Status of the EU F-Gas Regulation

The EU Regulation 517/2014 resp. 2024/573 for control of emissions of fluorinated greenhouse gases contains application bans for substances, partly based on the GWP value of the substance. The most important tool of the Regulation to lower the total emissions of fluorinated greenhouse gases is the phase down scenario, i.e. a stepped limitation of the total emission amount in carbon dioxide equivalents.

New F-Gas Regulation 2024/573 of 2024-02-20

Here the most important contents for refrigeration, air conditioning and heat pumps are collected. The text is available in all official languages of the EU.
The phase down scenario is adjusted slightly in the single steps from 2025 on compared to the Commission Draft of 2022-04 and has become a phase out scenario for HFC until 2050. In the quota for allowed emissions now also the amount for medical dose inhalers (MDI) of ca 10.5 Mt CO₂ equivalent is included. The document lists maximum emission values until 2049 and the value 0 from 2050 onwards. A revision of the scenario is scheduled for 2030.
The number of application related use bans is remarkably enlarged versus the current Regulation. Some definitions have been modified. Some of the definitions for applications and systems are still not unambiguous. Some applications will have to completely quit the use of fluorinated greenhouse gases (FGG).
Further new requirements:

• Export ban for stationary refrigeration, stationary air conditioning equipment and stationary heat pumps that contain or rely on fluorinated greenhouse gases with GWP > 1000 for their function, from 1 year after entry into force of the Regulation, means within 2025, if these applications or systems have a defined GWP related ban.
• Certification and training for handling of alternative refrigerants will become mandatory. The Commission is asked to elaborate the contents and requirements.

Source: https://eur-lex.europa.eu/eli/reg/2024/573/oj

The new emission amounts for HFC are very close to those of the Commission draft, but down to 0 from 2050. Additionally the amounts from 2025 on do, different from now, contain amounts of medical dose inhalers (MDI). This will make availability even worse for other users.

Year	% 517/ 2014	avg. GWP 517/2014	% 2024/573	avg. GWP 2024/573
2015	100	2200
2016	93	2046
2018	63	1386
2021	45	990
2024	31	682
2025	31	682	24,3	558
2027	24	528	12,3	282
2030	21	462	5,2	119
2033			4,8	110
2036			3,8	88
2039			3,5	80
2042			3,1	71
2045			2,7	63
2048			2,4	55
2050			0	0

The column "avg. GWP 517/2014" shows the estimated values up to now and reaches 462 for the year 2030 as average. The column "avg. GWP 2024/573" shows the estimated values calculated from the amounts of the new Regulation. There is only 119 left as average value for 2030, and from 2050 no HFC any more. Thus, the assumption made so far, that a GWP value up to 150 is sufficiently low, does not hold – not even for 2030.

The number of bans for refrigerants with high GWP in applications has been increased in the new Regulation. An X at "Safety exemption" in the following table means that local safety standards can lead to an exemption from the GWP limit. If a line follows with same application and year, higher GWP and no X, the ban is valid for this higher GWP value if safety standards apply.

Application	Safety exemption	Fluorinated greenhouse gases GWP > 2500	Fluorinated greenhouse gases GWP > 750	Fluorinated greenhouse gases GWP > 150	No fluorinated greenhouse gas
Reuse of refrigerant without recycling or cleaning
Service with recycling material		2030
Commercial refrigerators and freezers				2025
Stationary refrigeration, except chillers and except storage < -50°C		2025		2030
Self contained refrigeration, except chillers	X			2025
Service with virgin refrigerant on stationary refrigeration, except chillers			2032
Plug-in room air conditioning and heat pumps, self contained heat pumps, except chillers	X			2025	2032
Plug-in room air conditioning and heat pumps, self contained heat pumps, except chillers			2032
Chillers ≤ 12 kW	X			2027	2032
Chillers > 12 kW	X		2027
Monobloc and other self contained air conditioning and heat pumps 12 .. 50 kW, except chillers	X			2027
Monobloc and other self contained air conditioning and heat pumps 12 .. 50 kW, except chillers			2027
Other self contained air conditioning and heat pumps, except chillers	X			2030
Other self contained air conditioning and heat pumps, except chillers			2030
Split air conditioning and heat pumps air/water ≤ 12 kW	X			2027	2035
Split air conditioning and heat pumps air/air ≤ 12 kW	X			2029	2035
Split air conditioning and heat pumps > 12 kW	X		2029	2033

Proposal of the Commission 2022-04-05

Dated 2022-04-05 a draft proposal for the revision was published: PC Proposal of Commission. The number of application bans is increased, some definitions adjusted and the phase-down scenario adjusted: It contains values beyond the year 2048 for maximum total emissions and proposes significantly stronger steps down than the current Regulation, already from 2024 on.

Source: EUR-Lex - 52022PC0150 - EN - EUR-Lex (europa.eu)

According to the evaluation of industry associations, the new phase-down scenario would mean that fluorinated refrigerants with GWP above ca. 10 would only be available for maintenance of already existing systems from 2024 on. It would rather be a phase-out, which it in fact has been called by renowned politicians of the EU already. This is also visible in an estimation of the average GWP values, e.g. assuming similar tonnages of fluorinated refrigerants needed ongoing, see following table.

A strictening of the Regulation was expected. Associations and companies have given their statements to the proposal.

The column "Avg. GWP 517/2014" shows the estimated values for the current Regulation and reaches 462 as average for year 2030. The column "Avg. GWP proposal" shows the estimated values according to the amounts listed in the new proposal. Both estimates assume a constant tonnage of necessary refrigerant. According to this, for the year 2030 only 114 is the average value and from 2048 only 53. By this, the assumption so far, that a GWP value up to 150 is sufficiently low, is no longer valid – not even for 2030. With this phase-down as background, the new application bans and especially the exemptions "where safety standards make it necessary" are in fact not relevant. At the same time, the processing demands for recycling of refrigerants are increased: Cleaning or refurbishment shall become mandatory. Unfortunately, there is little capacity available and new blends have so far not been planned for recycling because of the delicate patent situations. Thus, also here an important part of the amount could be missing. The importance becomes clear to concentrate on developing and constructing refrigeration and heat pump installations with those refrigerants which surely will be long term available (Long-term available refrigerants).