Die Entwicklung des Einsatzes und der Emissionen von Fluorgasen, insbesondere von vollständig halogenierten Kohlenwasserstoffen (FKW)

1. How are fluorinated gases involved in the destruction of the ozone layer and climate change?

    CFCs (chlorofluorocarbons) are a group of gases that were widely used in refrigeration systems and aerosols, among other things because of their high stability and because they are not very reactive (and therefore not very toxic) from a chemical point of view.

    On the other hand, it became clear in the 1980s that these gases were harmful to the ozone layer, mainly through the chlorine they contained, which was released in the upper atmosphere when CFC molecules were decomposed by the high energy cosmic radiation. They were progressively banned following the Montreal Protocol of 1987 and replaced by other fluorinated gases containing either less chlorine (H-CFCs) which were much less damaging (about 90% less) to the ozone layer because they mostly decomposed before reaching the ozone layer and thus without releasing chlorine atoms or fluor gases containing no chlorine at all (hydrofluorocarbons or H-FC). They also had the property of being usable without having to change also the existing refrigeration or air conditioning installations.

    Meanwhile, these fluorinated gases are also greenhouse gases that contribute to global warming and whose use has since also been regulated.

    Main application areas for hydro-fluorocarbons (H-FC) (UNEP, 2011)

    • Refrigerants in stationary and mobile refrigeration systems (~ 55% of total use of H-FC in 2010, expressed in CO2 equivalent); 
    • Refrigerants for air conditioning (automobile (~ 24%); 
    • Blowing agents in plastic foam insulation (~ 11%); 
    • Propellant gas for aerosols (~ 5%); 
    • Extinguishing agents (~ 4%); 
    • Solvents (~ 1%); 
    • Engraving gas in semiconductor production (~ <1%) 

    2. How has the gradual ban on H-FC been planned?

      While the ban on CFCs and H-CFCs has been regulated and programmed globally via the Montreal Protocol, because of their effect on the ozone layer, the focus today is on the substitution of fluorinated H-FC type because of their global warming potential (GWP). H-FC regulations have been progressively established through the 1994 Kyoto Protocol on greenhouse gases. For its part, the European Union has adopted a strict legislative and regulatory framework, fiscal policies, the setting up of quotas limiting their marketing and adapted technological and economic tools.

      While CFCs accounted for 12 to 15% of total anthropogenic greenhouse gas (GHG) emissions, H-FCs now account for only about 2%. This is the main concrete achievement worldwide in terms of reducing anthropogenic greenhouse gas emissions.

      GWP-Weighted Fluorocarbon Production (1980-2007)

      3. What are the global and European regulatory constraints on H-FC?

        Due to the requirements imposed by international regulations, the initiatives and actions that can and should be taken by non-state actors in reducing the impact of fluorinated greenhouse gases, and in particular H-FCs, are very much framed.

        4.a. The Kigali Amendment to the Montreal Protocol on H-FC
        Through the Kigali Amendment to the Montreal Protocol signed in 2016 by the representatives of 197 States, the industrialized countries pledged to reduce by 45% the use of H-FCs by 2024 and by 85%. % in 2036, taking as a reference the period 2011-2013. In this context, developing countries will begin to cap and reduce their consumption of H-FC starting in 2024.

        4b. The EU Regulation on F-gases and phase-out of H-FC 2014
        The Regulations of the European Union1 initially planned the phasing out of the placing on the market between 1995 and 2015 of the CFC and H-CFC fluorinated gases because of their destructive effect on the ozone layer but also already because of their climatic impact.

        In a second step, the European Regulation on fluorinated greenhouse gases 517/20142, was extended to the category of gases with a GWP greater than 2500, in particular H-FC. It should be noted that the reduction requirements by 2024 of the European Regulation are stronger than those of the Kigali Amendment: 69% against 45% (expressed in tons equivalent CO2 or teq CO2). They include, by 2025, a schedule for gradually decreasing the placing on the market of these substances and the new equipment that implements them, to bring them back in 2030 to 21% compared to the period 2009/2012 (see table below)

        Provisional calendar of bans foreseen by the new E.U. F-Gas Regulation

        4.c European quotas for placing H-FC on the European market
        To stimulate the reduction of high-GWP H-FCs on the market, the European Commission has set up a quota allocation system which applies to producers, importers and distributors of fluorinated gases, on the basis of a schedule of prohibitions of use for certain equipment4.

        Since 2017, the H-FC refrigeration, air conditioning and heat pump equipment ("RACHP") are covered by this quota mechanism which is allocated and re-evaluated every three years. It is possible to transfer them from one company to another but no specific market mechanism has been foreseen and each actor must take care not to exceed its respective quota, including for the H-FC of equipment imported and obtained via authorizations.

        1 E.U. Regulation (EC) No 1005/2009 on substances that deplete the ozone layer 
        2 This Regulation   of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse defines "fluorinated greenhouse gases" as hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride and other fluorine-containing greenhouse gases listed in Annex I , or mixtures containing any of these substances.
        3  www.ademe.fr/sites/default/files/assets/documents/observatoire-gaz-fluores-donnees2016-201709-rapport.pdf
        4 it does not apply to military equipment or equipment intended for refrigeration applications at a temperature below -50°C.

        4. Is the prohibition of H-FC in the framework of European Regulations systematic?

          The prohibition of the use of H-FC does not apply to equipment for which, because of the energy efficiency gains obtained during their operation (via in particular the ecodesign requirements of Directive 2009/125 / EC), emissions expressed in CO2 equivalent over the entire life cycle would be lower than equivalent equipment that does not contain H-FC.

          Meanwhile, fluorinated gases represent only about 20% of the global climate impact of their main sectors of use, namely refrigeration and air conditioning systems, and thermal insulation foams. Most of this impact (70 to 80% in the case of refrigeration systems) comes indeed from indirect CO2 emissions linked to their electricity consumption (manufacturing, maintenance, etc.). Therefore, in the strategies of non-state actors, it is essential not to separate these two aspects in the assessment of the global climate impact of systems using refrigerant gases.

          Similarly, the EU Regulation does not apply where the use of technically feasible and safe alternatives would result in disproportionate costs. Intentional release into the atmosphere of fluorinated greenhouse gases is also prohibited and all technically and economically feasible measures must be taken to avoid accidental releases ("leaks").

          5. What is the evolution of the placing on the market of fluorinated gases in Europe and what are the alternatives?

            As a result of the ban on the placing on the market of H-CFCs since 2015, between 2007 and 2015 volumes of fluorinated refrigerants manufactured in Europe decreased from around 60,000 to less than 40,000 tonnes. In France, the 18% drop in volumes put on the market between 2014 and 2016 was mainly due to the shutdown of a production site.

            In Spain, to remedy the limited effectiveness of previous taxes and to respond to pressure from European and national stakeholders, a tax proportional to the GWP was introduced in 2014 for gases with a GWP between 150 and 4300.

            Recovery and recycling of fluorinated gases

            According to the report by the French organisation ADEME, while industrial recycling facilities are existing, the ratio between volumes recovered to be destroyed and those put on the market is only around 1% in Europe (around 1,200 tonnes in 2015), compared with more than 4% in France. Non-state actors could play an important role in helping end-of-cycle gas collection to avoid PRC emissions, including for CFCs and H-CFCs still in use in older equipment and facilities.

            Alternatives to fluorinated gases

            There are "natural" refrigerants as alternative to fluorinated gases including CO2, ammonia, propane, zeolite. Used at the industrial level, they present limits to their generalized use because some of their hazardous properties: flammability, explosiveness or toxicity. In addition, a new class of fluorocarbons, hydro-fluoro-olefins (HFOs) is an interesting and developing alternative with a shorter atmospheric lifetime than H-FCs and with a very low GWP. They offer similar benefits to H-FC in terms of performance and energy efficiency, but it is likely that in many applications, including refrigeration, they will be classified in the European Union as "Category 2L flammable". Moreover, because of their status as new products, they are protected by industrial patents, which represents an additional cost for their use.

            6. What is the monitoring of the application of the European regulations on fluorinated gases?

              7.a Follow-up by the European Commission

              The frequency of controls relating to the use of fluorinated gases depends on their GWP expressed in tonnes of CO2 equivalent (teq CO2). For example, 1 tonne of H-FC 134a (1,1,1,2-tetrafluoroethane), which is mainly used in automotive air conditioning, is equivalent to 1120 tonnes of CO25. Operators must report annually all movements of the past year by fluid type (stored-purchased-recycled-regenerated-destroyed), including refrigeration truck and refrigerated unit operators that contain fluorinated gases not contained in insulation foams6. A report on the availability of H-FCs on the market will be published by the European Commission in December 2020 before a global report in 2022 that will include a forecast of demand for H-FC until 2030 and beyond.

              7.b. Illegal sales of H-FC in Europe

              As the legal availability of high-PWC refrigerants decreases and the prices of these gases increase, there is an increasing number of illegal sales of refrigerants across Europe, including via Internet sites. However, the political will to stop them seems little or not obvious, as suggested in particular by a recent report from the European Commission which makes no mention of illegal trade in H-FC7 .

              However, some sources have revealed more than 80 offers of H-FC R134a and others in Germany and that a Chinese refrigerant supplier was selling illegally in the EU8. In Poland, there is talk of "massive and growing smuggling of H-FC" but cooperation between the government and some NGOs seems to be producing tangible results. Turkey has been denounced by an NGO in the fight against this problem, and in Greece, the air conditioning and refrigeration industry has accused Bulgaria of introducing, to avoid quotas, H-FC smuggled from from Albania, Macedonia and Turkey.

              Here too, non-state actors can mobilize themselves, particularly at the level of companies and their federations, to set up processes facilitating the denunciation of these practices, by both sellers and acquirers.

              5  www.ghgprotocol.org/sites/default/files/ghgp/Global-Warming-Potential-Values%20%28Feb%2016%202016%29_1.pdf
              6 www.coolingpost.com/uk-news/gouvernement-rejects-f-gas-concerns/  In the United Kingdom, the anomaly resulting from the fact that the general public could buy H-FCs to replenish car air conditioning systems was re-launched. The Environmental Audit Committee insisted that only qualified individuals should be able to manage the fluorinated gases because the legal availability of H-FC to GWP high for unsupervised charging of car air conditioners could undermine the system of quotas and the development of alternative solutions
              7 https://ec.europa.eu/clima/sites/clima/files/f-gas/legislation/docs/c_2017_5230_en.pdf  
              8 www.coolingpost.com/world-news/icool-acts-on-illegal-refrigerant-sales/   www.coolingpost.com/world-news/german-ebay-awash-with-illegal-r134a/   www.coolingpost.com/world-news/poland-swamped-by-illegal-refrigerant/ 

              7. What are the initiatives taken by non-state actors to reduce the uses and emissions of H-FC?

                Weather conditions are important determinants of the utilization rate of refrigeration and air conditioning equipment. Global energy demand for air conditioners is expected to triple by 2050 and will require electrical capacity equivalent to the current total capacity of the US, EU and Japan. The geographical conditions, in particular the most numerous periods of heat waves, lead also to an increase in the consumption of refrigerants. In addition, the average energy efficiency of air conditioners on the market is low, three times lower than the best available; it is even much lower in developing countries that have minimum or no energy performance standards in this area.

                This global inefficiency results in the loss of two million lives each year, due in particular to the deterioration of vaccines in the absence of refrigeration, a high risk of heat stress for about 500 million people or the waste of 400 million tons of food because of the lack of cold chains.

                Non-state initiatives must therefore also accompany actions that are implemented by States, regions and companies to comply with the regulatory agenda. These initiatives can amplify and accelerate the effects of these measures by organizing and coordinating local initiatives that identify transitions that can be adapted to facilities and encourage their owners and / or users to implement them.

                Concrete opportunities implemented for the reduction of uses and emissions of H-FC

                These can be grouped into five main categories and widely applied in each country:
                1. Establish and strengthen the political, institutional and regulatory framework for the gradual reduction of H-FC, including the development of an integrated strategy with other appropriate strategies; example: implement a national import and export licensing regime and introduce or amend an ecological building code;
                2. Raise awareness among the main actors: decision makers, industrialists, end-users and investors;
                3. Launch investment and demonstration projects for the conversion of particular uses or sub-sectors to low-GWP alternatives: the sub-sectors to be targeted depend in particular on the availability, price, efficiency and safety of substitutes, as well as specific national circumstances. This may include alternatives in areas where H-FCs are not currently used, but could be used after H-CFC phase-out, including thermal insulation foams;
                4. Create training for all stakeholder groups: maintenance technicians, but also design engineers of production lines of factories, workers, etc;
                5. Strengthen leak control and efforts to improve the recovery, recycling and reuse of H-FCs, while helping to reduce the quantities needed for a particular use.

                8.a Examples of initiatives at the level of international organizations

                For global H-FC use, the Climate & Clean Air Coalition initiative aims to mobilize the efforts of the private sector, civil society, international organizations and governments by proposing generic initiatives to help ensure transition to low-GWP refrigerants over the next few decades.

                According to the Lawrence Berkeley National Laboratory, a combined transition in the air-conditioning sector to low-GWP refrigerants and greater energy efficiency could produce, by 2050, peak energy savings of 544 to 1,270 gigawatt-hours that is an amount equal to the production of a thousand medium-sized coal-fired power plants9.

                The Rapid Climate Mitigation Campaign, developed by the Institute for Governance and Sustainable Development (IGSD)10, promotes the use of existing laws and institutions, including H-FC, and complements the efforts of the UNFCCC (United Nations Climate Change). It proposes action strategies that can be launched within 2-3 years and then implemented within 5 years in developed countries and within 10 years in developing countries. Note also the existence of the International Energy Agency (IEA) platform that brings together all the information related to refrigeration in terms of energy efficiency and contributes, among other things, to the operational monitoring of the Kigali Progress Process Tracker.

                Evolution of energy consumption and cost of refrigeration systems

                To guide non-state actions, there are tools such as those developed by the Council Working Group on Financial Stability (TCFD)12. It develops recommendations for voluntary and consistent reporting on science-based targets and encourages businesses to better manage them. The TCFD also stimulates the demand for transparency in standardized declarations and encourages investors to value companies that go further in reducing their environmental footprint.

                Another initiative that is entering the testing phase in France is the development by the Fondation 201913 of a form of "circular VAT" that makes it possible to integrate the cost of environmental externalities of products and production processes, including the cost of their climate impact. Non-state agency partnerships with developing countries are very effective in helping governments to develop and accelerate effective policies, standards and programs, including compliance programs and financial incentives to implement plans for implementation of more efficient refrigeration. Thus, the Kigali Cooling Efficiency Program (K-CEP)14 associated with the ClimateWorks Foundation15, was created to integrate energy efficiency into the reduction of high GWP fluorinated gases. K-CEP also supports the Cooling for All initiative, led by Sustainable Energy for All (SE4All), to stimulate action and existing political leadership by creating direct interactions with the Paris Agreement on Climate Change and the 17 Sustainable Development Objectives of the United Nations16. The goal is to bring together talent, expertise and program beneficiaries in a strong and supportive network to share best practices and foster the growing demand for access to refrigeration as part of a clean energy transition.

                8.b Examples of enterprise-level initiatives

                The field of refrigeration is particularly concerned by an intelligent reduction of the climatic impact of fluorinated gases. The consumer goods sector (manufacturing sites or retail stores) has a specific responsibility for actions taken to control greenhouse gas emissions, particularly those of fluorinated gases, in all segments of the value chain. At the crossroads of suppliers and consumers, it concerns almost all the inhabitants of the planet. Despite their proven benefits, low-carbon solutions are not yet widely applied. All alternatives to H-FC refrigerants still have many challenges to overcome in all types of refrigerant systems; this is the case for their flammability, their toxicity, their sometimes less effectiveness and their cost. Evaluating the possible alternatives and achieving a balance between safety, energy efficiency, costs and environmental impact therefore requires a coherent systemic methodology including a good design of refrigeration systems. The latter is essential to prevent refrigerant losses during the installation, operation and maintenance of equipment but also for their decommissioning and disposal at end of life.

                In this context, the Consumer Goods Forum (CGF)17, a global network of some 400 retailers, manufacturers, service providers and other stakeholders in 70 countries, promotes the benefits of low- and zero-carbon solutions worldwide. These also allow companies to increase their competitiveness and identify new business opportunities.

                The objective of the LIFE-IREPRO project18 is to transform the traditional process of producing expensive and rigid industrial non-fluorinated hydrocarbons (ethane, propane, propylene, butene, isobutene and dimethyl ether) into a highly innovative, more flexible and safe economic system. It would also be more sustainable and efficient for low-GWP industrial refrigeration while reducing greenhouse gas emissions, water and energy consumption. It should overcome the obstacles that have hitherto limited the use of hydrocarbons, including their low versatility, the presence of unwanted by-products and the treatment and handling of highly flammable gases.

                Many manufacturers of refrigeration and air-conditioning systems who had redesigned their systems to no longer use CFCs, took the opportunity to improve the efficiency of their designs, reduce their costs and, according to the Environmental Protection Agency ( US-EPA), cooling systems would be up to 50% more energy efficient. For example, Coca-Cola and PepsiCo reported energy efficiency gains of up to 47% in their new CO2 and hydrocarbon refrigeration equipment compared to H-FC models19.

                As for the end of life, there are initiatives, such as the test center of GIELLE in Italy20, which is upgrading and renovating old fire extinguishing systems using H -CFC and H-FC, decondition the fluorinated gas extinguishers and recycles or eliminates the gases safely. Specialized engineering teams have developed a very high temperature incinerator for the safe destruction of fluorinated gases, which will be approved by an official agency.

                For fire protection, companies and organizations that continue to use fluorinated gas systems have programs in place to identify their most critical needs, and fluorinated gases that can be removed from non-critical or obsolete facilities to be reused in more critical applications.

                9  https://eta.lbl.gov/sites/default/files/publications/lbnl-1003671.pdf
                 www.lbl.gov/wp-content/themes/LBL/docs/community/SERC/2010/DEIR/4_4GHG090310.pdf 10 http://www.igsd.org/ 
                11 www.iea.org/exchange/cooling/ 
                12 www.fsb-tcfd.org/publications/final-recommendations-report/ 
                13 www.fondation-2019.fr/ 
                14 www.lesechos.fr/idees-debats/cercle/0301329552325-pour-une-tva-circulaire-2155460.php 
                15 www.k-cep.org/year-one-report/ 
                16 www.un.org/sustainabledevelopment/sustainable-development-goals/ 
                17 www.theconsumergoodsforum.com/  
                18 http://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseaction=search.dspPage&n_proj_id=6233 
                19  www.igsd.org/wp-content/uploads/2017/05/H-FC-Primer-19May2017.pdf
                20 http://gielle.it/adv/fgas-en.html?camp=fgas-disposal&gclid=EAIaIQobChMI9dDcg4WS3QIVzrftCh3o7whEEAMYAiAAEgIRTvD_BwE 

                8. What are the specific initiatives in refrigeration and air conditioning?

                  The projects of the Climate & Clean Air Coalition adopted in 2014 could serve as an example of actions accessible to non-state actors. Their purpose is to demonstrate the technical feasibility and commercial viability of low-GWP, low-energy technologies and encourage their adoption in commercial refrigeration and automotive air conditioning. With the Institute for Governance and Sustainable Development (IGSD) coordinating the project, companies like Mahle and Tata Motors have received funding from the Coalition to Develop a System (SL-MAC) that provides for the testing of refrigerants at low GWP21.

                  9.a New options available for refrigeration systems in the commercial refrigeration sector

                  Because of the high levels of losses in these systems, commercial refrigeration is one of the areas where the demand for refrigerants is highest22. In the EU, it accounts for around 40% of direct greenhouse gas emissions (refrigerant-related losses) and indirect (energy-related), and the largest share (85%) comes from supermarkets. The majority of the current refrigeration systems are centralized in a separate machine room, which favors losses, and they still use H-FCs since low GWP refrigerants other than CO2 do not yet seem to be available for such facilities.

                  However, better design and installation practices would reduce direct refrigerant emissions by 60% and, by increasing the energy efficiency of the systems, reduce the indirect climate impact. The first rule is to ensure that systems are properly dimensioned, well maintained to prevent breakdowns and leaks, and properly insulated to minimize heat loss. It is at this level that multiple non-state actions can be decisive.

                  Autonomous systems, which are widely used in light commercial applications and convenience stores, and for which there are alternative refrigerants such as hydrocarbons (propane, isobutane, ammonia or CO2), would prove useful in larger areas. Moreover, transcritical CO2 seems to have become an operational technology for commercial refrigeration, especially in cold and mild climates23.

                  A particular challenge remains the specific certification of compliance with EU legislation by technicians who handle, recover, supply, install, manufacture, maintain or own cooling equipment containing H-FC refrigerants. In this context, Member States must recognize certificates and training certificates issued in another Member State. Many companies and associations throughout Europe offer guidance documents and training for such a qualification. Certifications generally do not consider energy efficiency while energy consumption is increased. By neglecting this in the optimization, monitoring and maintenance of equipment, cooling performance will be lower and the service life of equipment reduced.

                  9.b. Examples of substitution in the cold chain of supermarkets and container transport.

                  Advances in refrigeration technologies can help, including food retailers, reduce refrigerant loads and emissions. In a 2016 UNEP-GWP report called Alternatives in Commercial and Transport Refrigeration: An Expanded Compilation of Propane, CO2, Ammonia and HFO Case Studies24, some of the cases studies provide a systemic approach to issues with state-of-the-art energy design methodologies and tools such as computer models and airflow dynamics (CFD) simulation and lighting techniques. This approach is often overlooked while all forms of energy use need to be verified/reviewed. For example, the interactions between heat and cooling generators must be analyzed to optimize their energy efficiency.

                  Many other examples presented in various reports25 illustrate the options available for adapting systems to zero or low GWP refrigerants. They focus mainly on the implementation of CO2, hydrocarbons and unsaturated HFO refrigerants, as well as other deployment options using ammonia and other refrigerant configurations. They should inspire the generalization of transitions in the case of systems used in supermarkets, as well as in the case of autonomous units, taking into account all the factors involved: design, energy performance, climate and environmental impact and costs analysis. Among these examples, individual companies that are members of the Consumer Goods Forum (CGF), including Wal-Mart, Nestle, Sobeys, Supervalu and Tesco, have converted their existing equipment to low-GWP refrigerants while reducing leaks and improving their energy efficiency. In 2014, Whirlpool replaced all foam blowing agents used in the manufacture of refrigerators and freezers sold in North America26, with a reduction of Global Warming Potential (GWP) of 99.9%.

                  These examples should not be interpreted as solutions applicable to all other companies in the same sector and the CGF report emphasizes in particular that a key success factor for all types of solutions is the collaboration between the relevant departments within a company and/or between the companies concerned.

                  21 http://ccacoalition.org/en/activity/H-FC-alternative-technology-demonstration-projects  and Tata Motors and MAHLE partner together to develop a prototype Secondary Loop Mobile Air Conditioning System on a vehicle 
                  22 According to the 2014 assessment by the Montreal Protocol Advisory Committee, the Technical Options Committee of the Technology and Economic Assessment Panel (TEAP)
                  23  https://ec.europa.eu/clima/sites/clima/files/f-gas/legislation/docs/c_2017_5230_en.pdf
                  24  http://www.unep.fr/ozonaction/information/mmcfiles/7806-e-Lower-GWP_Alternatives_in_Commercial_and_Transport_Ref.n.pdf
                  25 These examples come from two reports previously mentioned: the 2016 UNEP report and the CGF report.
                  26 By shifting from H-FC-245fa (with a GWP100-yr of 858) to HFO-1233zd (with a GWP100-yr = ~ 1)


                  Appendix: What is the regulatory situation in France regarding H-FC?

                  The French Climate Plan presented in July 2017 provided for the introduction of an incentive tax on H-FC but the modalities were still not presented at the end of 2018. In addition, a Fluorinated Gases Observatory has the mission to control the quantities of different types of fluorinated gases put on the market, used, recycled or destroyed and to control actors in the sectors concerned, in particular in the refrigeration and air-conditioning sector, fire protection, high-voltage and as solvents.

                  At the non-state level, the French regulation imposes obligations on distributors of refrigerants that perform, in a professional capacity, any operation requiring the handling of refrigerants. Producers of refrigerants and equipment pre-loaded with refrigerants must recover them at no additional cost, process them or have them processed in authorized facilities on the national territory or abroad to allow their reuse in accordance with the requirements of their original specifications, or to have them destroyed in case of impossibility of compliance or prohibited reuse.

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