EFCTC COMMENT ON THE F-GAS CHALLENGES TO ACHIEVE MARKET INTEGRITY

In our 2018 year-end review we noted three challenges for the HFC sector under the F-Gas Regulation - illegal imports, market bans for high GWP refrigerants and supporting recycling and destruction to increase refrigerant availability and minimise emissions. It is becoming increasingly clear from recent reports that these appear to be interlinked. Measures that help supress illegal imports might also be expected to have an impact on the other challenges.

Recently, a news feature suggests that estimated illegal imports were about 20% of the allowable quota in 2018, mainly the most widely used refrigerants R-134a, R-410A and very high GWP R-404A. While all illegal imports are damaging to the objectives of the F-Gas Regulation by exceeding the HFC cap, the illegal import of R-404A is expected to have an impact on the market and use bans from 2020 for virgin refrigerants with a GWP > 2500 slowing its replacement by lower GWP alternatives, which are readily available. Furthermore, although reclaimed and recycled R-404A can continue to be used for servicing and maintenance, the availability of illegal R-404A may discourage this activity as well. In addition, a news feature points out that the cylinders used for illegal imports have no legitimate return system and are most likely disposed of without residual refrigerant being recovered leading to increased emissions.

These are complex issues, which require efforts from all of us to improve compliance with the F-Gas Regulation. EFCTC member companies through their supply chains have made available lower GWP alternatives that have similar safety and technical properties to the high GWP HFCs.

Data are critical to our understanding of compliance with the HFC phase-down. While illegal imports have been estimated based on HFC- trade data, the F-gas regulation requires verification of quantities placed on the market to ensure accuracy and compliance. However, this verification requirement is limited to larger suppliers.

Companies throughout the supply chain and users of HFCs have invested to deliver the requirements and objectives of the F-Gas Regulation. Illegal imports will delay the transition to lower GWP refrigerants and thereby impact EU’s climate change goals.