The industry will have to deal with some major regulatory changes over the coming months, but Tony Williams believes they will have a positive impact on professionalism and system performance
The European Commission is poised to make major changes to the F-Gas Regulation aimed at reducing the amount of refrigerant gas with global warming potential used in cooling and heating equipment.

The industry is also racing to deal with the total phase out of R22 that comes into force on 1 January 2015.

The F-Gas Regulation was adopted by EU member states in 2006 and industry bodies estimate that it will have reduced emission rates by 40% by 2030. However, the European Commission is keen to tighten up the rules still further.
This year's review of the Regulation proposed two key improvements that members of the Building & Engineering Services Association (B&ES) have been calling for and which are currently being considered by the European Parliament.

Firstly, it looks like that there will be a ban on manufacturers pre-charging non-monobloc air conditioning and heat pump systems from 2015. This should prevent the DIY and 'cowboy' element from importing products and selling them via retail outlets so will be crucial in reducing refrigerant leakage.

If systems are supplied without gas, then end users will have to come to professional companies to get them tested and charged. Although all pre-charged systems must currently be installed, serviced and maintained by an F-Gas certified company - and leak tested on installation - if they contain 3kg or less of refrigerant gas they do not need to be regularly leak tested or to have a log book, which means their gas content is untraceable.

This perceived weakness in the Regulation is causing increasing alarm because 20 million small heat pumps containing that amount of HFCs are expected to be installed across Europe by 2020. In other words, we would be looking at an additional 60 million kg of unrecorded refrigerant gas on the market without this new proposal.

None of this gas is recorded in national databases because importers only have to report amounts over one tonne. That is a mighty big loophole that the Review is attempting to plug.

The Commission has also clarified the legal situation regarding supply of refrigerant to uncertified operators. From 2015 it will be illegal for a wholesaler to supply the gas to non-certified contractors. With the ban on precharging, this effectively creates a defacto guarantee that installation is only carried out by certified professionals.

This is seen as a vital move right across Europe and is backed by AREA - the European trade body representing air conditioning, refrigeration and heat pump contractors across the whole continent.

'This could be a game changer because it will put the legitimate contractor back in charge,' said AREA President Graeme Fox. 'Brussels has clearly been listening to us. 'EU member states have a legal duty to report the amount of refrigerant gas in circulation, but they only have the vaguest idea how much is out there,' added Mr Fox, who is also a former chairman of the B&ES Refrigeration, Air Conditioning and Heat Pumps Group.

'Importers only have to report amounts over one tonne, but there are millions of split air conditioning systems coming into the EU that are already precharged with refrigerant gas, which is not recorded anywhere.'

A long-term phase down of popular refrigerants, including HFCs, is underway, but European regulators believe more can be done in the short term to limit emissions. It is already illegal to take delivery of f-gas refrigerants without a valid refrigerant handling certificate. From 2015 it could be illegal for a wholesaler to supply the gas to non-certified contractors so leading to a 'de facto guarantee that installation would be carried out by a certified professional', according to AREA.

As well as ensuring only registered installers can handle the gas, a ban on pre-charging would also improve operating efficiency. Pre-charged systems often have too much gas because manufacturers allow for pipe runs from 20 to 70 metres, which many applications don't need.

A ban on pre-charging will ensure systems have the right amount of gas and that there is not more gas in the market than there needs to be. B&ES members say they are often called in to repair faulty pre-charged systems that were bought from retail outlets or DIY stores only to find that all the refrigerant charge has been lost because of poor installation practices. In many cases, that gas has simplyn been vented into the atmosphere.

The second big change is a plan for mandatory certification for ALL refrigerants to support the long-term phase down of HFC equipment. Environmental pressure groups had been pushing aggressively for a ban on HFCs, but now understand the industry's position that the qualified workforce is simply too small to cope with a continent wide replacement programme exclusively using HFC alternatives such as CO2, ammonia and hydrocarbons.

So, they have agreed this compromise that will ensure alternatives and HFCs are professionally handled as part of the better management of all refrigerant gases.

Other proposed changes to the Regulation include mandatory certification for anyone using 'alternative' refrigerants, such as hydrocarbons, ammonia and CO2; and further restrictions on the use of some low cost, but notoriously leaky refrigerants.

The end of R22 in just over a year also marks the end of an era. The grumbling about this decision will continue for some time, but contractors and their clients have to face the fact that they will not be able to use this gas to top up and service refrigeration and air conditioning equipment. Owners of equipment will not be able to buy it.

Many large commercial refrigeration and air conditioning users have already taken the necessary steps to retrofit their systems to gases like ammonia; hydrocarbons; R407C and R404a that are considered to be more environmentally benign because they have no ozone depletion potential - however, there are many thousands more yet to act. So it is going to be a busy time.

However, it is important that we as an industry stress the benefits to our customers if these proposed changes are ratified.

Yes, they do represent draconian regulation and tough environmental rules, but they are not just about abiding by the law. They also have an upside in terms of potential running cost savings; improved overall system performance and a more professional industry. The latter means clients can expect better designed and engineered systems as the norm.

The tighter the regulations become the more expert contractors must be to meet them. Bona fide firms, particularly those in membership of B&ES, embrace these higher standards and look forward to helping their customers achieve the potential long-term benefits.

// The author is chairman of the B&ES Refrigeration, Air Conditioning and Heat
Pump (RACHP) Group //