AEFYT experts explain the impact of F-GAS on the refrigeration sector

In your opinion, what does the refrigeration sector expect from the regulation of fluorinated gases?

Lluís Giralt: The industry would like stability, and as few changes as possible, but in Europe we are dependent on the F-GAS regulation, which aims to reduce greenhouse gas emissions through a quota system that progressively reduces them, and restrictions according to the type of application and the GWP of the refrigerant used. Now that the F-GAS has been published, it is essential to interpret it correctly, so that the sector can draw up the necessary strategies to achieve the ambitious objectives of this regulation in the medium and long term.

José María Cabria: The new F-Gas regulation establishes two realities for the market. One is the need to go to low GWP refrigerants in new installations (below 150). The other is what to do with the current installed base that, let's not forget, is where the biggest challenge lies, as 80% of existing installations still operate with gases above 150 GWP, typically in the region of 1300.

Lluis Giralt: Several technologies are available with GWP below 150, such as HFO-based fluorinated gases, and so-called 'natural' refrigerants (CO₂, ammonia, hydrocarbons...). A single refrigerant type cannot cover all refrigeration applications, in terms of efficiency or compliance with current safety regulations, and therefore all these technologies will be needed for this transition.

José María Cabria: The F-Gas not only speaks of new facilities, but also, and first of all, on how to deal with existing installations and the importance of controlling leaks, which are the biggest cause of CO₂ emissions into the atmosphere in a refrigeration installation. There is no point in switching to other refrigerants if we do not adopt a culture of leak awareness, especially with refrigerants such as CO₂, with working pressures around 6 times higher, where any leakage means that the installation is enormously inefficient. As we often say, there is no gas with a lower GWP than that which remains in the installation.

Until 2032, installations can be recharged with new gases up to 750 GWP. However, there is no limitation on recharging installations with reclaimed or recycled gases, something that the market has been doing for years, recovering this gas from old installations that have been refurbished. This point is of tremendous importance and all owners and installers on the market should be aware of it.

Lluis Giralt: We also have to bear in mind that this regulation leaves the door open to exemptions for medium GWP refrigerants if, for safety reasons, refrigerants with a GWP of less than 150 cannot be used, and that there will be new revisions in the future.

How important is it that these reviews take place as soon as possible?

Lluis Giralt: Very. We anticipate that by 2026 there will be a major lack of availability of medium GWP refrigerants (e.g., 1500), which are almost 80% of those used in refrigeration today. As a result, many existing facilities will not be able to be maintained. Changes to refrigerants with a GWP below 150 are not as quick as with direct replacement refrigerant gases, but, depending on the case, different parts of the installation will have to be changed or even completely replaced. This means that end customers must be prepared for these investments, which, depending on the technology chosen, can be very significant. Another problem that has been a problem for years is the lack of refrigeration professionals, which will be even more acute when all these changes have to be made. For all these reasons, it is important to clarify the latest approved F-GAS revision, and to work with low GWP refrigerants now, not only in new but also in existing installations.

José María Cabria: Moreover, it is very important to consider that HFC prices already underwent a very steep increase last year. In the first quarter of 2023 alone, R448A (currently the most widely used gas in commercial refrigeration) was up 17% compared to the first quarter of 2022 (Source Öko-Recherce), and R134a (present in virtually all subcritical facilities) was up 48%. This trend will continue to grow exponentially and, more seriously, the availability of new gases of this type will be significantly reduced, putting the sector's activity at risk.

It is therefore vitally important that we check for leaks. The average leakage rate in Europe is 30%, which is an absolute atrocity that can be fixed. Leakage at 0% in a refrigeration plant is practically impossible to achieve, even in new facilities, but nowadays it is already possible to keep leakage between 3% and 8%. Any facility that leaks more than 10% will be putting its operability at risk in a scenario of gas shortages and uncontrolled prices, not to mention other factors associated with leakage, such as the exponential increase in electricity consumption and premature ageing of the installation.

It is impossible to revamp the facilities of the 20,000 plus supermarkets still operating in Spain with HFCs in some seven years. There is neither the investment capacity to undertake this titanic task (even more so when many of these installations are still in repayment periods), nor sufficient personnel or materials on the market. It is therefore critical to establish an action plan that takes into account both the facilities to be upgraded and the facilities to be kept and to reduce leakage in both, because both are harmful to the environment and to the profitability of the properties.

in what ways could the new regulation benefit or harm the sector?

Lluis Giralt: Change always creates opportunities for growth, and those who do not succeed will fall by the wayside. The change of installations will lead to years of high investment in the sector, and we will make our facilities more environmentally friendly. A major danger in the face of high product shortages and refrigerant price increases is that the black market for high-GWP refrigerants will increase, affecting the entire industry, as it will make the transition to low-GWP refrigerants impossible, and all the professionals who have invested in or prepared for these changes will have been in vain.

Also due to the tensions in the market, we have detected that there are technicians, usually unqualified, who neglect the safety of facilities and, consequently, that of people, by using highly flammable hydrocarbon-based refrigerants in facilities designed for non-flammable use without having made any prior changes. This practice in the refrigeration sector has been reported and banned by the Spanish Ministry of Industry.

José María Cabria: In short, regulations are usually a catalyst for market activity, and this new regulation will be the same, but even more important is that we all manage to establish sensitivity to the problem of leaks, banish the myth that 'it is normal for a facility to leak more than 10%', or that there are even annual budgets dedicated to covering the purchase of gas to refill installations, as if gas were a consumable that disappears no matter what.

It is the responsibility of all market players, legislators, manufacturers, installers, maintainers and properties, to raise awareness of the serious problem of refrigerant gas leaks and to train and remedy them through a series of monitoring and preventive maintenance systems, and the work and professionalism of qualified refrigeration companies that maintain these facilities and have the knowledge to repair these leaks.

What other aspects of the F-Gas would you highlight?

José María Cabria: Undoubtedly, the F-Gas is a regulation with a focus on sustainability and environmental care. Within the F-Gas, as mentioned, there are several alternatives to solve the current problem. It will be crucial to understand all options – there is no one-size-fits-all option – and also to analyse the acquisition cost, but more importantly, the return on investment, payback period and cost per TCO₂e for each of the alternatives. In this respect, there is no more cost-effective option per TCO₂e than monitoring and reducing refrigerant gas leakage.

Lluis Giralt: Finally, we must stress that the F-Gas foresees a review in 2030, and we will keep an eye on possible modifications.