EU F-Gas Regulation 517/2014
The F-Gas Regulation creates controls on the use and emissions of fluorinated greenhouse gasses (F-Gases) which include HFCs. The 2014 EU F-Gas Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing a number of new important measures.
This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014).
Personnel training & certification
Personnel involved in certain activities on equipment that contains, or is designed to contain, F-Gases require an F-Gas handling training qualification. In particular this applies to:
- Leakage checking
- Maintenance or servicing
- Refrigerant recovery
All technicians that carry out the activities detailed above on equipment that contains F-Gases must hold an F-Gas handling certificate.
This requirement applies 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.
For personnel working on stationary refrigeration, air-conditioning and heat pumps, the European Commission Regulation 303/2008 refers to four different levels of certification, which allow personnel to carry out different activities. Category 1 covers all activities whereas the other 3 categories are more restrictive. The categories are defined in Table 1.
The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance of existing refrigeration equipment containing HFC refrigerants. The rules depend on the type and size of refrigeration equipment being used. The regulations affecting existing equipment relate to leak prevention, record keeping and service bans;
Mandatory Leak Checks
Mandatory leak checks are required on all RACHP equipment above certain size thresholds.
Under 2006 F-Gas Regulation, the thresholds were set in terms of physical quantity of refrigerant in the system – those containing more than 3 kg required a regular leak check.
Under the 2014 Regulation the requirements are similar, but the size thresholds are defined in terms of tonnes CO2 equivalent. These new CO2 equivalent (CO2 e) size thresholds mean that the kg threshold for each refrigerant is different. Refrigerant with high GWP (e.g. HFC404A) will have a lower size threshold than refrigerants with lower GWP (e.g. R134a). Table 2 shows leak testing requirements under both Regulations. Example thresholds are given for HFC404A and HFC134a.
The new CO2 thresholds will require some systems below the old 3kg threshold to be regularly leak tested. As shown in Table 2, the size threshold for HFC404A is only 1.3 kg. Contractors should check which of the systems they maintain are affected by the new CO2e size thresholds. Most of the leak checking rules apply from 1st January 2015, continuing a similar requirement in the 2006 Regulation. For systems with less than 3 kg, the 5 tonnes CO2e threshold only applies from 1st January 2017.
Mandatory Automatic Leak Detection
For all RACHP systems containing over 500 tonnes CO2e there is a mandatory requirement for an automatic leak detection system to be fitted.
Mandatory automatic leak detection 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 HFC404A systems the new threshold for automatic leak detection systems is reduced from 300 kg to 127 kg. This new rule applies from 1st January 2015.
Automatic leak detection systems MUST be tested every 12 months to ensure their proper functioning.
Operators must ensure records are kept for each piece of equipment that is subject to mandatory leak checks (i.e. above 5 tonnes CO2e threshold). The records are similar to those required under 2006 Regulation:
- Quantity and type of F-Gas installed.
- Quantities of F-Gas added during installation, maintenance or when repairing a leak.
- Whether the F-Gases used have been recycled or reclaimed (including the name and address of the recycling or reclamation facility and, where applicable, the certificate number).
- Quantity of F-Gas recovered.
- The identity of the undertaking that installed, serviced or decommissioned the equipment, including where applicable, their certificate number.
- Dates and results of mandatory leak checks.
- If the equipment was decommissioned, the measures taken to recover and dispose of the F-Gases.
Records must be kept by the plant operator for at least 5 years. Where a contractor prepares records for the operator, the records should also be kept by the contractor for at least 5 years. The records shall be made available on request.
An important new feature of the 2014 F-Gas regulation is the Service Ban:
- From 1st January 2020 the use of F-Gases with a GWP above 2500 to maintain refrigeration charge size of 40 tonnes CO2e or more shall be prohibited.
In the refrigeration sector this will mostly affect systems that use HFC404A. The size threshold of 40 tonnes CO2e is equivalent to 10 kg of HFC404A.
It is important to note that several refrigerants used as ‘drop-in’ replacements for R22 have a GWP above 2500 and are affected by the Service Ban (e.g. HFC 422D).
It will be legal to continue operating systems affected by the service ban, but you will not be allowed to top up any leaks with virgin refrigerant. Contractors should advise operators of equipment affected by the Service Ban that they have 3 main options:
- They can replace the plant with new equipment using a refrigerant with a lower GWP.
- They can ‘retrofit’ the plant, replacing the refrigerant with a lower GWP alternative.
- You can use reclaimed or recycled refrigerant for plant maintenance until 1st January 2030.
Purchase of Refrigerant
HFC refrigerants shall only be sold to and purchased by certified companies or end users that employ certified personnel. This means that refrigerant suppliers will require evidence that the contractors are certified and qualified to make the purchase.
This applies to refrigerant sold in any size of cylinder. The purchase rule applies to refrigerant sold for the purposes of carrying out the installation, servicing, maintenance or repair of equipment containing F-Gases.
In addition to personnel certification, contractors working on stationary refrigeration systems require a company certificate.
A Company Certificate is required by contactors providing services related to stationary refrigeration, air conditioning and heat pumps.
All contractors working for other parties need a Company Certificate. An end user of RACHP equipment that employs its own staff to carry out the above activities on their RACHP equipment must ensure that their staff have the appropriate personnel certificate, but they do not require a company certificate.
How Callenberg Technology Group can help you
Our fully certified technicians carry out onsite leak testing and assessment of all your refrigeration plant & equipment.
We can also develop, deploy and manage a planned leak testing program to suit your operational requirements and to help you fully comply with all legislation. This enables us to be pro-active and contact you in advance of any pending test requirements and schedule these at you convenience.