Re-use, Recycle, Recover
The recovery, recycle, reclaim and re-use of fluorinated greenhouse gases (HFCs, HFOs and HCFOs) contributes to emission reduction and also to the circular economy by reducing the requirement for virgin refrigerants. Where HFCs, HFOs and HCFOs cannot be re-used (i.e., either recycled or reclaimed) then destruction is mandated to avoid emissions.
The previous F-gas Regulation 517/2014 did not require undertakings to report the quantities of F-gases they reclaimed. Regulation 2024/573 in Article 26 (6) requires each undertaking that reclaimed quantities exceeding 1 metric tonne or 100 tonnes of CO2 equivalent of fluorinated greenhouse gases shall report to the Commission the data specified in Annex IX (quantities of each substance reclaimed and stocks) on each of those substances for that calendar year. This new requirement will provide comprehensive data on the quantities of F-gases being reclaimed for re-use. Under the old F-gas Regulation, there was a data gap for quantities reclaimed. However, recycling and reuse of F-gas refrigerants by service and maintenance engineers will be by far the dominant activity, compared to reclamation, where refrigerant quality is acceptable and the recycling is allowed by regulation.
The most recent Fluorinated greenhouse gases 2024 Data reported by companies on the production, import, export and destruction of fluorinated greenhouse gases in the European Union, 2007-2023 covers the period where previous F-gas Regulations were in force. The F-gas report ETC CM Report 2024/05 is available at https://www.eionet.europa.eu/etcs/etc-cm/products/etc-cm-report-2024-05. The F-gas report for the period 2021 to 2023 (EU-27) in Table 3 states reported reclamation of HFCs as 1026 tonnes (2021), 905 tonnes (2022) and 931 tonnes (2023). Reclamation data is confidential for other F-gases, but HFCs account for about 90% by weight of total reported F-gas reclamation. The F-gas report in Figure 3-15 shows reported destruction of HFCs for 2021-2023 of about 2300 to 2500 tonnes each year, accounting for roughly 95% of the total F-gases destroyed.
Where F-gases cannot be re-used, then destruction is required. According to Regulation 2024/573, HFCs shall be destroyed only by destruction technology that has been approved by the Parties to the Montreal Protocol. The destruction technologies and status of their approval are available here. HFCs are in two groups under the Montreal Protocol, Annex F Group I- all HFCs listed in Annex F, except HFC-23 which is in Annex F Group II. The technologies approved for destruction have some differences between Group I and Group II. Some of the technologies allow the recovery for re-use of hydrogen fluoride (HF).
The European Research Council (ERC) is funding a project to investigate the chemical recycling of HFCs. The project will translate and commercialise a technology allowing the fluorine content of both HFCs and fluoropolymers to be reused to generate commercially relevant fluorochemicals this activity marks an important step toward a new circular economy for fluorine. See https://cordis.europa.eu/project/id/101198849
Measures in F-gas Regulation 2024/573 require emissions control throughout the production and equipment lifecycle, by leak checking, monitoring and leak rates. The Regulation also has requirements for recovery, recycle, reclaim and destruction, and provides exemptions for the use of recycled and reclaimed refrigerants some with some categories being time limited.
F-gas Regulation 2024/573
Article 3 Definitions
(11) ‘recovery’ means the collection and storage of fluorinated greenhouse gases from containers, products and equipment during maintenance or servicing or prior to the disposal of the containers, products or equipment;
(12) ‘recycling’ means the reuse of a recovered fluorinated greenhouse gas following a basic cleaning process, including filtering and drying;
(13) ‘reclamation’ means the reprocessing of a recovered fluorinated greenhouse gas to the equivalent performance of a virgin substance, taking into account its intended use, in authorised reclamation facilities that have the appropriate equipment and procedures in place to enable the reclamation of such gases and that can assess and attest to the level of the required quality;
(14) ‘destruction’ means the process of transforming or decomposing, permanently and as completely as possible, a fluorinated greenhouse gas into one or more stable substances that are not fluorinated greenhouse gases;
Article 9 Extended producer responsibility schemes
Without prejudice to existing extended producer responsibility schemes, Member States shall ensure that by 31 December 2027, the financing obligations for waste electrical and electronic equipment referred to in Articles 12 and 13 of Directive 2012/19/EU include the financing of the recovery, and the recycling, reclamation or destruction, of fluorinated greenhouse gases listed in Annexes I and II to this Regulation from the products and equipment, containing those gases, which are electrical and electronic equipment within the meaning of Directive 2012/19/EU and that have been placed on the market from 11 March 2024.
Member States shall inform the Commission about the actions undertaken.
Article 13 Control of use Virgin, Recycled or Reclaimed Refrigerants
F-gas Regulation 2024/573 prohibits the use of some virgin refrigerants, determined by GWP, but allows the use of recycled or reclaimed refrigerants, with some categories being time limited.Member States shall inform the Commission about the actions undertaken.
3 Extracts. Refrigeration equipment
From 1 January 2025, the use of fluorinated greenhouse gases, with a global warming potential of 2500 or more, for the maintenance or servicing of any refrigeration equipment shall be prohibited. The prohibitions shall not apply to the following categories of fluorinated greenhouse gases until 1 January 2030:
(a) reclaimed fluorinated greenhouse gases listed in Annex I (HFCs) with a global warming potential of 2500 or more used for the maintenance or servicing of existing refrigeration equipment, provided that containers containing those gases have been labelled in accordance with Article 12(7);
(b) recycled fluorinated greenhouse gases listed in Annex I (HFCs) with a global warming potential of 2500 or more used for the maintenance or servicing of existing refrigeration equipment, provided that they have been recovered from such equipment; such recycled gases shall only be used by the undertaking which carried out their recovery as part of maintenance or servicing or by the undertaking for which the recovery was carried out as part of maintenance or servicing.
4 Extracts. Air-conditioning and heat pumps
From 1 January 2026, the use of fluorinated greenhouse gases listed in Annex I, with a global warming potential of 2500 or more, for the maintenance or servicing of air-conditioning equipment and heat pumps shall be prohibited.
The prohibition shall not apply to the following categories of fluorinated greenhouse gases until 1 January 2032:
(a) reclaimed fluorinated greenhouse gases listed in Annex I (HFCs) with a global warming potential of 2500 or more used for the maintenance or servicing of existing air-conditioning equipment and heat pumps, provided that containers containing those gases have been labelled in accordance with Article 12(7);
(b) recycled fluorinated greenhouse gases listed in Annex I with a global warming potential of 2500 or more used for the maintenance or servicing of existing air-conditioning equipment and heat pumps, provided those gases have been recovered from such equipment; such recycled gases shall only be used by the undertaking which carried out their recovery as part of maintenance or servicing or by the undertaking for which the recovery was carried out as part of maintenance or servicing.
5 Extracts. Stationary refrigeration equipment excluding chillers
From 1 January 2032, the use of fluorinated greenhouse gases listed in Annex I (HFCs), with a global warming potential of 750 or more, for the maintenance or servicing of stationary refrigeration equipment, with the exclusion of chillers, shall be prohibited.
The prohibition shall not apply to military equipment or equipment intended for applications designed to cool products to temperatures below – 50 °C or equipment intended for applications designed to cool nuclear power stations.
The prohibition shall not apply to the following categories of fluorinated greenhouse gases:
(a) reclaimed fluorinated greenhouse gases listed in Annex I (HFCs) with a global warming potential of 750 or more used for the maintenance or servicing of existing stationary refrigeration equipment, with the exclusion of chillers, provided that containers containing those gases have been labelled in accordance with Article 12(7);
(b) recycled fluorinated greenhouse gases listed in Annex I (HFCs) with a global warming potential of 750 or more used for the maintenance or servicing of existing stationary refrigeration equipment, with the exclusion of chillers, provided such gases have been recovered from such equipment; such recycled gases shall only be used by the undertaking which carried out their recovery as part of maintenance or servicing or by the undertaking for which the recovery was carried out as part of maintenance or servicing.