Framework conditions for the use of refrigerants in Europe/Switzerland
The use of synthetic refrigerants is facing increasing political pressure in Europe, including Switzerland. This article discusses the reasons for the tightening of the European framework, potential effects of a ban on PFAS (perfluorinated and polyfluorinated alkyl substances), the EU F-Gas Regulation, the revision of the F-Gas Regulation and the legal framework in Switzerland. It also provides the views and recommendations of the Swiss Refrigeration Association (SVK).
Reasons for the tightening of the European framework conditions
There are two main reasons for the political pressure against synthetic refrigerants in Europe. First, many synthetic refrigerants have a high global warming potential (GWP) and contribute significantly to global warming. The F-Gas regulation aims to promote the use of low GWP refrigerants. Second, PFASs, a group of substances used in various products, including some refrigerants, pose significant environmental and health risks. The European Chemicals Agency (ECHA) has proposed a comprehensive restriction on PFAS that would affect several commonly used refrigerants in heat pumps and refrigeration systems.
Potential impact of a PFAS ban
A ban on PFAS would affect refrigerants such as HFC R125, R134a, R143a, and HFO R1234yf and R1234ze(E), which are included in many alternative refrigerant blends currently in use. R-404A and R-410A would also be affected. Such a ban could lead to shortages and increased costs for these refrigerants, which could impact the refrigeration and heat pump industries and increase maintenance and operating costs.
EU F-Gas Regulation
The F-Gas Regulation (EU) No. 517/2014 applies throughout the European Union and regulates the use of fluorinated greenhouse gases (F-gases). It aims to reduce emissions of F-gases and contribute to climate protection. However, the F-Gas Regulation has no direct validity in Switzerland.
Revision of the F-Gas Regulation
The F-Gas Regulation is currently being revised, and the European Parliament has adopted the Environment Committee’s draft with minor adjustments. The industry is expected to face a significant phase-out of F-gases in the near future, with a general ban on new stationary refrigeration systems using F-gases starting in 2025. However, further amendments and compromise negotiations between the European Council, the Parliament and the Commission are to be expected.
Legal framework in Switzerland
European regulations, including the F-Gas Regulation and the REACH Regulation, have no legal validity in Switzerland. The Swiss legal framework for refrigerants and refrigeration systems is governed by the Chemical Risk Reduction Ordinance (ChemRRV), which aims to reduce environmental and health risks from hazardous chemicals. The ChemRRV is regularly reviewed and adapted on the basis of international legal developments and scientific and technical progress.
Position and recommendations of the SVK
The Swiss Refrigeration Association (SVK) recognizes the trend towards natural refrigerants and supports it in principle. However, SVK also advocates reasonable restrictions that take into account environmental, energy, safety and economic aspects. It recommends the long-term use and availability of natural refrigerants such as ammonia, carbon dioxide and water. Customers are advised that although systems using synthetic refrigerants may be allowed under certain conditions, restrictions may occur in the future, such as shortages or refill limitations.
The use of synthetic refrigerants is under increasing pressure in Europe and Switzerland. The tightening of the regulatory framework, potential PFAS bans and the revision of the F-Gas regulation will have a significant impact on the refrigeration and heat pump industry. The SVK supports the transition to natural refrigerants, but emphasizes the need for balanced and feasible regulations. The move toward natural refrigerants is clearly evident around the world, and stakeholders are encouraged to stay abreast of and adapt to the evolving regulatory landscape.