All eyes are on a European proposal to restrict per- and polyfluoroalkyl substances (PFAS) that may result in bans on many widely used refrigerants.
Alex Pachai, who chairs the Eurammon technical committee, the International Institute of Refrigeration working group on safety, and the industrial heat pump manufacturer’s group at the Danish Heat Pump Association, explains the proposal and its potential impacts.
The European Chemical Agency (ECHA) has released a proposal for the regulation of substances that contribute to the formation of per- and polyfluoroalkyl substances – called PFAS. There are approximately 10,000 different PFAS from many different sources, but all contain fluorine molecules of CF2, CF3 or higher structures. The challenge with these substances is that no known natural breakdown paths exist, and the substances are therefore also called “forever chemicals”. Carbon-fluorine bonds are one of the strongest in chemistry. They have also been found to cause health problems for humans and animals.
Of course, regulation of fluorinated and chlorinated gases is not new to the industry. The most widely known instrument, the Montreal Protocol, regulated substances containing chlorine that impacted the ozone layer and was signed in 1987.
Even at that time it was already understood that the next challenge for the industry would be the global warming potential (GWP) of the alternative gases. Some companies focused on non-fluorinated compounds such as carbon dioxide (CO2), ammonia (NH3) and hydrocarbons (HCs), while others started to look for synthetic compounds. As a result, more than 100 blends of different compositions have emerged in the market.
In recent years, reports from the Intergovernmental Panel on Climate Change (IPCC) and the media have pointed to the discovery of different fluorine compounds in nature, for example, from ski wax, firefighting foam, and non-stick pans. This has caused more concerns about PFAS.
Now, five European countries – Germany and the Netherlands leading, strongly supported by Norway, Sweden and Denmark – have put forward a proposal for regulating PFAS under the ECHA umbrella. Coming at the same time as the revision of the F-gas directive (the European legislation for phasing down high-GWP HFC refrigerants), this has led to heated debate.
The Greens in the European Parliament have proposed including PFAS in the updated F-gas regulation. The issue is that the F-gas regulation focuses on GWP, while the ECHA focuses on health and safety of humans and nature. Putting the two regulations together will not be easy.
What does the PFAS regulation mean for the HVAC&R industry?
A number of the more widely used components of blends that will be affected are:
Some widely used refrigerants, such as R32, will not be affected. But the F-gas legislation is looking at limiting the GWP at 750, which challenges R32.
What is rarely mentioned in the heat of discussions is the update of the ODP (ozone-depleting potential) regulations, which is looking at banning substances that contain chlorine. This will also apply to R1233 and R1224.
There are two implementation timeframes: five years and 12 years. The five-year timeframe will apply where alternatives are already in the market. The 12-year timeframe is for where there are no known alternatives.
There is a reasonable chance that the proposal will be accepted. It states: “Evidence has been cited that systems using alternatives are cost-competitive, which matches their emergence in the market in recent years.”
Cost efficiency is one of the drivers for selection of the timeframe. In this author’s humble opinion, it can happen relatively quickly. For example, five years from the day the process ends, which means effective in 2030.
What comes next?
A result is expected by 2025. The initiative is in line with the EU Green Deal, as promoted by the EU commission.
The proposal will now go to scientific committees and consultations, with the following timetable laid out:
- Start of consultation: March 22, 2023
- Online information session: April 5, 2023
- End of six months’ consultation: September 22, 2023
- Committees provide opinions: 2024
- Decision enters into force: 2025
- Restriction becomes effective: 2026–27.
Many experts are already recommending that the industry start adapting to a future without fluorinated substances, because there are alternatives in the market. The sooner we start, the less costly it becomes to make the switch. Waiting until 2030 is playing a dangerous game.
The media briefing on the proposal to restrict FPAS chemicals the EU is available on YouTube.