EU F-Gas Hydrocarbons
Visual adaptation of the EU Green Deal Strategy by the Copernicus agency of the European Commission.

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

Ban on certain stationary split air-conditioning and split heat pump equipment containing f-gases would help adoption of R290 equipment.

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

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 ban certain stationary split air-conditioning and split heat pump equipment:

  • As of January 1, 2025, systems that contain less than 3kg of f-gases (listed in the proposal’s Annex 1) that have a GWP of 750 or more.
  • As of January 1, 2027, systems with a rated capacity up to and including 12kW (3.4TR) that contain f-gases with a GWP of 150 or more.
  • As of January 1, 2027, systems with a capacity of more than 12kW that use f-gases with a GWP of 750 or greater.

The first two bans detailed in the proposed EU F-Gas proposal would support the uptake of hydrocarbons-based appliances, such as propane (R290)-based heat pumps and air conditioners in the EU residential market. The third ban would help the adoption of commercial R290 heat pumps.

R290 heat pumps have already gained market share in the European commercial sector, while R290 residential ACs are being marketed by companies like Midea in Europe and Godrej in India.

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.

Heat pumps have gained much attention as a means of decarbonizing heating systems that rely on fossil fuels, as well as a way to avoid using gas imported from Russia, following its invasion of Ukraine.

The EU F-Gas proposal would also increase the number of engineers and technicians 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, such as hydrocarbons used as heat carriers.

In drafting the current proposal, the EC considered suggestions by external consultants Öko Recherche, Ricardo and Öko Institut. The results of this assessment were presented in May 2021 in a background briefing and at a stakeholder workshop.

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.”

Greater reductions of CO2e emissions

Under the new EU 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. This tighter schedule would favour the uptake of natural alternatives, such as hydrocarbons, ammonia/NH3 (R717), carbon dioxide/CO2 (R744), air and water.

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.

“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.”

Frans Timmermans, Executive Vice-President of the European Commission

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