F-Gas service ban and product prohibitions

Effective from 1 January 2020

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:

Product or application What does it mean?
Refrigerators and freezers for commercial use (hermetically sealed equiment) that contain HFC refrigerants with a GWP of 2500 or more. Stand-alone self-contained freezers and refrigerators for commercial use; shops, supermarkets, any retail use, etc. can only be sold where they are using a refrigerant with a GWP <2500. It does not apply to multipack systems or split type systems with an external condensing unit.
Stationary refrigeration equipment that contains, or whore functioning relies upon, HFC refrigerants with a GWP of 2500 or more except applications designed to cool products to below -50°C. Any new refrigeration system (including split type) can only be sold or installed where it uses a refrigerant with a GWP <2500. Ultra-low temperature applications such as cryogenics to lover than -50°C are exempt from this prohibition.
Moveable room air conditioning equipment that contains HFC refrigerants with a GWP of 150 or more. Portable AC units, self-contained and designed to be moveable by the end user - normally small units on wheels - can only be sold where they use a low GWP refrigerant <150 GWP.

Service bans

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.

Service bans

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.

You can download a pdf version of this Technical Bulletin TB/046 here.


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