Impacts of the European F-Gas Regulation

What does it mean for the Marine Industry?

After much anticipation, the European Union (EU) (Fluorinated) F-Gas regulation has officially been finalized through a passing vote by the full European Parliament. Now that the regulation has been published, many questions remain around just how the requirements will affect refrigerant choices in the marine industry. To help clear the air, we turn to two experts at Thermo King who have been following this topic closely: Michelle O’Neill, vice president of government and public affairs EMEA; and Dermott Crombie, vice president, strategic initiatives.

A previous F-Gas regulation focused largely on the HVAC industry but this new law will extend some requirements such as servicing and maintenance to truck and trailer applications. A cap and phasedown scheme will apply to all HFCs used in the EU regardless of the product application. The new regulation will also ban the use of high global warming potential (GWP) HFCs in some, mainly stationary refrigeration, products.

What is the goal of the EU F-Gas regulation?

Michelle O’Neill:  The purpose of the F-Gas regulation revision is basically two-fold. The first is to push HFC users to use lower GWP refrigerants (e.g. HFOs or other refrigerants), and the second is to strengthen the rules that already apply for leakage checks in the HVAC sector and to extend those requirements to truck and trailer or marine containers that enter EU territory.

Importantly, the new regulation places a cap on HFC supply, gradually reducing it overtime so that by 2030 the HFC supply will be cut by 79 percent. In 2018, the cut will be less than 37 percent. The cap and phasedown is directly applied to chemical suppliers and is GWP weighted. Suppliers will each be given a specific quota of F-gases to supply and that will be reduced over time. Quota will be adjusted when higher GWP HFCs are supplied.  

Coincidentally, the MAC Directive effectively reduces R134a usage by 80 percent, but does so by 2017.

When does the EU F-Gas regulation come into effect and what industries are impacted?

Michelle O’Neill:  The cap and phasedown of HFCs will begin in 2015 and some bans will also be applied in 2014. Any industry using HFCs in the EU is impacted by the HFC cap and phase-down.

Reporting requirements for mandatory leakage inspections cover all HFCs as well as some of the new ultra-low GWP HFCs in the HFO family. Bans apply to a limited number of products, mainly in residential HVAC and commercial refrigeration. Servicing and maintenance leakage inspections apply to stationary products such as refrigeration, air-conditioning and heat pump equipment, as well as fire protection systems and truck, trailer and marine reefers.

Exact details about leakage detection and related training and certification are left to the discretion of member state governments and certification bodies. The European Commission in Brussels will be responsible for administering the phasedown and related quota registry. HFC pre-charged equipment entering the EU will need to be accounted for under this quota system.

What does the EU F-Gas regulation mean for mobile transportation refrigeration in general?

Dermott Crombie: The final F-Gas regulation does not affect systems with less than 40 ton carbon dioxide (CO₂) equivalent charge being placed on the market in the EU, meaning it does not impact any Thermo King system currently on the market.

What does the EU F-gas regulation mean for container refrigeration and Thermo King in particular?

Dermott Crombie: Thermo King marine containers units fall below the 40 ton CO₂ equivalent threshold so are not directly affected by the F-Gas regulation.

Nonetheless, Thermo King is keen to continue to lead in its environmental stewardship. Thermo King was the first company to exit CFCs more than two decades ago, and today Thermo King is looking to solutions that protect the existing installed fleet of Thermo King reefers going forward, and address climate concerns as well. We recognise that safety, efficiency and reliability are intertwined and have a number of functioning drop-in refrigerant solutions in our labs today.

Are other regulations or directives affecting the industry’s direction when it comes to refrigerant use?

Dermott Crombie:  The F-Gas regulation aims to reduce HFC, PFC and SF₆ production by 79 percent by the year 2030. The previously published EU MAC Directive specifically forces the phase-down of R134a by 80 percent by 2017. This significantly changes the commercial playing field for all reefer equipment going forward, and on a much faster timeline.  

In regards to longer-term solutions, a number of proposals refer to refrigerants used more than a century ago. All of these have their challenges:

• CO₂ in vapour compression refrigeration has its limitations, as it does not condense above 28.5 C. This limits its efficiency in higher ambient temperatures and adds system complexity. It also runs much higher pressures than traditional refrigerants.
• Hydrocarbons are fine refrigerants, if the flammability aspect can be satisfactorily addressed.
• Ammonia is also an adequate refrigerant, albeit both flammable and toxic.

There is still work to be done and decisions to be made in regards to lower GWP refrigerant and system designs. We cannot lose sight of the extraordinary reliability afforded by today’s HFC reefers. Our MAGNUM® technology offers the fastest pull-down, lowest box temperatures, lowest weight, and simplest design available, and we need to ensure none of these attributes is lost going forward, no matter what refrigerant is chosen. Important to remember is that any loss of efficiency translates into higher fuel consumption and higher indirect global warming emissions, the very enemy these legislative regulations are designed to fight!

Eighty years ago, people in the developed world ate fresh food, in season, grown within 100 miles of where they lived. Outside those parameters, they ate dried or pickled food. Today, people in the developed world eat pretty much any fresh food they want, anytime, all year round. The container industry is largely responsible and Thermo King aims to keep it that way.

More information about the new EU F-Gas regulation can be found at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2014.150.01.0195.01.ENG

To begin, what is the scope of the EU F-Gas regulation?

Michelle O’Neill: The new EU F-Gas regulation applies directly to the 28 member states of the EU. Member states do not have flexibility in adapting the regulation, as opposed to EU Directives, which are binding but can sometimes be transposed into national laws and go beyond the EU standard. It was created to combat global warming by limiting the use of F-gases through climate and environmental legislation. Chemicals covered in the F-Gas regulation are HFCs (the group that is of primary interest to the marine industry), PFCs and SF₆. An exception is mobile air-conditioning (in e.g., passenger and light commercial vehicles), which is covered by an additional law, the EU Mobile Air-Conditioning (MAC) Directive. 

        Quick Reference Guide

HFCs = Hydrofluorocarbons

PFCs = Perfluorocarboninated chemicals

SF₆ =     Sulfur hexafluoiride

HFOs = Hydrofluoroolefins

CFCs = Chlorofluorocarbons