on the purchase of new equipment
When purchasing new commercial refrigeration equipment you should also consider the HFC phase down. This will reduce the quantity of HFCs that can be sold in the EU – by 2030 there will be an 80% cut in HFC supply. Equipment bought now will still be operating when deep cuts in HFC supply are in force. Irrespective of the bans described above, it makes sense to always purchase equipment using refrigerants with the lowest practical GWP to minimise the future impact of the phase down.
4. Operation of existing equipment
The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance of existing commercial refrigeration equipment containing HFC refrigerants. The exact rules depend on the type and size of commercial refrigeration equipment being used. The regulations affecting existing equipment relate to (a) leak prevention, (b) record keeping, (c) the Service Ban and (d) the use of trained technicians. These requirements are described below.
Leak prevention and mandatory leak checks
The intentional release of F-Gases into the atmosphere is prohibited and operators of all commercial refrigeration equipment must take all measures that are technically and economically feasible to minimise leakage. Where leaks are detected operators must carry out repairs without undue delay.
NEW: Under the 2006 Regulation, the legal responsibility for preventing F-Gas releases was only given to the operator (usually the owner) of the equipment. In the 2014 Regulation there is a similar legal responsibility given to third party contractors carrying out installation, maintenance, leak checking or refrigerant recovery on behalf of operators.
Mandatory leak checks are required on all commercial refrigeration equipment above certain size thresholds. Under the 2006 F-Gas Regulation, the thresholds were set in terms of the physical quantity of refrigerant in the system – those containing more than 3 kg required a regular leak check.
NEW: Under the 2014 Regulation the requirements are similar, but the size thresholds are defined in terms of tonnes CO2 equivalent (CO2e). These new CO2e size thresholds mean that the kg threshold for each refrigerant is different. Refrigerants with a high GWP (e.g. HFC 404A) will have a lower size threshold than refrigerants with a lower GWP (e.g. HFC 134a). Table 1 shows leak testing requirements under both Regulations. Example thresholds are given for HFC 404A and HFC 134a.
Table 1: Size Thresholds for Mandatory Leak Checks
* Leak check frequency is halved if automatic leak detection system is installed
** The threshold for annual leak checks of hermetically sealed equipment is 10 tonnes CO2
The new CO2e thresholds will require some systems below the old 3 kg threshold to be regularly leak tested. As shown in Table 1, the size threshold for HFC 404A is only 1.3 kg. Operators should check which of their systems are affected by the new CO2e size thresholds. Most of the leak checking rules apply from 1st January 2015, continuing the similar requirement in the 2006 Regulation. However, for systems with less than 3 kg, the 5 tonnes CO2e threshold only applies from 1st January 2017.
If a leak is found during a mandatory leak check it must be repaired without undue delay and the leak test repeated within one month to ensure the repair was effective.
Mandatory automatic leak detection
NEW: For all commercial refrigeration systems containing 500 tonnes CO2e or more there is a mandatory requirement for an automatic leak detection system to be fitted. This is a continuation of a similar requirement in the 2006 Regulation, although the size threshold is changed from 300 kg to 500 tonnes CO2e. This will have a significant impact on plants using high GWP refrigerants.
For HFC 404A refrigeration systems, the new threshold for automatic leak detection is reduced from 300 kg to 127 kg. This rule applies from 1st January 2015. The lower size threshold for HFC 404A will affect many central pack systems as they often contain more than 127 kg.
An automatic leak detection system is defined as a “calibrated mechanical, electrical or electronic device for detecting leakage of F-Gases which, on detection, alerts the operator or a service company of any leakage”.
Automatic leak detection systems must be tested at least once every 12 months to ensure their proper functioning.
Operators of commercial refrigeration equipment must keep records for each piece of equipment that is subject to a mandatory leak check (i.e. above the 5 tonnes CO2e threshold). The records that must be kept are similar to those required under the 2006 Regulation:
NEW: Records must be kept by the plant operator for at least 5 years
NEW: Records collected by a contractor on behalf of an operator must be kept by the contractor for at least 5 years
The records shall be made available on request to the UK Government’s competent authority (i.e. the Environment Agency) or to the Commission.
NEW: Service Ban
An important new feature of the 2014 F-Gas Regulation is the Service Ban, affecting existing systems:
In the commercial refrigeration sector this will mostly affect systems that use HFC 404A. The size threshold of 40 tonnes CO2 is equivalent to 10 kg of HFC 404A. Small systems, including hermetically sealed units and many condensing units will be unaffected if they are below this size threshold.
All existing central pack systems and larger condensing units (with more than 10 kg of HFC 404A) will need to comply with the 2020 Service Ban. It will be legal to continue operating such systems, but you will not be allowed to top up any leaks with virgin HFC 404A. Owners of equipment affected by the Service Ban have 3 main options:
Use of trained technicians
All refrigerant handling operations on commercial refrigeration equipment containing HFC refrigerants must be carried out by suitably trained technicians holding an F-Gas handling certificate and working for an F-Gas Certificated company. This includes plant installation, leak testing, maintenance and end-of-life decommissioning.
5. End-of-life requirements
Any commercial refrigeration equipment containing HFCs in either the refrigeration circuit or the insulation foam that is being disposed of at end-of-life must undergo an HFC recovery process.
For central pack systems and condensing units refrigerant must be recovered by a certificated technician before the plant is dismantled. Modern refrigerant recovery machines should be able to remove well over 95% of the refrigerant in an old system. Any insulating foam associated with these refrigeration systems (e.g. PU foam in retail displays and small cold rooms) should be sent to a specialist recovery facility, where the foam can be crushed and the HFCs recovered.
For hermetically sealed commercial refrigerators and freezers any HFC refrigerant or HFCs in insulating foam must be recovered. The whole unit can be sent to a specialist recovery facility where HFCs from both the refrigeration circuit and the insulating foam can be recovered. Alternatively, the refrigerant can be recovered in situ and then the unit sent to a specialist facility for foam recovery.
All recovered HFC refrigerants can either be:
Given the HFC supply shortage that will be created by the phase down process, it is worth trying to send the old refrigerant for reclamation as it may have a good residual value. If the old refrigerant is too contaminated it cannot be reclaimed and must be sent for destruction. It is important not to mix different gases in the same recovery cylinder – as this would render them unsuitable for reclamation.
Reclaimed refrigerant can be used in any refrigeration equipment. Recycled refrigerant must always be used with care as it may be contaminated or of unknown composition. The use of recycled refrigerant with a GWP above 2,500 is restricted to either (a) the organisation owning the plant from which the gas was recovered or (b) the organisation that carried out the recovery.
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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