R22 System Options After 1st January 2015

Many businesses are still operating air conditioning systems using R22, therefore this document is to ensure that you remain compliant with new legal requirements.

The Legal Framework

Regulation (EC) 1005/2009 on Ozone Depleting Substances (ODS) which came into effect on 1st January 2010 requires –


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The effect of this regulation is compounded by the recently revised F-Gas Regulation, (EU) No 517/2014, which came into effect on the 1st January 2015.  The revised F-Gas regulation has an impact on what alternatives can be used to retrofit existing R22 / HCFC based systems and on new replacement R22equipment based on HFC refrigerants. The following details how to ensure compliance with both the ODS and revised F-Gas Regulation.

  1. Regulation (EC) 1005/2009 on Ozone Depleting Substances

Use Ban

  • The use of reclaimed R22 or any HCFC for service or maintenance is banned after 31st December 2014.
  • Existing equipment will not have to be decanted of its refrigerant but it must not be charged with reclaimed / recovered HCFCs as of the 1st January 2015under any circumstances.

 

Recovered refrigerant must be destroyed

  • Any HCFCs recovered from after 31st December 2014 must be sent for destruction.
  • HCFCs recovered during servicing or maintenance cannot be returned into the systems and must be sent for destruction after 31st December 2014.

Be cautious when considering retrofit refrigerants

  • If retrofitting existing HCFC plant to a HFC based alternative refrigerant, be very careful what retrofit alternative refrigerants you offer end users.
  • High GWP retrofit replacement refrigerants may come within the bans of the recently amended F-Gas Regulation and future availability is likely to be a serious issue.
  1. New F-Gas Regulation (EU) No 517/2014Limits on HFC use
  • Under the revised F-Gas regulation, the CO2 equivalent value of the HFC refrigerant will dictate when and how much HFC refrigerant a system can use.

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The limits will impact retrofitting

If retrofitting existing HCFC systems to a HFC based refrigerant , be careful what retrofit refrigerant you use as the re-charging of existing refrigeration equipment with a charge size of 40 tonnes CO2 equivalent or more, and an evaporating temperature of -50°c and above with virgin HFC refrigerant of GWP greater than 2500 will not be permitted from 1st January 2020.

The table below shows the threshold limits for some commonly used HFC retrofit refrigerants (sometimes referred to as “drop-ins”). Choosing a high GWP refrigerant will shorten the effective life of the retrofit. Reclaimed HFC refrigerant with a GWP greater than 2500 can be used for servicing above the threshold values shown below until 31st December 2029 but there is no guarantee that they will be readily available.

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Limits on supply of new equipment

If selecting new equipment to replace an existing R22 or other HCFC based air conditioning systems, it should be borne in mind there are many prohibitions concerning the placing of equipment on the market under the revised F-Gas Regulation.

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New requirement to label equipment

From 1st January 2017, refrigeration and air conditioning equipment placed on the market containing F-Gasses shall be labelled with a reference that the equipment contains fluorinated greenhouse gasses, the name of the refrigerant, the quantity of gas expressed in kg and CO2 equivalent along with the GWP value of the refrigerant.

Typical indicative labelling requirement for a system containing 8kg of R410A as follows –

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Introduction of a quota system for supply of pre-charged equipment

From 1st January 2017 refrigeration, air conditioning and heat pump equipment pre-charged with HFCs will not be allowed to be placed on the market in the EU unless the HFCs charged into the equipment are accounted for within the EU HFC quota system.  Site installed equipment without a pre-charge will need to have the CO2 equivalent charge weight calculated by the installer and the equipment label shows as shown above.

Changes to leak checking requirements

From the 1st January 2015, operators of equipment that contain F-Gasses in quantities of 5 tonnes of CO2 equivalent or more that are not contained in foams have to ensure that the equipment is regularly checked for leaks.

This applies to operators of stationary refrigeration equipment, stationary air conditioning equipment, stationary heat pumps and refrigeration units of refrigerated trucks and trailers.

The table below shows the thresholds for some commonly used HFC based air conditioning refrigerants.

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  1. For more detailed information on the new restrictions on refrigerant use see:
  • The DEFRA information website and helpdesk at defra.gov.uk/fgas
  • The Air Conditioning and Refrigeration Industry Board also has lots of information and links to the new regulations at acrib.org.uk