EU F-Gas Ammonia
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EU Releases Proposed F-Gas Regulation, Opening Doors for Ammonia

But the EIA believes the proposal is not aggressive enough with bans of new HFC-based refrigeration, heat pump and air-conditioning equipment.

The European Commission (EC) on April 5 released its long-awaited proposal updating the EU F-Gas Regulation with measures to further clamp down on HFC use in the EU, opening up opportunities for natural refrigerants like ammonia/NH3 (R717).

Key parts of the proposal include accelerating the HFC phase down from 2024 onward – which would reduce HFC use to 2.4% of 2015 levels by 2048 – and improving enforcement and implementation. The F-Gas Regulation proposal would abolish certain exemptions and bring the EU’s HFC phase down fully into line with the Montreal Protocol’s Kigali Amendment.

The proposed regulation would also, as of January 1, 2027, ban split air-conditioning and heat pump equipment with a capacity of more than 12kW (3.4TR) that use f-gases with a GWP of 750 or greater. This ban would include industrial systems that could be replaced by ammonia-based systems.

In regard to heat pumps, the proposal notes that any heat pump equipment with f-gases that is put into operation today will lead to direct GHG emissions for many years into the future due to leakage, necessary servicing with more f-gases and possible emissions when the equipment enters the waste stream. “Where possible this should be avoided, which is why specific product bans are included,” the proposal adds.

The proposal would also increase the number of engineers qualified to handle climate-friendly equipment in Europe as EU member countries would be required to expand their certification and training programs to cover climate-friendly technologies that replace or reduce f-gas systems.

The F-Gas Regulation proposal amends a 2019 directive and repeals the 2014 version of the F-Gas Regulation, which was originally implemented in 2006.

The EC considered suggestions by external consultants in developing the proposal. The results of this assessment were presented in May 2021.

Along with the proposed F-Gas Regulation, the EC also released a proposed update to the regulation of ozone-depleting substances (ODS).

Both proposals will now be negotiated by the Council of the European Union, the European Parliament and the EC in a process that will last about 18 months.

“For decades the European Union has had the world’s most ambitious policy on fluorinated gases and Ozone Depleting Substances,” said Frans Timmermans, the EC’s Executive Vice-President for the European Green Deal, in a statement. “While existing laws have been successful, science urges us to go further and faster now.”

In a nod to natural refrigerant systems, Timmermans added, “Making climate-friendly technologies more widely available will help us reach the EU’s long-term climate goals and encourage countries outside Europe to reduce their F-gas and use of Ozone Depleting Substances too.”

EIA’s critique

However, the London-based Environmental Investigation Agency (EIA) found that the new proposal falls short of achieving important climate goals.

“This proposal doesn’t go far enough to eliminate the use of HFCs and unless it’s significantly amended, it will result in yet another lost decade of climate change action at a time when the world can least afford it,” said Clare Perry, Climate Campaigns Leader for EIA, in a statement.

In particular, the EIA believes the proposed regulation is not nearly aggressive enough in regards to bans of new HFC-based refrigeration, heat pump and air-conditioning equipment. Based on a 10-year-old EC study, “these sectors should have already transitioned to climate-friendly alternatives,” said the EIA.

The issue has taken on new urgency with the Russian invasion of Ukraine. The EC is planning a rollout of 30 million new heat pumps by 2030 to reduce reliance on gas from Russia.

“It is critical that the revised F-Gas Regulation includes robust measures to ensure these heat pumps do not lock in the use of HFC refrigerants, effectively pitting one piece of climate legislation against another,” said Perry. “Climate-friendly natural refrigerants can cover a significant proportion of the heat pump market, so a double climate win is possible – if the Parliament and Council have the vision to make it happen. Waiting until 2027 for bans to take effect is not an option.”

Following the EU F-Gas Regulation, in Denmark a number of district heating plants have adopted ammonia heat pumps to provide heating in lieu of fossil-fuel options.

Another NGO, the Brussels-based Environmental Coalition on Standards (ECOS), welcomed the amended regulation’s phase out of sulfur hexafluoride (SF6) as of 2031, supporting a quicker one nevertheless. Alternatives to SF6 in medium voltage switchgears were already presented at an ATMOsphere event with Schneider Electric in February 2022 and were suggested by the EC’s external consultants.

Greater reductions of CO2e emissions

Under the new F-Gas proposal, the maximum amount of HFCs allowed to be placed on the EU market in 2024-2026 is 41,701,077 metric tons of CO2e, compared to a 2015 baseline of 176,700,479 metric tons. The maximum allowed in 2027-2029 is 17,688,360 metric tons, a significant drop from the current allowance (about 30 million metric tons). The amount allowed from 2048 onwards in the proposal can be no more than 4,200,133 metric tons.

Thus, the proposed F-Gas Regulation would save the equivalent of 40 million tons of CO2e emissions by 2030 beyond the expected reduction under current legislation, reaching total additional savings equivalent to 310 million tons of CO2e by 2050, the EC said. This would reduce the potential climate impact of new HFCs coming onto the EU market by 98% between 2015 and 2050, the EC said. The previous iteration of the regulation had an 80% reduction over the same time period.

The EC said the proposal would also make it easier for customs and surveillance authorities to control imports and exports, cracking down on the trade of illegal f-gases and equipment. Penalties will also become “harsher and more standardized.” The quota system will be “limited to genuine gas traders through stricter registration rules and the introduction of a fixed quota price,” added the EC.

In addition, a broader range of substances and activities would be covered and the procedures for reporting and verifying data would be improved.

Along with the proposed EU F-Gas Regulation, the EC’s new proposed regulation on ODS is also expected to contribute to the EU’s climate objectives. With this amended version, the EC wants to prevent the equivalent of 180 million metric tons of CO2e and 32,000 metric tons of ozone depleting potential (ODP) emissions by 2050. Higher ambition, modernized management systems and improved monitoring and enforcement are the main amendments presented in the text.

“While existing laws have been successful, science urges us to go further and faster now.”

Frans Timmermans, the European Green Deal

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