Keeping cool with refrigerants: The F-gas review

Summary

F-gases are covered by the Kyoto Protocol, which commits the EU to reducing its greenhouse gas emissions by 8% between 2008 and 2012.  

In 2006, the EU adopted two pieces of legislation to constrain the use of HFCs (see EurActiv LinksDossier):

• A regulation – enforceable directly at national level – was passed to cover air conditioning systems, industrial refrigeration and other 'stationary' industrial applications. Domestic refrigerators were excluded. Obligations covered the containment of leakages, recovery of used equipment, labelling of products, reporting of emissions data to the EU, and a ban on the use of some F-gases, such as SF6 (magnesium dye-casting).
• The 'Mac Directive' was also passed, phasing out F-gases for use in 'mobile' car air conditioning. The directive bans gases with a global warming potential (gwp) of more than 150 for all cars as of 2017 (as of 2011 for new cars coming out of factories). The gwp scale measures greenhouse gas trapped in the atmosphere relative to a unit of carbon dioxide (standardised to 1). The directive banned HFC-134a, which had a gwp of 1430 and led to an industry-wide shift to a less damaging HFC called 1234yf, with a gwp of 4.

Review

The European Commission was mandated to publish a report on the application of the F-gas measures by 4 July 2011, following a public consultation which closed earlier in January. Öko-Recherche, the consultants responsible, submitted a preliminary report to the European Commission in July.

The report recommends that on top of the 2006 legislation, "further reductions of F-gas emission may be appropriate and these will need to be based on additional policy measures".  Among other things, these would cover HFC emissions from mobile air conditioning systems in ships, rail vehicles, transport refrigeration and refrigerated ships.

It also recommends a review of the Mobile Air-conditioning Systems (MAC) Directive to address the air conditioning systems contained in all types of motor vehicles. "Bans have been the most effective type of measure so far and resulted in significant and measurable reductions of F-gas consumption and hence emissions," the report says.

Nonetheless, it continues, "the option to establish step-wise gwp-weighted limits for the placing on the market of HFCs has been identified to show the highest emission reduction potential of up to 64 Mt CO2 eq. at abatement costs of ca. 18 €€/t CO2 eq. on average while including all sectors relying on HFCs".

Following an October 2011 impact assessment, the Commission will decide whether or not to propose changes to the F-gas regulation later in the year. Many issues will need to be resolved first.

Issues

Global warming damage caused by HFCs

F-gases are more damaging to the planet than carbon dioxide and the most widely used one, HFC 134a, is over a thousand times more potent than CO2 in causing global warming.

The release into the atmosphere of 300 grams of HFC 134a – the amount needed to power a domestic refrigerator – would thus cause as much carbon emissions as driving a Volkswagen Golf from London to Moscow, according to Greenpeace, the environmental pressure group.

Industry asserts – and environmentalists accept – that F-gases currently only make up a small percentage of carbon emissions, probably around 1% or 2%. According to Tim Vink of US conglomerate Honeywell, "it is not a very substantial part of the [global warming] problem, as it were," although he noted that if all potential emissions from refrigeration units were released, that would change.

Even so, the UN Intergovernmental Panel on Climate Change (IPCC)'s measurement of "radiative forcing" estimated that the built-up presence of F-gases in the atmosphere accounted for 17% of the total human contribution to climate change in 2005. 

One of the most famous studies, the prestigious US National Academy of Sciences's report in 2009, predicted that if business were to continue as usual, HFCs would be responsible for between 9% and 19% of carbon-equivalent emissions by 2050. If emissions of CO2 were stabilised but HFC use were to continue as normal, that figure would rise to between 28% and 45%.

HFC manufacturers, represented by the European Fluorocarbons Technical Committee (EFCTC), responded by calling for consideration of technological developments in the industry, raw material constraints, and more regulation.

In private, F-gas advocates today argue that although the emissions trends of the future are disputed, HFC use in the EU is already dropping, partly due to EU legislation adopted in 2006. A decoupling is already taking place between sales of industrial equipment and HFC emissions, they claim.

One source in the F-gas industry told EurActiv that the National Academy study had been "irresponsible" because the assumptions underlying its projections had been drafted in such a way as to "promote the issue" in advance of climate change talks.

"It was not a valid scientific comparison," he said. "It came out with a rather skewed look at the future." However, the report has been accepted by governments and international agencies all over the world.

Is new legislation needed?

In 2006, the EU adopted two pieces of legislation to curb F-gases – one dealing with 'stationary' items, such as fridges, and one tackling car air conditioning systems (see 'Summary').

Part of the legislation focused on training and certification schemes to ensure that workers handling the powerful gases do not leak them into the atmosphere, where they cause lasting damage.

By January 2011, between six and eight EU member states had still not notified the European Commission of their certification/training systems for working with refrigerants, according to a 2011 progress report by Okö-Recherche, a consultancy.

Not all importers of products and equipment subject to labelling and certification requirements were complying with the new legislation either. Applied recovery and containment measures for F-gas installations also varied widely between EU member states.

The result was that powerful greenhouse gases stored in European refrigerants and air conditioners were still leaking into the atmosphere.

David Holyoake, legal advisor to Client Earth, an environmental NGO, said that industrial sources were whispering about obligations going unmet. "You've got people out there leaving the valves open while they go and get a spanner from their suitcase allowing small but terrible amounts of HFCs to escape," he told EurActiv.

His concerns were reinforced by an EU official who told EurActiv that, in sectors such as foam manufacturing, highly qualified personnel servicing the equipment, putting in refills, and checking for leaks made little difference once the equipment was ripped out of the building, and the gases were vented into the atmosphere.

But while certification and monitoring failures lead environmentalists to call for tougher legislation, with fewer loopholes, F-gas manufacturers argue that they illustrate a need to enforce existing legislation better.

"It is a bit difficult to judge the size of the regulation's impact on emissions reduction now," said Andrea Voigt of the European Partnership for Energy and the Environment (EPEE), a chemical manufacturers' association. "It would have been better if we could have waited a little longer to see exactly what the impact has been," she told EurActiv. 

Costs to industry

If new EU legislation were to phase out HFCs, their proposed replacements – natural refrigerants such as ammonia, propane, butane and CO2 (a harmless chemical in air conditioners and refrigerants) – would be more environmentally friendly but also more expensive, at least in the short term.

F-gases were introduced in the 1990s to replace the ozone-depleting CFCs and HCFCs. The last phase-out of CFCs cost one industrial manufacturer about $100 million, according to a company representative contacted by EurActiv. Nowadays, the cost of phasing out HFCs would "probably be much higher," an industry source explained, "because HFCs share a lot of the same characteristics as the ozone-depleting refrigerants".

Environmentalists accuse industry groups of exaggerating such expenses. 

As well as being technologically novel, industry groups argue that natural refrigerants are often flammable, volatile and toxic. Because of this, manufacturing warehouses must be situated outside urban areas, they say, and insurers will not cover liability costs. 

Environmentalists counter that once a general shift has taken place to natural refrigerants – which have a global warming potential (gwp) thousands of times less than F-gases – no further transition costs will be needed.

Natural refrigerant manufacturers "are working very hard to make sure that their systems are more energy efficient so that you actually save money," Marc Chasserot, managing director of Shecco, an environmental marketing and communications company, told EurActiv.

Chasserot accepted that the initial investment costs per unit for a new system would be "a little bit higher" but argued that the sums involved should be calculated over a product's entire lifetime.

Officials at the European Commission say that they will be sensitive to the industrial costs borne by manufacturers if and when they draw up a proposal, but that the costs and benefits to society as a whole also need to be considered.

Developing world objections

Some of the strongest objections to a switch-over to natural refrigerants have come from the developing world. These have been made on grounds of cost, and a suspicion that Western manufacturers would transfer the greatest burden to them.

Tim Vink of refrigerants manufacturer Honeywell told EurActiv that there were good arguments to convince the developing world that energy- efficient natural refrigerant proposals could help their development goals.

"They currently don't have targets under the Kyoto Protocol but sooner or later they will become part of the control regime for greenhouse gases," he told EurActiv. "Possibly they're trying to maximise their negotiating position ahead of cuts that I think they accept will be inevitable in the longer term."

EU officials noted that a phase down of F-gases spread over many years would give developing world industries a chance to adjust. One observed that a precedent already existed in that F-gas machinery had been installed by Western manufacturers in the past.

Safety first

Industry sources say that natural refrigerants provide a headache for safety consultants, and have led some major projects to scale back planned installations. Recently, a decision was taken by London's Olympic Delivery Authority to scale back its planned use of ammonia in venues that could not be catered for by the Authority's central energy hub.

"If you go into substances that are highly flammable, toxic or explosive, you have a lot more serious safety concerns to take into account," one industrial source told EurActiv. "For us – if we ever did have an accident – we would incur the liability, and that is again a very big cost."

Even so, in 2010, the number of UK stores using climate-friendly refrigeration grew from 46 to 239, according to a report by the Environmental Investigation Agency, and Coca-Cola announced a plan to go HFC-free by 2015.

Opponents of F-gases also note that CO2, the number one natural refrigerant, is neither flammable nor explosive, although it does require careful engineering. High ambient temperatures in southern Europe, however, make CO2 refrigerants a less attractive option there than in the north of the continent.

Despite this, the safety credentials of F-gases such as 1234yf, which were rolled out to replace R-134a, a first generation CFC replacement, remain in question. The German Environment Agency UBA last year concluded that 1234yf was highly toxic and should not be used in car air conditioning systems. 

Environmentalists contend that they face a "perverse" market arena in which less energy efficient HFCs can replace their predecessors with official sanction, while natural refrigerants constantly need to prove their efficiency bona fide.

Consultant bias or Lobbyist meddling?

When Okö-Recherche was commissioned to write the European Commission's review of F-gas legislation, the European Fluorocarbon Technical Committee (EFCTC) sent a letter to Brussels noting that the consultants' expertise was in "technical analysis and promotion of alternative refrigerants rather than the fluorinated gases" and that "this could potentially conflict with the work to be carried out for this report".

The EFCTC declined to share further contents of the letter. But Jacques de Gerlache, a spokesman for the EFCTC, confirmed their doubts to EurActiv. "We wondered whether the consultants would be the most neutral," he said. After the report's publication, "we made some very constructive comments suggesting changes or bringing some information and were a bit frustrated to see that few of those inputs were taken into account".

At Client Earth though, David Holyoake said green influence on the report was over-stated. "I was locked out of the stakeholder group and so were a number of NGOs," he told EurActiv. "That was the only opportunity for formal engagement with Okö-Recherche – who were also sat at the table – or the Commission."

Phase-down or phase-out?

One of the most crucial debate in the review is whether F-gases should be the subject of a "phase-out" (a ban), or a "phase-down" (strict climate-friendly regulations), and over what time period these should be implemented, if at all.

One industry representative complained to EurActiv that the Okö-Recherche report offered the Commission "a choice between a phase-out and a phase-out". But EU officials said all options remained on the table.

"A 'global warming potential-weighted' system has advantages because it allows a mix, and offers the producer and the consumer a choice in the longer term," one said. "On the other hand banning [HFCs] may have a more dramatic and instant impact. It gets rid of the worst performing [substances] and makes space for the better performing ones."

Similar issues are being addressed in the Montreal Process, where a North American proposal for a global phase down of HFC production, spread over thirty years, is still being considered. At a Montreal Protocol conference in Bangkok last November, EU states made up 28 of the 91 signatories to an initiative to extend the CFC treaty to HFCs.

However, the world's three biggest producers of HFCs – China, India and Brazil – refused to support the plan.

Positions

cThe European Commission is playing its cards close to its chest on the F-gas review at this stage.

One official told EurActiv that alternatives to F-gases had to be considered before a phase-down could be entertained. If there were not any, he said, it would be harsh to force an industrial overhaul. A gwp-weighted mix would allow producers and consumers to choose the most efficient product for the function they wanted, he continued, because some gases with higher gwp were more effective at conducting heat than others at a lower gwp. The amount of energy needed in all stages of the process - including the changeover - were another factor in the mix.

The director of environmental marketing and communications company Shecco, Marc Chasserot, told EurActiv that the problem over the last 20 years of international negotiations had been a lack of education about alternatives to F-gases.

"The chemical manufacturers say 'OK, we'll phase out one product in our range and replace it with another', but they never talk about natural refrigerants because they are not patented and they can't make money out of that," he said. Some industrial firms were now attempting to blend different hydrocarbons without fluoride, such as the pure hydrocarbon formulation HCR188C2 which could be patented. But refrigerants such as CO2 and ammonia remained patent-free, he added.

Chasserot thought that an EU-wide feed-in tariff for natural refrigerants was "an interesting idea" because tariffs had previously kick-started the European renewable energies market. "It would make sense to have that for a few years," he said.

But he noted that many manufacturers were working with both natural refrigerants and F-gases in their portfolio anyway, as a way of spreading their future risk. "The companies that are thinking ahead and looking at what's in the pipeline in terms of legislation and market innovation and trends are rightly looking at alternatives and they see natural refrigerants as a big and important player," he said.

Jacques de Gerlache, who represents F-gas manufacturers at the European Fluorocarbons Technical Committee (EFCTC), told EurActiv that "if F-gases are still used in heat pumps, air conditioning and refrigeration, it is simply because they have specific advantages which in many cases do not raise a real problem with regard to climate change. They have a higher efficiency, and you avoid CO2 emissions because the fuel consumption [with natural refrigerants] is higher than what the HFCs themselves could have".

Andrea Voigt, director general of the European Partnership for Energy and the Environment (EPEE), another industry group, thought that a phase- out of HFCs would not lead to CO2 emissions reductions "because it would push the industry and users to find alternatives which might not be suited for the intended application. It would be counterproductive in that it would very probably lead to higher energy consumption and therefore higher emissions, whereas a phase-down would give industry flexibility to look into alternatives and innovate".

She told EurActiv that machinery installers would be put at risk when handling toxic or flammable substances if a natural refrigerants phase-in were undertaken suddenly, because a training infrastructure was not yet in place. "We support a phase-down but it needs to take into account energy efficiency and safety and we shouldn't be rushed into it," she said.

Her colleague Tim Vink, director of refrigerant manufacturer Honeywell's government relations arm, who also works for EPEE and EFCTC, took part in the same conference call. He agreed with a gradual phase down of HFCs because "as a market-based instrument, it avoids politicians making choices determining which applications products can and cannot be used. It provides legal certainty over a longer time period to the business community enabling them to take investment and technology decisions and then compete in markets".

As far as he could see, there were "no particular problems" with the existing legislation passed in 2006. "A choice had to be made between a command and control regulation or one that recognised the value that these substances bring, but focused on the efforts to minimise emissions," he told EurActiv. "That's exactly what the regulation set out to do." But he acknowledged that some implementing provisions had been "a bit difficult for some member states" because they required certification procedures for personnel and qualification procedures for sectoral companies.

David Holyoake of Client Earth said that enforcement issues were critical. "We infer that there's a chronic lack of certification for the people doing this [installing and maintenance]," he told EurActiv. He questioned why the commission had not started infringement proceedings against EU member states which were not meeting the obligations.

"There's a raft of reasons why it hasn't been enforced," he said. But one is because it was so heavily compromised by industry during the [legislative] process. You have ambiguous prohibition that are sometimes hard to decipher, you don't have cost thresholds set, and you've got exemptions. For example, the Commission says that operators must recover and destroy HFCs in these circumstances unless it's 'disproportionately expensive' – but without any guidance as to what that means".

Weaknesses in the legislation were a key aspect of compliance problems, in his view. He said: "There's also a lack of reporting requirements which puts the onus on companies and authorities to be ever vigilant to go out and inspect logbooks rather than simply having an affirmative duty on operators to report to the member states and Commission all of their activities concerning F-gases. But there's no excuse for EU member states, which have not even set up or notified penalties, turning a complete blind eye to these laws."

Timeline

• l12 Aug. 2003: European Commission adopts proposal for regulation to reduce by almost a quarter projected fluorinated gas emissions by 2010.
• 31 Jan. 2006: Parliament and Council reach compromise agreement on:
  • A regulation on 'stationary' industrial installations such as refrigerators and air conditioning systems.
  • A directive to phase out HFC-134a from car air conditioning systems.
• 6 April 2006: Parliament gives formal green light to compromise deal.
• 25 April 2006: Council adopts rules on fluorinated greenhouse gases and on air conditioning in motor vehicles (press release).
• 2010: Commission to assess need for further action and EU standards in light of progress made on international commitments (post-Kyoto).
• Nov. 2010: Commission opens public consultation on F-gas review (closed in January 2011).
• 2011: Ban on F-gases with a global warming potential of more than 150 being used in newly "type-approved" cars coming out of factories. This effectively rules out the use of HFC-134a.
• Oct. 2011: Commission report on F-gas review consultation.
• 2012: Specific national measures to be lifted in favour of EU-wide standard. 
• By 2017: A ban on cars with a global warming potential (gwp) of more than 150.

External Links

EU official documents

• European CommissionFluorinated greenhouse gases
• European CommissionEU statistics on fluorinated greenhouse gases 2009
• European CommissionEuropean Parliament Regulation on fluorinated greenhouse gases (2006)
• European CommissionMac Directive (2006/40/EC)
• European CommissionImpact Assessment of options to reduce SF6 emissions
• European CommissionStudy on applying the 2006 Regulation to air conditioning and refrigeration systems in transport modes
• European CommissionAnalysis on the Recovery of F-gases in the EU between 2004-2007
• European CommissionAnalysis of F-gas emissions from refrigerators and air conditioners in non-automobile transport sectors

European Union

• European Parliament): Less fluorinated-gases in Europe's atmosphere (10 April 2006) [FR] [DE]
• European CommissionEU F-Gases Regulation and MAC Directive (Powerpoint presentation, 1 March 2006)
• European Parliament legislative observatory (OEIL)Air pollution: F-gas emissions from motor vehicle air-conditioning systems
• European Parliament legislative observatory (OEIL): Climate change: F-gases

Business & Industry

• CAREProducer of alternative refrigerants
• EurofluorApplications
• EurofluorIntroduction to the Flourine Industry
• EurammonRefrigerants: impact on ozone and climate
• EPEEPosition paper on international HFC control proposals
• • European Fluorocarbon Technical Committee (EFCTC)Position - Actual measurements demonstrate that F-gas containment is already working. (March 2004)
• European Fluorocarbons technical Committee (EFCTC) Fluorocarbons and sulphur hexafluroide
• • European Fluorocarbon Technical Committee (EFCTC)Agreement on F-Gas Regulation (1 Feb. 2006)
• • European Partnership for Energy and the Environment (EPEE)
• EurammonRefrigerants delivered by mother nature
• EPEERecommendations for improvement of the F-gas regulation
• Alliance for responsible atmospheric policyARAP
• ARAPGlobal Comparative Analysis of HFC and Alternative Technologies (August 1999)
• ARAPHFC and HCFC Documents

NGOs and Think-Tanks

• Beyond HFCsA campaign promoting natural refrigerants
• SheccoA marketing and communications consultancy, focussed on the natural refrigerant CO2
• r744.comNatural refrigerants interactive platform
• GreenpeaceNatural Refrigerants
• GreenpeaceHFCs: A growing threat to the climate December 2009
• GreenpeaceNatural Refrigerants: The Solutions
• GreenpeaceF-Gas Science
• Client EarthOverhauling EU regulation of F-gases: Legal report 17 March 2011
• Refrigerants Naturally InitiativeWebsite

Surveys and data

• US National Academy of Sciences The large contribution of projected HFC emissions to future climate forcing
• UN Inter-Governmental Panel on Climate Change (IPCC)HFC-23 emissions from HFC-22 production
• Environmental Investigations Agency200+ HFC-free refrigeration stores in the UK
• Öko-RechercheWebsite
• Öko-Recherche Emissions and Reduction Potentials of F-gases in Germany (Oct. 1999)
• Environmental Investigation AgencyChilling Facts III
• IPCCCompilation of technical information on the new greenhouse gases