- January 1, 2010: prohibition of the use of virgin HCFCs in the maintenance and servicing of all equipment;
- January 1, 2015: prohibition of the use of all HCFCs, including recycled HCFCs.
There is in addition a review clause which might bring forward the 2015 time frame to 2012. These deadlines will probably pose important problems in many EU countries, where a large HCFC-22 bank still exists.
Two main challenges will have to be met within the EU: the first one is the shortage of HCFC-22 for maintenance purposes when, by January 2010, only recycled material will be allowed. It is important that the repetition of what happened in 1994 with the CFC phase-out should be avoided. At that time, having mandated an earlier CFC phase-out, the Commission was forced subsequently to authorize non-EU CFC imports because the user industry was not yet ready to use HCFC substitutes.The second challenge will be the lack of qualified personnel who are already required for the implementation of Regulation 842/2006.
In the case of France for instance, an enquiry has revealed an estimated bank of 18,300 tons of HCFC-22, corresponding to over a million installations needing to be converted. If only one quarter of this number i.e. 250,000 units were adapted or replaced before 2010, nearly 3,000 installations per week would need significant changes.
HCFC-22 users are therefore strongly encouraged by the authorities to start retrofitting or replacing their current equipment, as delayed action could lead to a shortage of qualified staff capable of performing the work required.