The objective of this technical bulletin TB/046, is to inform members of the next steps in service and placing on the market bans coming into force on 1 January 2020 under the F-Gas Regulations.
Whether or not the UK leaves the EU with a deal, the one thing that is absolutely clear is that the regulations we currently work within will remain exactly as they are at the moment: phase down steps, service and product bans either in place or coming into force – all will continue as planned over the coming years.
Some of the product (placing on the market) and servicing bans will have major implications for the sector, and it is essential that our members understand what these changes will mean for them.
Product placing on the market bans
EC517/2014, Annex III sets out a timetable for various different sectors and uses of different refrigerants where the sale of these systems/applications becomes illegal after certain dates.
For the purposes of clarity this technical bulletin shall only consider those prohibitions coming into place on 1 January 2020:
The use of virgin fluorinated greenhouse gases with a GWP4 of 2500 or more to service or maintain refrigeration equipment with a charge of 40 tonnes CO2 equivalent or more is prohibited from 1 January 2020. The figure below shows what this threshold means for some common refrigerants currently in widespread use.
There is no restriction on the servicing nor the long-term use of these systems, other than the prohibition on using virgin refrigerants after 1 January 2020. There are no current plans to prohibit the use of these systems in future. Exemptions from this service ban apply to military equipment and also where equipment is intended for applications designed to cool products to below-50c. An extension of the use of fluorinated greenhouse gases with a GWP of 2500 or more applies until 1 January 2030 for:
• Reclaimed refrigerant used for the service and maintenance of existing refrigeration equipment, provided the refrigerants have been labelled in accordance with Article 12(6). Note this is for existing equipment only – reclaimed refrigerants cannot be used in new equipment being installed.
• Recycled refrigerant used for the service or maintenance of existing refrigeration equipment provided they have been recovered from such equipment. Such recycled gases may only be used by the undertaking which carried out the recovery as part of maintenance or servicing or the undertaking for which the recovery was carried out. This means that the service company who carried out the recovery of the used refrigerant can recycle the recovered charge and re-use on the same systems, or the end user can retain the recycled refrigerant to re-use on their systems.
See REFCOM TB/023 Refrigerant Recovery for further definitions and clarification on the recovery, reclamation and recycling processes.