Energy Regulation: The role of HFCs, HFOs and HCFOs

Regulations affecting all HFCs HFOs and HCFOs

Directive (EU) 2018/844 of the European Parliament and of the Council of 30 May 2018 amending Directive 2010/31/EU on the energy performance of buildings and Directive 2012/27/EU on energy efficiency (Text with EEA relevance). Further information can be found here.

The revised energy performance of buildings directive improves energy efficiency in buildings and encourages building renovation. Decarbonising the existing, highly inefficient European building stock is one of its long-term goals. The long-term renovation strategy requires each Member State shall establish a long-term renovation strategy to support the renovation of the national stock of residential and non-residential buildings, both public and private, into a highly energy efficient and decarbonised building stock by 2050.

Consistent with these energy performance issues, for both new construction and renovation, the demand for thermal insulation has increased substantially as the role of buildings in reducing energy dependency and greenhouse gas emissions has been recognised. Retrofitting insulation in the shells of existing buildings can significantly cut energy consumption. HFOs and HCFOs have excellent insulation and safety properties for use in insulation foams

Energy efficiency directive (EED)

The 2012 Energy Efficiency Directive (2012/27/EU) establishes a set of binding measures to help the EU reach its 20% energy efficiency target by 2020. In 2018, as part of the ‘Clean energy for all Europeans package‘, the new amending Directive on Energy Efficiency (2018/2002) was agreed to update the policy framework to 2030 and beyond. The key element of the amended directive is a headline energy efficiency target for 2030 of at least 32.5%. The target, to be achieved collectively across the EU, is set relative to the 2007 modelling projections for 2030. Further information can be found here.

Renewable energy sources directive (RED)

In December 2018, the revised renewable energy directive 2018/2001/EU entered into force, as part of the Clean energy for all Europeans package, aimed at keeping the EU a global leader in renewables and, more broadly, helping the EU to meet its emissions reduction commitments under the Paris Agreement. The new directive establishes a new binding renewable energy target for the EU for 2030 of at least 32%, with a clause for a possible upwards revision by 2023. More information can be found here.

The amount of aerothermal, geothermal or hydrothermal energy captured by heat pumps is considered to be energy from renewable sources for the purposes of this Directive. There is growth in heat pump installations, with extensive continuing HFC use according to BSRIA80% of heat pumps sold in 2019 contained R-410A refrigerants with R-134a being the second most common”. It is expected that lower GWP HFCs, HFC/HFO blends, HFOs and HCFOs will be used more widely for heat pumps.

Energy labelling and Ecodesign (specific LOTs)

Directive 2009/125/EC establishing a framework for the setting of ecodesign requirements for energy-related products (recast). Detailed information about energy labelling, ecodesign and energy efficient products can be found here. Its objective is to ensure that energy efficient products are placed on the market by setting mandatory minimum standards.  Ecodesign also supports industrial competitiveness and innovation by promoting better environmental performance of products throughout the internal market.  It focusses on individual products, some of which use refrigerants and foam blowing agents. For some products different minimum energy requirements apply depending on the refrigerant GWP being > or < 150. However, for some products as refrigerants are subject to F-gas Regulation 517/2014 no specific requirements on refrigerants are set.


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