How are F-gases regulated?

The use and emissions of F-gases are managed successfully under the EU’s F-gas Regulation (EU 517/2014), which aims at reducing F-gas emissions by two thirds of the 2014 levels by 2030. This is achieved through a well-established quota system for HFCs and other measures, including training and certification of personnel and maintenance of systems that use F-gases.

The F-gas Regulation review also provides the most appropriate approach to control emissions of HFCs and HFOs by applying containment measures (Chapter II of Regulation (EU) 517/2014) to the HFOs.

HFOs and HFCs play a crucial role in the context of the EU Green Deal and EU decarbonisation goals, including allowing a more widespread adoption of heat pumps, through their efficiency in use, excellent safety profiles, low flammability and increased energy efficiency.

The use of F-gases is also regulated through the mobile air conditioning (MAC) directive. The Directive 2006/40/EC prohibits the use of F-gases with a global warming potential of more than 150 times greater than carbon dioxide (CO₂) in new types of cars and vans from 2011, and in all new cars and vans produced from 2017. It covers MACs fitted to passenger cars and light commercial vehicles.

The traditionally used refrigerant in MAC systems, R134a, has a GWP of 1430. The Directive does not suggest any particular refrigerant or system, leaving the technical choice to the car manufacturers. Almost 100% of new passenger cars sold in the EU use HFO-1234yf (GWP=1) as a refrigerant.

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals EC 1907/2006) is the backbone of the EU chemicals management and, in principle, applies to all chemical substances.

The REACH Restriction process provides a mechanism for the protection of human health and the environment from unacceptable risks posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. As part of the REACH process manufacturers and importers of chemicals provide safety information on their substances that facilitate their safe use and handling. ECHA is the guardian of this regulation. More information can be found here: https://echa.europa.eu/home

In July 2021, the authorities of five European Member States published their intention to propose a REACH restriction for PFAS.

PFAS is a broad, generic term, which includes a multitude of fluorinated compounds containing CF₂ or CF₃ groups. They can be gases, liquids, solids and polymers. PFAS can vary widely in their physical, toxicological and environmental properties. They are used today in a wide range of high-tech high-performance applications necessary to enabling society to function.

The OECD PFAS definition from July 2021 excludes several F-gases (such as R-32, R-23, CF3I, R-152a, and R-22).

The original REACH proposal uses a slightly broader definition and for its data collection it assumes that all F-gases (with at least a CF₂ group) are included, to ensure more complete data. This was updated on 23 February 2022 to align with the OECD definition.

EFCTC believes that F-gases should be excluded from the REACH restriction proposal due to their unique physical, chemical and (eco)toxicological properties, and that the most appropriate way to control emissions of HFCs, HFOs and HCFOs is via the F-gas Regulation, which is currently underway.

F-gases are already controlled through the F-gas Regulation, which requires the reporting of all supplied F-gases. This review can strengthen containment measures for all F-gases. EFCTC strongly believes that F-gases should not be included within the proposed REACH restriction for the following reasons:
 

• F-gases degrade completely in the atmosphere to substances that occur in nature. They are not toxic “forever chemicals”, unlike a number of the products mainly considered as “PFAS”
• Some F-gases produce trifluoroacetic acid (TFA) as a by-product of their degradation. TFA is found in nature, with up to 200 million tonnes in the earth’s oceans
• The effects of TFA from F-gases have been thoroughly investigated, are well understood and judged to not pose a risk to human health or the environment.