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F-Gas Regulation

ACRIB &

The F-Gas Regulation Review

By theACRIB F-Gas Implementation Group

as at 28.9.10

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F-Gas Regulation

Timetable for the Review

• First proposal July 2000

• Final Draft published by European Parliament 20th. February 2006

• Published in Official Journal of the EU on 14th. June 2006

• Became law on 4th. July 2006

• Came into effect from 4th. July 2007

• 4th July 2011 is deadline for F Gas qualification.

• 4th July 2011 is deadline for Full Company certification

• July 2011 EU Regulation review report should be published

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F-Gas Regulation

Primary objective:

• To reduce emissions of the fluorinated greenhouse gases (including HFCs) covered by the Kyoto Protocol by:

• Containment and responsible use.

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F-Gas Regulation

Structure & key elements

• Article 1. Scope

• Article 2. Definitions

• Article 3. Containment - prevent/inspect for and repair leaks

• Article 4. Recovery - proper recovery by certified personnel mandatory

• Article 5. Training and Certification - mandatory/restricts sales of F-gas

• Article 6. Reporting - by producers, importers and exporters of HFCs

• Article 7. Labelling - new labels applied by equipment manufacturers

• Article 8. Control of use

• Article 9. Placing on the Market

• Article 10. Review

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F-Gas Regulation

Article 10. Review

Within 5 years of any Regulation coming into force the EU Commission is

required to produce a report based on experience of application of

Regulation. In the case of the F Gas Regulation this must be done by 4th July

2011.

The Commission will:

• Review international & national markets and policies on all F Gases.

• Assess the effectiveness of the current Regulation.

• Identify technically feasible, effective, efficient & consistent options for further EU

action.

• Analyse the economic, social and environmental impacts of identified options.

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F-Gas Regulation

Article 10. Review

The formal review is a 13 part assessment and evaluation process:

1. Assessment of impact on emissions and projected emissions plus cost effectiveness.2. Assess whether additional F-Gases should be added.3. Evaluate Training & Certification Programmes.4. Assess need for new emission control standards.5. Evaluate effectiveness of containment measures.6. Assess/propose modifications to the reporting requirements.7. Assess best environmental practices concerning prevention and minimisation of emissions.8. Summarise development of technology regarding foams.9. Assess if alternatives to sulphur hexafluoride in sand casting is feasible.10. Assess if inclusion of further products and equipment containing F-Gases is technically feasible & cost

effective, taking account of energy efficiency.11. Assess if the Regulation provisions concerning global warming potential of F-Gases should be

amended taking account of technological and scientific developments and need to respect industrial product planning timescales.

12. Assess need for further action in light of existing and new international commitments regarding reduction of greenhouse gas emissions.

13. Where necessary will make appropriate proposals for revision of relevant provisions of Regulation.

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F-Gas RegulationThe Review

The review is being conducted on behalf of the European Commission by Oko Recherche (German Engineering research Company) following extensive consultation. The report on their conclusions is due this autumn (2010)

Actions by ACRIB:• Implementation Group commented on effectiveness of the Regulation

ahead of review report - for the European Commission and DEFRA. • Developed a position paper in July 2010 with input by Technical

Committees of all ACRIB member organisations plus others with specialist knowledge.

• Position paper sent to EC, DEFRA/BIS and Oko Recherche (plus EPEE, AREA and F Gas support).

• Issued Press Release outlining content of position paper (July)

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F-Gas Regulation

ACRIB Position Paper

ACRIB made six key recommendations:1. A public awareness campaign aimed at equipment operators covering

enforcement in combination with a non-compliant reporting service.2. More active enforcement and increased policing of operators’ legal

obligations under the Regulation to take place.3. The introduction of mandatory individual registration and public

databases of company certification scheme members.4.Refrigerant/equipment suppliers to be responsible for ensuring only

appropriately certified individuals are supplied with F Gas refrigerants.5.Government to actively monitor all 3 company certification bodies to

ensure common standards industry-wide. Company certification bodies be authorised to carry out greater verification of applicants.

6.Government to ensure that standards are maintained by the UK’s two bodies appointed to issue individual training certifications.

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F-Gas Regulation

ACRIB Position Paper

Detailed comments by ACRIB:1. Impact assessment - Industry initiatives demonstrate that Regulation is effective

in reducing leakage but too early for full assessment.2. More F-Gases - ACRIB does not believe it necessary to include more F Gases.3. Evaluate Training & Certification - mechanisms weak, high risk of non-

compliance after 4th July 2011 deadline. Registration databases will help plus stds. audits.

4. Emission control - Industry does not believe new emission control stds needed.5. Containment measures - reducing limit from 3kgs to 100 gramms will ensure only

white goods are excluded from scope. Onus on refrigerant supply chain rather than purchaser will improve containment.

6. Producer Reporting modifications - no comment.7. Assess environmental practices - UK initiatives are improving containment and

considering alternatives to F Gas but unquantifiable at this time.

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F-Gas Regulation

ACRIB Position Paper8. Foams Technology Developments - No comment.9. Alternatives to Sulphur Hexafloride - No comment.10. Inclusion of further products and equipment - sales & installation of pre-

charged equipment by unqualified personnel. Mobile A/C top-up containers.11. GWP and Technical Developments - containment and leak tight systems are

better known to improve efficiency thus reducing total direct and indirect GWP. Skills to support alternatives not yet available.

12. Assess international commitments to reduce GWP - No new agreements yet in place so EC should not impose new restrictions.

13. Appropriate revision proposals -Art.3 reduce containment limit from 3kgs to 100 gramms. Art. 5 Mandatory databases for certified companies and individuals. Art. 5 Audit training and certification standards. Art. 5.1 revise to “F Gas shall not be supplied to..” from “only certified persons can take delivery of..”Art. 9 Placing on market bans to include pipe freezing sprays, mobile A/C top up kits, pre-charged equipment. Art.11 Promotion of alternatives should obligate member states to consider current skill base and infrastructure to support alternatives.

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F-Gas Regulation

ACRIB Position Paper

• ACRIB’s position paper was endorsed by AMDEA, ARC, BFFF, CIBSE, FETA, FSDF, HVCA and IOR.

• It was circulated to the Commission, Oko Recherche, AREA, EPEE, IIR and in the UK - Defra, BIS and F Gas Support.

• Addressed both the European Commission and where appropriate the UK Government specifically.

• Included as an appendix “IOR Refrigerant Selection and System Design – the role of HFCs - note 18 issued April 2009”

• Download the full position paper at:www.acrib.org.uk

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F-Gas Regulation

Position Paper response

The immediate response from the UK has been very encouraging:

1. F Gas support will be promoting awareness of the 11th July 2011 deadline for individual and company certification on the basis that industry take up has been low (it is estimated that less than half of those who need F Gas qualification have adopted it).

2. SummitSkills has produced a leaflet on F Gas training standardsand how this can benefit individuals and employers.

3. ACRIB has been invited to face to face meetings with Defra in October to discuss (a) individual certification and (b) recommendations in position paper.

4. There is a special Stakeholder meeting planned for later in October scheduled to follow Commission meetings to consider the review by Oko Recherche.

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F-Gas Regulation

Conclusion

Although outside the ACRIB F GAS Implementation Group’soriginal remit - the position paper representing the UK RACHP industry view ahead of review report was an appropriate action.

It has captured the attention of UK Government and been endorsed by other industry bodies.

Government has confirmed that the review will be a lengthy procedure. UK industry is in a strong position to work with UK Government to further improve containment in order to allow continued responsible use of HFCs into the future.

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F-Gas Regulation

F-Gas Regulation enquiries should be directed to:

F Gas Support - tel: 0161 874 3663www.defra.gov.uk/fgas