Mark Vender
In the wake of changes to Europe’s F-gas regulation, which will see HFC refrigerants phased out by 2050 and bans on HFO refrigerants that were at one stage touted as the next generation of working fluids, some industry stakeholders in Australia have raised questions about the process.
Is the F-gas regulation over-reaching its original remit? Is the approach technology neutral? And is industry ready to safely deliver solutions with alternative refrigerants?
HVAC&R News reached out to experts in Europe who have been closely engaged with the revision of the F-gas regulation for their views.
HFOs out of scope?
The Kigali Amendment and the F-gas regulation were created to deal with HFCs and their high global warming potential (GWP). Some claim that these instruments are now being made to do double duty in phasing out HFOs due to concerns about PFAS, dubbed “forever chemicals” because of their persistence in the environment.
At the same time, the EU is considering a ban on the manufacture, placing on the market and use of PFAS in non-essential applications in an ongoing restriction proposal within the REACH regulation (registration, evaluation, authorisation and restriction of chemicals).
One question, then, is whether the F-gas regulation is the right place to deal with HFOs.
Christine Lützkendorf is a Policy Advisor on Fluorinated Greenhouse Gases at Deutsche Umwelthilfe (DUH – Environment Action Germany), an environmental and consumer protection NGO in Germany. She says that the ongoing PFAS restriction proposal under the REACH regulation is an extremely important complement to the EU’s F-Gas regulation, but in no way a double-up.
“NGOs have in fact criticised the EU Commission for not considering the HFO/PFAS point of view enough in the revised F-gas regulation,” she says.
“Our perspective is that if some F-gases (such as HFCs) are restricted and phased out, it is the responsibility of policy-makers to anticipate in their regulation which substances will replace the HFCs and give a strong political signal towards future-proof solutions. From our perspective, this was only achieved in the few places where a total F-gas ban was set, such as monobloc heat pumps, split systems, and switchgear. The rest of the regulation does not restrict HFOs – which I criticise highly from an environmental point of view.”
Lützkendorf also notes another aspect of HFOs and their climate impact.
“HFOs are framed as climate friendly ‘alternatives’,” she says. “However, more studies are now stating significant unwanted side emissions during the manufacturing process, forming of super greenhouse gas R23, feedstock emissions, etc., which shows that these climate friendly claims are not trustworthy and HFOs are no true alternative.”
Dr Daniel Colbourne, co-manager of UK refrigerant consultancy Re-Phridge, says whether HFOs are in or out of scope for the F-gas regulation is up to the policy-makers – and there are arguments for both approaches.
“On one hand, HFOs are still HFCs that happen to have an unsaturated bond,” he says. “In the same way, R1270 or propylene is an unsaturated hydrocarbon; it is still referred to as an HC, not an ‘HO’. On the other hand, some saturated HFCs (such as R134a) are also PFASs. And even though the direct GWP of unsaturated HFCs/HFOs is comparatively low, there are also concerns over the not insignificant emissions associated with some peripheral issues related to these substances, such as production energy and emissions of intermediates and feedstocks from their manufacture, as well as the ease with which they could be counterfeited (e.g., R134a bottled up as R1234yf).”
Alex Pachai is an independent consultant who is a member of the Eurammon technical committee and the International Institute of Refrigeration, and consultant to the Danish Heat Pump Manufacturers Association. He says HFOs are not related to the Kigali Amendment and the Montreal Protocol – but that could soon change.
“The coming F-gas regulation allows the use of HFO fluids (in Annex II), but in the comments they say that if a REACH decision says that they shall no longer be allowed, the F-gas regulation will have to be revised to reflect this.”
Technology neutral?
Another question about the latest F-gas regulation changes is whether they are technologically neutral, or are pushing end-users towards a particular solution.
Speaking from an NGO perspective, Lützkendorf says a push towards natural refrigerants is much needed.
“It gives the whole market and industry a clear path for the future and planning security for their investments,” she says. “In contrast, allowing or pushing problematic substitutes like PFAS/HFOs, which some industry players frame as ‘technology neutral’, is dangerous in all aspects.”
Lützkendorf stresses the importance of three Ps: people, planet and profit.
“There are now many scientific studies that show the concerning effects of PFAS,” she says. “A very recent one states that PFAS exposure may increase the risk of disease in unborn children. Of course, the group of PFAS is very diverse. However, talking F-gases specifically, the F-gas degradation product TFA and its extreme persistence and increasing concentrations in our environment are highly concerning. Allowing the uptake of more PFAS – for example, by allowing more HFO solutions – is a breach of the precautionary principle, which is the leading environmental principle since the Rio Declaration 1992. Moreover, there is a UN human right to a toxic-free environment, which gets violated.”
In terms of the third P, profit, Lützkendorf says that PFAS substitutes also represent a serious business risk in the shape of more litigation, liability risks, higher costs because of limited availability, stricter regulations, and decreased trust of investors, insurers and the public.
“It would actually be irresponsible of policy-makers to not guide manufacturers and end-users towards future-proof solutions, to let them invest in technologies that pose higher business risks and will be prone to future restrictions.
“There is no ‘technology neutral’ if the ‘neutral technology’ is seriously dangerous for people, planet and profit.”
Pachai takes exception to the term “technology neutral”.
“It is a word used by companies that try to avoid changes,” he says. “However, technology neutrality is no longer an option. HFCs were about the global warming crisis; HFOs are about an environmental crisis. PFAS and TFA pollution is everywhere and in everybody, and in some regions even at levels that increases the risk of effects on the human body.
“I have also heard some people say ‘technology agnostic’. If you are agnostic you don’t know, and that is even worse.”
Dr Colbourne argues that what some perceive as a lack of technological neutrality could also be interpreted simply as moving end-users away from more environmentally damaging options.
“There are several non-fluorinated alternatives,” he says, “all of which are currently being used fairly widely. For some types of systems there can be challenges with applying these alternatives, but it is likely to be a minority of cases. Over the past five or 10 years there has been considerable expansion in the uptake of these non-fluorinated refrigerants as well as experience and confidence in handling them. There are of course more than one type of system that can be used to cool and heat a given application, so it is expected that equipment manufacturers will find a way to provide energy-efficient refrigeration for them all.”
A safe and timely transition?
Finally, will the technology be ready to safely deploy natural refrigerants in all applications, especially when options such as R290 are highly flammable? Some have raised concerns that industry was not sufficiently consulted when deciding on the timelines.
Lützkendorf rejects this suggestion.
“The proposal for the new F-Gas regulation that was presented by the EU Commission was carefully prepared and backed by numerous impact assessments that are all open access,” she says. “There have been in-depth studies by renowned experts.
“Some industry players try to act surprised by these regulations – however, almost the same discussions were held in 2014, when the F-gas regulation was revised last time. Moreover, the revision is a several-years-long process that is done in a way that all stakeholders are consulted.”
Regarding the safety concerns around using natural refrigerants, Lützkendorf says that although there are definitely chemical and physical properties that need to be managed, they are by no means show-stoppers.
“For every natural refrigerant, there are established technical solutions that have been on the market for decades,” she says.
In the case of flammable hydrocarbons, Lützkendorf calls for perspective.
“Household fridges have been successfully running on hydrocarbons for a while now, and nobody is concerned about them exploding. Propane bottles of 11kg can be bought in every construction store, and many households have it for their BBQs. Hydrocarbons are in almost all hairspray or deodorant spray cans. And gas heating – that is, using flammable gas for exactly its flammable property and handling it in huge amounts – is a common way of heating in many countries.
“So to summarise, yes, there are properties that we need to take care with. However, they are manageable and are no generic argument against naturals. In contrast, there are many examples that show the willingly misleading framing against naturals by the chemical industry to push F-gases.”
When it comes to availability of products, Pachai says there are already many products on the market using R290.
“We get them from China and elsewhere in Asia, but European companies have also now moved on,” he says. “It is only about sourcing at a contractor level. Companies that have not yet got the products ready will be left back at the railway station.”
According to Pachai, the main challenge will not be the equipment, but providing technical staff with the necessary qualifications. He sees the need for updates to the current education systems.
Dr Colbourne is more circumspect, and says preparedness depends on the manufacturer.
“Many companies have been producing all sorts of systems with non-fluorinated refrigerants for years now,” he says, “either because of market demands or as a means of offering ‘greener’ products, so there is a lot of experience. Others who have not worked with these alternatives may find the timescales for some types of equipment more challenging.”
Concerns about using flammable refrigerants have often focused on split systems. But Dr Colbourne says that several of the world’s largest manufacturers have been developing R290 models. He also notes that the regulation includes a caveat for safety requirements.
“The regulation states that where a particular alternative cannot be applied to a type of system because safety requirements are prohibitive, then the placing on the market ban would not apply,” he says.
The regulation also includes a contingency for situations where the use of alternative refrigerants results in “disproportionate” system costs.
“So, in practice there appears to be a lot of ‘padding’ in the regulation to help soften the transition for more challenging equipment types,” Dr Colbourne says.
“I have also heard some manufacturers praise the decisiveness of the regulation, in that is helps to bypass the perpetual process of implementing new, incrementally lower-GWP refrigerants.”
Have you read through the changes to the EU F-gas regulation, and what are your views on the updates? Let us know in the comments below.
Photo by Beate Vogl.
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