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Navigating the Future of Refrigerants: EU Regulations, Options, and Safety Considerations

Updated: Aug 28

A detailed HVAC system design blueprint showing the layout of ductwork, air conditioning units, and ventilation paths within a commercial building, highlighting the integration of energy-efficient natural refrigerants to meet EU regulations.
The Phase Down & The Bans of Refrigerents

The EU is on a determined path to reduce the environmental impact of refrigerants, particularly those with high Global Warming Potential (GWP). The recent updates to the F-Gas Regulation, effective from 2024, are designed to phase out high-GWP refrigerants, pushing for the adoption of more sustainable alternatives by 2030. This shift presents both challenges and opportunities for businesses and property owners who must now plan their strategies for compliance and long-term viability.


The EU F-Gas Regulation, initially implemented on January 1, 2015, aims to phase down high Global Warming Potential (GWP) hydrofluorocarbons (HFCs) by 2030. This phase-down is managed through a quota system and sector-specific bans on the use of certain high-GWP refrigerants.

The regulation has evolved significantly, with its primary goals being the mitigation of climate change, improving resource efficiency, and addressing environmental health concerns. The EU's F-Gas regulation has positioned itself as a leader in global environmental policy, even preceding the Kigali Amendment to the Montreal Protocol, and in some aspects, surpassing it.


Evolution and Review of the F-Gas Regulation

The first EU F-Gas regulation came into effect in 2006, focusing on containment and service. The 2015 revision introduced a more aggressive phase-down of high-GWP HFCs, which has now been further strengthened with the 2024 revision. This latest regulation, published on February 20, 2024, is particularly ambitious, aiming for a complete phase-out of F-gases in the long term.

Key updates in the 2024 regulation include a more rapid reduction in quotas from 2025 onwards and a significant decrease in the availability of F-gases even for servicing existing systems post-2030. Additionally, Metered Dose Inhalers (MDIs), previously exempt from the quota system, will be included from 2025, reducing the available quota for the Refrigeration, Air Conditioning, and Heat Pump (RACHP) industry.


Market and Export Bans

Alongside quota reductions, the EU has introduced more detailed market prohibitions. These bans target the use of high-GWP refrigerants in new equipment, effectively directing the market towards lower-GWP alternatives. A notable development is the introduction of an export ban starting in 2025, which prohibits the export of RACHP systems that use refrigerants with a GWP of 1000 or higher if these systems cannot be sold within the EU. This measure is intended to prevent the dumping of obsolete equipment in developing countries.


Impact on Heat Pumps

As part of its broader strategy to decarbonize the heating sector, the EU is promoting the widespread adoption of heat pumps. However, concerns have arisen regarding the availability of suitable F-gases, especially for split systems under 12 kW, which will be subject to a GWP limit of 150 from 2027. This has led to a yearly assessment and a possible extra - but very limited – quota for the years 2025-2029. The shift to refrigerants like R290 (propane), which have a low GWP but are flammable, raises safety and liability concerns for manufacturers.

Nevertheless, certain applications, such as small air-to-water monoblock heat pumps, are already using compliant refrigerants like R290, which should minimize the impact of the new regulations on these systems.


Service Bans and Future Compliance

Service bans have also been tightened. From 2025, small refrigeration systems will no longer be allowed to use virgin refrigerants with a GWP greater than 2500, which will particularly affect older systems using R404A. By 2032, this limit will drop further to a GWP of 750, and the servicing of air conditioning and heat pump systems will be restricted to refrigerants with a GWP below 2500 starting in 2026. However, reclaimed and recycled refrigerants can still be used under these restrictions.


Engineers reviewing an HVAC design plan focused on retrofitting existing systems with low-GWP refrigerants, ensuring compliance with the latest F-Gas regulations in a modern office complex.
The Service bans imposed by the 2023 EU F-Gas regulation.

Conclusion

The EU's F-Gas regulation is driving significant changes in the RACHP industry, pushing for the adoption of low-GWP and natural refrigerants. Businesses need to plan strategically to comply with these regulations, whether by retrofitting existing equipment, transitioning to natural refrigerants, or investing in new systems designed for long-term compliance. While natural refrigerants offer a sustainable solution, their flammability and other safety concerns must be carefully managed to ensure safe and effective implementation.


For further inquiries or assistance, feel free to contact us.


For those interested in a more detailed energy or sustainability assessment, we recommend reaching out to our sister company MTSDNC. They provide expert advice on improving the efficiency of existing systems and understanding the impact these improvements can have on your building’s energy rating and sustainability.

 

Disclaimer:

The information provided in these posts is for informational purposes only and should not be considered design advice, specifications, or a calculation template. We assume no responsibility or liability for the use of the information presented. For professional advice or design services, please contact us via our contact form.


 

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