Preparatory study for a review of Regulation (EC) 

No 842/2006 on certain fluorinated greenhouse gases 

Final Report 

Prepared for the European Commission in the context of 

Service Contract No 070307/2009/548866/SER/C4 

Authors: 

Dr. Winfried Schwarz, Barbara Gschrey, Dr. André Leisewitz (Öko-Recherche GmbH) 

Anke Herold, Sabine Gores (Öko-Institut e.V.) 

Irene Papst, Jürgen Usinger, Dietram Oppelt, Igor Croiset (HEAT International GmbH) 

Per Henrik Pedersen (Danish Technological Institute) 

Dr. Daniel Colbourne (Re-phridge) 

Prof. Dr. Michael Kauffeld (Karlsruhe University of Applied Sciences) 

Kristina Kaar (Estonian Environmental Research Centre) 

Anders Lindborg (Ammonia Partnership) 

September 2011 
This report has been prepared for the European Commission in the context of Service 

Contract No 070307/2009/548866/SER/C4. The views expressed herein are those of the 

authors alone and can in no way be taken to reflect the opinion of the European 

Commission. The European Commission is not responsible for any use that may be made of 

the information contained therein.
Content 

0. Executive Summary ..................................................................................................... V

1. Introduction .................................................................................................................. 1

2. Methodology................................................................................................................. 5

2.1 Collection of data and information ........................................................................... 5

2.1.1 Basic and background information......................................................................... 5

2.1.2 Data on the status of implementation and application of the F-gas Regulation ...... 5

2.1.3 Role of the Expert Group....................................................................................... 8

2.2 Compilation of sectoral data and modelling ............................................................. 9

2.2.1 Compilation of data and development of models ................................................... 9

2.2.2 The model AnaFgas .............................................................................................10

2.2.3 Two scenarios for global HFC consumption..........................................................14

2.2.4 The terms demand, supply and consumption .......................................................17

2.3 Measurability of emission reductions in 2011 and emission factors in AnaFgas .....21

2.3.1 Lack of empirically verified data on emission factors ............................................21

2.3.2 Assumptions on emission factors in AnaFgas.......................................................29

2.4 Emission factors used in this report........................................................................31

2.5 Identification of policy options.................................................................................34

2.5.1 Policy options at international level.......................................................................34

2.5.2 Policy options in EU-27 ........................................................................................34

3. F-gas markets and policies............................................................................................35

3.1 Global and European F-gas markets......................................................................35

3.1.1 Montreal Protocol as main driver of growing use of HFCs ....................................35

3.1.2 HCFC phase-out drives use of HFC refrigerant blends.........................................35

3.1.3 Strong increase of HFC production in developing countries..................................36

3.1.4 Slow market growth in developed countries: F-gas demand in EU-27 ..................39

3.1.5 HFC markets in North America, Japan, and Asia-Pacific ......................................42

3.2 Policies addressing F-gas emissions......................................................................43

3.2.1 International level............................................................................................43

3.2.2 European level ................................................................................................47

3.2.3 Member State level .........................................................................................49

3.2.4 National level outside of EU-27 .......................................................................56
Content II 

3.2.5 Norms and standards......................................................................................61

3.2.6 Impact of policies addressing F-gas emissions.....................................................64

3.3 Interactions of other policies with EU F-gas policy framework ................................65

3.3.1 ODS policy......................................................................................................65

3.3.2 Waste policy....................................................................................................67

3.3.3 Climate & energy and industrial emissions policies .........................................71

3.3.4 Policies related to safety .................................................................................77

3.3.5 Consideration of interactions within the project work .......................................78

4. Application of the EU F-gas Regulation........................................................................79

4.1 Status of implementation of certain provisions of the F-gas Regulation in EU-27........79

4.1.1 Requirements for implementation of Article 5 .......................................................79

4.1.2 Implementation of Art 5(2): status of notification by Member States .....................82

4.1.3 Implementation of Article 5(2): reasons for delay..................................................87

4.1.4 Status of implementation of Article 13 (penalties) .................................................87

4.2 Application of the provisions of the F-gas Regulation..................................................89

4.2.1 Certification requirements and availability of training centres in Member States...89

4.2.2 Application of certification requirements by sectors ..............................................92

4.2.3 Other issues related to Article 5..........................................................................100

4.2.4 Summary: Status of certification .........................................................................102

4.2.5 Application of containment provisions (Art 3)......................................................104

4.2.6 Application of recovery provisions (Article 4) ......................................................117

4.2.7 Application of reporting provisions (Art 6) ...........................................................127

4.2.8 Application of labelling provisions (Article 7).......................................................134

4.2.9 Application of bans (Articles 8 and 9)..................................................................137

4.3 Costs of implementation and application of the F-gas Regulation .............................140

4.3.1 Costs of the F-gas Regulation ............................................................................140

4.3.2 Most important types of costs .............................................................................140

4.3.3 Costs for certification of personnel and companies.............................................141

4.3.4 Costs of containment provisions (Art 3) ..............................................................148

4.3.5 Costs of recovery (Art 4).....................................................................................151

4.3.6 Costs of Reporting (Article 6)..............................................................................152

4.3.7 Costs according to Article 7 (labelling, instruction manuals) ...............................153

4.3.8 Public set-up costs .............................................................................................154

4.3.9 Summary: Total costs acc. to Articles 3-7 of the F-gas Regulation .....................154
Content III 

5. Impact and cost-effectiveness of the current EU F-gas policy framework...............156

5.1 Concept of the current EU F-gas policy framework ...................................................156

5.2 Current and projected impact of the F-gas Regulation and its cost-effectiveness......157

5.2.1 Model output: Emission scenarios in EU-27........................................................157

5.2.2 Emission Reduction Potential of current EU F-gas legislation.............................162

5.2.3 Impact of the EU F-gas policy framework ...........................................................169

5.3 Cost-effectiveness of the EU F-gas Regulation.........................................................171

5.4 Emissions not addressed by the EU F-gas policy framework ....................................172

6. State and potential of technology in the different sectors ........................................186

6.1 State of technology and HFC use and emission trends.............................................187

6.1.1 Common technology by sectors..........................................................................187

6.1.2 Global BAU trend of HFC use until 2030 by sectors ...........................................189

6.1.3 HFC demand and emissions in EU-27 until 2050 (WM scenario)........................192

6.2 The market potential of abatement technology..........................................................195

6.2.1 Selection of sector abatement options................................................................195

6.2.2 The concept of penetration rates ........................................................................195

6.2.3 Determination of penetration rates......................................................................198

6.2.4 Combination of penetration rates (“penetration mix”)..........................................199

6.2.5 Difference between A2 countries and Europe.....................................................201

6.2.6 Key abatement options by sectors......................................................................202

6.3 Abatement costs and global HFC consumption reduction .........................................206

6.3.1 Developed countries (A2) ...................................................................................206

6.3.2 Developing countries (A5) ..................................................................................208

6.4 Abatement cost, emission and demand reductions in EU-27 ....................................210

6.4.1 Demand reductions in EU-27 by 2030 ................................................................210

6.4.2 Emission reductions in EU-27 by 2030 ...............................................................212

7. Options for further international action to reduce F-gas emissions .....................215

7.1 Projection of global HFC consumption and the need for international action.............215

7.2 Scenarios for the control of consumption and production of HFCs ............................218

7.2.1 Presentation of the scenarios .............................................................................218

7.2.2 Comparison of scenarios for A2 countries ..........................................................220

7.2.3 Comparison of scenarios for A5 countries ..........................................................223

7.2.4 Comparison of HFC consumption reductions in the scenarios............................226
Content IV 

8. Options for further EU action to reduce F-gas emissions......................................228

8.1 Options for the review of the F-gas Regulation .........................................................228

8.1.1 Option A: No policy change ................................................................................229

8.1.2 Option B: Discontinue existing provisions ...........................................................229

8.1.3 Option C: Non-regulatory approaches at EU level ..............................................230

8.1.4 Option D: Regulatory approaches.......................................................................240

8.1.5 Option E: Marked-based approaches .................................................................275

8.2 Screening and ranking of options .........................................................................279

8.3. Key impacts and comparison of policy options.........................................................310

ANNEXES..........................................................................................................................317

ABBREVIATIONS..............................................................................................................318
Executive Summary V

0. Executive Summary 

Background 

Fluorinated greenhouse gases (F-gases) are used in numerous applications and include 

three types of gases: HFCs, PFCs and SF6. F-gas emissions are mainly released from 

refrigeration and air conditioning equipment, foams, aerosols, solvents, fire protection 

equipment, from halocarbon production, from certain industrial processes in semiconductor 

and non-ferrous metal industry and from equipment for transmission of electricity during 

manufacture, use and at disposal. 

Due to their relatively high global warming potentials, F-gases are addressed by international 

conventions such as the United Nations Framework Convention on Climate Change 

(UNFCCC) and its Kyoto Protocol, as well as by policies at European and at national level in 

EU Member States and other countries, for example Switzerland, Japan, Australia and the 

USA. 

The EU committed to reduce overall greenhouse gas emissions by 8% compared to the base 

year 1990 during the first commitment period 2008-2012. In order to comply with these 

commitments, the European Commission identified and developed an EU strategy through 

the European Climate Change Programme (ECCP) which, inter alia, led to the adoption of 

Directive 2006/40/EC, the so-called MAC Directive, and Regulation (EC) No 842/2006, the 

so-called F-gas Regulation. 

The F-gas Regulation applies since 4 July 2007 with the exception of Article 9 and annex II, 

which apply since 4 July 2006. The Regulation has been complemented by 10 Commission 

Regulations adopted between December 2007 and April 2008, which establish certain 

technical elements of the provisions1

. Whilst provisions have been directly applicable in the 

Member States, a few elements rely upon implementation through national legislation. 

The MAC Directive, transposed at national level, applies since 5 January 2008. Its measures 

are expected to reduce F-gas emissions from mobile air conditioning systems in passenger 

cars from 2011 onwards. 

Objective and scope of this project 

The overall objective of this project is to assist the Commission in reviewing Regulation (EC) 

No 842/2006 by providing technical data, analyses and general support. This service 

contract carried out by Öko-Recherche and partners since December 2009 includes the 

following tasks2

: 

- A review of relevant F-gas markets and policies internationally as well as in the EU-27, 

including investigation of possible interactions, complementarities or overlaps amongst 

the EU F-gas policy framework (F-gas Regulation and MAC Directive) and other EU or 

international policies. 

 

1

 Commission Regulations (EC) No 1493/2007, 1494/2007, 1497/2007, 1516/2007, 303/2008, 

304/2008, 305/2008, 306/2008, 307/2008, 308/2008. 

2

 European Commission: Specifications to tender ENV.C.4/SER/2009/0033 Service contract to provide 

technical support for conducting a review of Regulation (EC) No 842/2006 on certain fluorinated 

greenhouse gases. 
Executive Summary VI

- An assessment of the effectiveness of current EU F-gas policy, through the development 

of appropriate models and datasets for emission scenarios in EU-27 and an ex-post 

assessment of the key elements in the current EU F-gas policy. 

- An assessment of the feasibility of emerging options for an international emission 

reduction arrangement for HFCs and, if appropriate, other F-gases by assessing the 

feasibility and cost-effectiveness of the replacement of F-gases, developing and 

comparing scenarios for the control of supply and/or production of HFCs while 

considering any other elements that could be appropriate to complement a possible 

international reduction arrangement for HFCs. 

- The development of options and recommendations for the review of the F-gas 

Regulation and an analysis of their impacts. 

The project was guided by a Steering Group from the European Commission. In addition, an 

Expert Group consisting of experts on fluorinated gases from authorities in EU-27, industry 

and non-governmental organisations has commented and provided further input to the work. 

This process has enabled the authors of this report to substantially improve the model 

assumptions and background data. 

F-gas markets and policies 

The main influencing factors for F-gas markets include the CFC and HCFC phase out under 

the Montreal Protocol, which have led to the development of HFCs as substitutes for ODS. 

For many applications pure HFC species (e.g. HFC-134a) could not reach the refrigeration 

performance of HCFC-22, therefore blends containing several HFC types were developed 

and placed on international markets as replacements for HCFCs. HFC production in 

developed countries is only slightly growing today, while a strong increase in developing 

countries is projected due to growing demand for HFCs. 

F-gas policies were identified on international, European and Member State level as well as 

at national level in countries outside of EU-27. The underlying approaches include regulatory 

action, market-based mechanisms and voluntary initiatives. 

Furthermore, a number of international, European and national standards apply to all sectors 

relying on F-gases. Although they are, in principle, voluntary to use and do not impose any 

regulation, many governments, as well as industry groups and trade associations require 

products or services to adhere to a standard before they can be placed on the market. 

Interactions between the EU F-gas policy and other policies have been analysed. In some 

cases, F-gas policies and pieces of climate and energy legislation as well as waste 

legislation complement each other (e.g. WEEE Directive, EPB Directive). The Renewable 

Energy Directive promotes the installation of heat pumps, which has lead to strong growth of 

this subsector that is expected to continue. In some cases interlinkages between the F-gas 

Regulation and other policies need to be respected when deciding on particular review 

options influencing e.g. GWP thresholds set out by other legislation and definitions. 

Application of the current EU F-gas policy framework 

Whilst provisions of Regulation (EC) No 842/2006 are directly applicable in all Member 

States a few elements relied upon implementation by Member States. These include 

provisions on certification/ attestation systems according to Article 5(2) and on penalties 

according to Article 13. For both aspects, national legislation had to be established and the 
Executive Summary VII

Commission had to be informed about. This “implementation” refers to the legal 

establishment of provisions at Member State level. The relevant notifications of the Member 

States to the EU Commission serve as indicators. Furthermore, the “application” of the 

current F-gas Regulation has been analyzed which refers to the realization and possible 

enforcement of the provisions of the F-gas Regulation in the Member States. 

As of 4th July 2011, notification for Member States certification/attestation bodies was still 

lacking from some Member States in all sectors. The status of notification in the largest 

sector, the stationary refrigeration, air conditioning and heat pump sector according to 

Regulation (EC) No 303/2008 is illustrated in figure ES-1. Notification for rules on penalties 

were lacking from 4 Member States. 

Figure ES-1: Status of notification of 

certification bodies in the stationary 

refrigeration, air conditioning and heat pump 

sector according to Regulation (EC) No 

303/2008 in July 2011. 

Green: 20 Member States in compliance with 

notification obligations. 

Red: 7 Member States not yet in full 

compliance. 

A review of the progress in the application of the F-gas Regulation in the Member States 

considers separately its key provisions: Training and certification (Article 5), containment 

provisions (Article 3), requirements for proper recovery of F-gases (Article 4), reporting 

obligations (Article 6), labelling requirements (Article 7) and bans (Article 8 and 9). 

With regard to training and certification (Article 5), it should be noted that further to the 

establishment or adaptation of the legal framework the actual availability of training centres is 

a prerequisite for the application of the requirements in the Member States. The 

establishment of training infrastructure for application of the certification requirements of the 

F-gas Regulation in the main sectors (stationary refrigeration, air conditioning and heat 

pumps; mobile air conditioning) has improved in almost all Member States during the 

analyzed time period from early 2010 to July 2011. 

The certification status in the different sectors varies considerably between Member States. 

For EU-27, average shares for final personnel and company certification/attestation were 

determined on the basis of empirical data (table ES-1). About 600,000 persons are subject to 

certification and attestation requirements according to Regulations (EC) No 303-307/2008, 
Executive Summary VIII

thereof ca. 60% in the mobile air conditioning sector, 38% in the stationary refrigeration, air 

conditioning and heat pump sector and about 2% in the other sectors. 

Table ES-1: Status of final personnel and company certification per sectors, EU-27 (July 2011) 

Sector Personnel holding 

final certifications 

Companies holding 

final certifications 

Stationary refrigeration, AC, heat pumps 48% 43% 

Fire protection 34% 9% 

High voltage switchgear 72% - 

F-gas based solvents 54% - 

Recovery of F-gases from AC systems 

contained in passenger cars 43% - 

While in some sectors and Member States the share of certified personnel and/or companies 

out of the personnel and/ or companies subject to certification provisions is high, certification 

of personnel and companies are delayed in other sectors and Member States. 

This is partly due to delays in the establishment of national legislation implementing the 

requirements of the F-gas Regulation. In addition, coordination between institutions, industry 

associations and other stakeholders as well as discussions on recognition of existing 

qualifications and the integration of the minimum requirements of the F-gas Regulation in the 

training programs needed time and effort. Furthermore, training facilities and providers had to 

be put in place in some Member States, in particular for the small, very specialized sectors. 

With regard to containment (Article 3) and recovery (Article 4) provisions, application also 

differs widely within EU-27. For the effectiveness of containment and recovery measures set 

out by the F-gas Regulation only little evidence has been found so far. Reliable data on a 

broad basis to assess the quantitative effects of these measures is not yet available. 

Systematic enforcement and control activities by authorities with regard to recovery and 

containment provisions seem to be lacking widely. 

Concerning reporting obligations (Article 6), it can be stated that reporting is wellestablished and benefits from experiences made under the earlier ODS reporting, which 

involved the majority of companies also covered by F-gas reporting. Considering that all 

large producers/importers/exporters fulfil their reporting obligation, the reported sales and 

production quantities of F-gases are well within acceptable statistical error range. Control 

and enforcement mechanisms with regard to reporting seem to be not fully active at this point 

in time. 

Labelling provisions (Article 7) affect in the sector of stationary air conditioning and 

refrigeration incl. heat pumps around 50.000 companies (OEM and contractors assembling in 

site components), about 100 F-gas suppliers including suppliers of cylinders for fire 

protection sector and about 25 manufacturers of high voltage switchgear equipment. Industry 

efforts focus on harmonization of labels, in particular in sectors where products and 

equipment are marketed across Europe, and integration of the additional labelling 

requirements into other labels. Voluntary industry action in terms of labelling of household 

appliances should be noted. Compliance with labelling provisions is high among large 

manufacturers active in several Member States. However, not all importers of products and 

equipment subject to labelling requirements are compliant, which might partly be due to a 

lack of awareness and/or information. 

Bans (Articles 8 and 9) have been the most effective type of measure so far and resulted in 

significant and measurable reductions of the use of F-gases and hence F-gas emissions. SF6
Executive Summary IX

has been substituted in large magnesium die casting facilities (>850 kg/year) and is no 

longer used for filling of vehicle tyres. Full compliance with Articles 8 and 9 can be stated for 

the novelty aerosols and PU canned foam sub sectors as HFCs are today only used as 

components of preparations with GWP <150. However, further investigation of the 

application and potentially enforcement of the bans in soundproof windows seems 

necessary. Articles 8 and 9 have been applied to a large extent with minor administrative 

costs since conversion of production in these sectors largely took place so far, without 

significant needs for enforcement and control by authorities. 

Costs associated with the F-gas Regulation result mostly from its application and 

enforcement in the Member States. One-off costs, which are related to implementation and 

application of the F-gas regulation, are estimated in the range of €617 million. Almost 90% 

thereof result from costs for certification of the personnel and companies. 66% of the 

certification costs relate to the SRAC sector. Recurring annual costs of provisions set out by 

the F-gas Regulation are estimated at €702 million for EU-27 in 2010, at €1,061 million in 

2015 and at €1,551 million in 2030. Containment measures account for high shares of these 

costs (leakage checks, records) and occur mostly in the stationary refrigeration, air 

conditioning and heat pump sector. The share of recovery costs increases significantly over 

time. 

Impact and cost-effectiveness of the current EU F-gas policy framework 

The impact of the F-gas Regulation is illustrated by a comparison of two scenarios calculated 

by the model AnaFgas (Analysis of Fluorinated greenhouse gases in EU-273

): A counterfactual scenario “Without Measures” (WOM) and a scenario “With Measures” (WM), which 

includes the MAC Directive and the F-gas Regulation. 

Empirically verified data on emission factors of different emission sources are lacking largely. 

In particular, quantitative data on large scale on the effects of the containment provisions of 

Article 3 on emissions of refrigerants and fire protection extinguishing agents (i.e. sectors 

affected by Article 3) are not yet available. Similarly, for the application of recovery provisions 

(Article 4) little quantitative information is available on F-gas quantities recovered and 

recycled on site as well as on waste streams of recovered F-gases for reclamation and 

destruction. For certain sub sectors such as supermarket and industrial refrigeration, data 

sets on the use of F-gases during several years have been made available by few 

companies. However, these limited data do not yet allow extrapolation of emission factors to 

large scale. 

It was generally found that none of the reporting schemes currently established for 

fluorinated greenhouse gases allows calculation of emission factors in the different sectors 

reflecting the impact of particular measures for emission reductions. 

By taking into account the current state of application of the relevant provisions and 

assuming that by 2015 all provisions should be fully implemented and applied, it can be 

expected that emission factors will be reduced significantly during the 2010-2015 period as a 

result of the containment measures (Article 3) and recovery measures (Article 4) 

complemented by the training and certification measures (Article 5). The quantified changes 

 

3

 The model AnaFgas is a bottom-up stock model to derive consumption and emission scenarios for Fgases in relevant sectors and sub-sectors for the EU-27 Member States. Data series for consumption 

and emissions of HFCs, PFCs, SF6 and HCFC-22 can be modelled for the period 1995 to 2050. 
Executive Summary X

of emission factors are based upon expert estimates and are considered “best case” 

assumptions. 

On this basis, emission reduction potentials of the key types of measures in the current FGas policy framework have been calculated (table ES-2). At this point in time only the bans 

for use and placing on the market are already contributing to measurable emission 

reductions. In the medium-term a significantly larger emission reduction potential is expected 

to emerge from containment and recovery measures (Articles 3 and 4), in the sectors 

covered by these types of measures. Overall, most of the long-term reduction potential is a 

result of the provisions of the MAC Directive. 

EU-27 F-gas Emissions 1995-2050 by WOM and WM scenario, all sources

0

50,000

100,000

150,000

200,000

250,000

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050

[kt CO2eq]

Without measures With measures

Figure ES-2: F-gas emissions in 1995-2050 in a scenario without measures (WOM) and a 

scenario with measures (WM) of EU F-gas legislation. The shape of the emission curves 

indicates the emission reduction potential for F-gas emissions. From 2008 onwards the two 

curves distinctly split up. In the WM scenario, emissions will remain at a stable level from 2010 

until 2050, while in the WOM scenario emissions would continue to increase up to almost the 

double. It should be noted that even in the WM scenario absolute emissions in 2050 will be 

higher than in the WOM scenario in 2008 (by 6,800 kt CO2 eq). 

The current EU F-gas policy framework including the F-gas Regulation and the MAC 

Directive opens up the opportunity to significantly slow down the increase of future emissions 

(figure ES-2). The emission reduction relative to the WOM scenario totals 2,900 kt CO2 eq at 

present (-2.6%), increasing to 30,800 kt CO2 eq in 2015 (-22%) and 93,300 kt CO2 eq in 

2050 (-46%). 

Table ES-2: Emission reduction potentials (kt CO2 eq) of measures set out by EU legislation on 

F-gases (including F-gas Regulation and the MAC Directive) in 2008-2050 (WOM-WM) 

 2008 2009 2010 2015 2020 2030 2050 

MAC 

Directive 0 0 0 3,419 13,150 40,965 49,916 

Art 3 and 

Art 4 0 0 0 24,357 29,478 35,609 38,815 F-gas 

Regulation Art 8 and 

Art 9 909 2,687 2,861 3,012 3,223 3,750 4,616 

Total 909 2,687 2,861 30,787 45,850 80,325 93,347 
Executive Summary XI

With regard to cost-effectiveness of the F-gas Regulation, abatement costs of 40.8 €/t CO2

eq in 2015 and 41.0 €/t CO2 eq in 2030 have been calculated on the basis of the WM 

scenario. 

Furthermore, significant shares of projected F-gas emissions remain unabated although their 

sources might be subject to containment and recovery provisions already. The following 

sectors will contribute large proportions of future F-gas emissions: Room air conditioning, 

commercial refrigeration, industrial refrigeration. 

Currently certain F-gas emissions are not effectively addressed by the EU F-gas policy 

framework. These include HFC emissions from mobile air conditioning systems contained in 

ships and rail vehicles, from transport refrigeration and refrigerated ships, from foams, from 

halocarbon production, HFC-23 by-product emissions, PFC emissions from industry, SF6

emissions from certain applications. F-gas emissions from Organic Rankine Cycles and 

emissions from other fluorinated gases are currently not covered (NF3, SO2F2, unsaturated 

HFCs, other HFCs and PFCs). 

In the light of international and EU unilateral commitments to reduce greenhouse gas 

emissions, further reductions of F-gas emission seem to be appropriate. These will need to 

be based on additional policy measures. 

State and potential of technology in the different sectors 

The projected F-gas demand in 2050 and emissions of the WOM and WM scenario are 

based on sub sector specific assumptions of growth rates. These assumptions do not include 

in most cases technological changes or growing shares of alternative technologies but are 

based on continued use of conventional technology (“frozen technology”). 

In order to identify the maximum reduction potential of F-gas emissions, the potential for the 

replacement of F-gases by low-GWP solutions in all sectors currently relying on F-gases is 

assessed. For each sector, technically feasible and cost-effective alternative technologies to 

sector-typical conventional F-gas technology were identified and are hereafter referred to as 

“alternative options”. The selection of replacement technology was guided by three criteria 

including the reduction potential of CO2-weighted use of F-gas and emissions, cost 

effectiveness (expressed in abatement cost of €/t CO2 eq) and energy consumption. For 

each alternative option, the penetration rate, which is defined as maximum potential of each 

technical choice to replace new products or equipment relying upon F-gas, was estimated. 

Penetration rates are given for each alternative option based on technical feasibility to 

replace existing F-gas technology by a specific alternative technology, at least cost. 

On the basis of a sector penetration mix, which is the set of alternative options in a sector 

with the highest aggregated technical reduction potential, sector specific (average) 

abatement costs and related reduction potentials for demand and emissions of F-gases 

through the use of alternative technologies in 2030 are calculated. 

At the international level, this results in the findings that HFC consumption in 2030 can be 

reduced by ca. 760 Mt CO2 eq in developed countries (figure ES-3) and by almost 2,000 Mt 

CO2 eq in developing countries (figure ES-4) at costs < 20 €/t CO2 eq. In both, developed and 

developing countries, abatement costs > 20 €/t CO2 eq occur for abatement options in buses, 

multi split systems, ducted air conditioners, and heat pumps. 
Executive Summary XII

At EU level, technically feasible and cost effective abatement options are analysed in terms 

of HFC demand reductions (=potential emissions) and actual HFC emission reductions. In 

relation to the WM scenario, HFC demand of 136 Mt CO2 eq can be reduced at costs < 20 €/t 

CO2 eq in EU-27 in 2030 (figure ES-5) and HFC emissions of 66 Mt CO2 eq can be abated at 

costs < 25 €/t CO2 eq in EU-27 in 2030 (figure ES-6). 

DϮϮϬϯϬ

ͲςϬ

ͲκϬ

ͲϮϬ

Ϭ

ϮϬ

κϬ

ςϬ

ΘϬ

Ϭ ϮϬϬ κϬϬ ςϬϬ ΘϬϬ ϭ͘ϬϬϬ ϭ͘ϮϬϬ

ZĞĚƵĐƚŝŽŶWŽƚĞŶƚŝĂůŝŶϮϬϯϬ΀DƚKϮĞƋ΁

ΦͬƚKϮĞƋ

Figure ES-3: Marginal Abatement Cost Curve for consumption reductions in developed 

countries in 2030. The red line on the right indicates total HFC consumption in developed 

countries in 2030. 

DρϮϬϯϬ

ͲςϬ

ͲκϬ

ͲϮϬ

Ϭ

ϮϬ

κϬ

ςϬ

Ϭ ρϬϬ ϭ͘ϬϬϬ ϭ͘ρϬϬ Ϯ͘ϬϬϬ Ϯ͘ρϬϬ ϯ͘ϬϬϬ

WŽƚĞŶƚŝĂůZĞĚƵĐƚŝŽŶŝŶϮϬϯϬ΀ƚKϮĞƋ΁

ΦͬƚKϮĞƋ

Figure ES-4: Marginal Abatement Cost Curve for consumption reductions in developing 

countries in 2030. The red line on the right indicates total HFC consumption in developing 

countries in 2030. 
Executive Summary XIII

EU-27 MACC demand reduction vs. WM scenario 2030

-50

0

50

100

150

0 40,000 80,000 120,000 160,000

ktCO2eq

€/ktCO2eq

Figure ES-5: Marginal Abatement Cost Curve for F-gas demand reduction in EU-27 in 2030. 

Demand includes quantities contained in pre-filled imported equipment imported in the EU. 

EU-27 MACC emission reduction vs. WM scenario 2030

-50

0

50

100

150

0 20,000 40,000 60,000 80,000

ktCO2eq

€ / tCO2eq

Figure ES-6: Marginal Abatement Cost Curve for F-gas emission reductions in EU-27 in 2030. 
Executive Summary XIV

Options for further international action to reduce F-gas emissions 

Scenarios project HFC consumption during the period 2010-2030 under business-as-usual 

(BAU) and technically feasible reductions of global HFC consumption in the same period in 

both developed and developing countries. 

Growing use of HFCs and hence emissions are mainly a result of the phase out of ODS 

under the Montreal Protocol: HFC demand in developing countries is projected to increase 

drastically in the next decades, while HCFC demand will decrease (BAU scenario). HFC 

demand in developed countries is only slightly growing and likely to reach stable levels 

around 2030. 

As F-gas markets are global markets, HFC production is often taking place in one country 

while HFC consumption and related emissions during and at the end of product life take 

place in other countries. Local or regional policy action can hence only address the 

contribution of HFCs to global warming to minor extent, while international action is thought 

to be able to achieve significant consumption and emission reductions at large scale. 

Current policy discussions at international level treat the question on how to link the work on 

F-gases, in particular HFCs, done under the UNFCCC climate regime and further phase out 

of ODS under the Montreal Protocol more closely. The Montreal Protocol holds a special role 

as it addresses most industries and sectors which rely on F-gases while not addressing 

these gases. It could be possible to abate HFC emissions in a similar way as ozonedepleting substances by applying an approach similar to that of the Montreal Protocol. 

Two existing proposals for HFC phase down under the Montreal Protocol resubmitted by 

Northern American (NA) countries and the Federated States of Micronesia (FSM) in 2011 are 

turned into the “NA scenario” and the “FSM scenario”. 

Based on the findings on abatement technologies for each sector, potential HFC supply 

reduction scenarios for developed and developing countries are calculated: A reduction 

scenario (RED) is based on all technically feasible abatement options identified for each 

sector at the maximum penetration rates in a particular year. Another reduction scenario 

(RED10) is based on technically feasible abatement options at abatement costs <10 €/t CO2

eq identified for each sector at the maximum penetration rates in a particular year. 
Executive Summary XV

Figure ES-7: Comparison of scenarios for HFC phase down in developed countries. 

The reduction scenarios, the NA scenario and the FSM scenario are compared (figure ES-7 

for developed countries) with regard to the control schedules for developed and developing 

countries as well as their global HFC consumption reductions. 

Options for further EU action to reduce F-gas emissions 

The identification of policy options for further EU action is based on the project work and 

includes the forward looking options listed in Article 10 of the Regulation. The WM scenario 

calculated by the model AnaFgas serves as reference and allows comparison of different 

policy options. 

Policy options for further action describe different ways forward and are, in most cases, 

mutually exclusive, although certain of the options and many of the sub-options might 

complement each other. The main options/ sub-options include: 

Option A Business-as-usual (do nothing). 

Option B Suspend provisions of the F-Gas Regulation. This option was discarded from 

further analysis because such approach would clearly not be in line with the EU’s overall 

climate objectives. 

Option C Non-regulatory approaches. 

C-1: Environmental agreements and self-regulation. 

C-2: Improved coordination. 

C-3: Enhanced technical standards 

Option D Further regulatory action (includes several sub-options addressing particular 

sectors, types of measures and/or types of F-gas emissions). 

D-1: Include F-gases currently not covered in annex I of the F-gas Regulation. 
Executive Summary XVI

D-2: Enhance application and monitoring of the Regulation. 

D-3: Improve containment and recovery in certain sectors. 

D-4: Ban the use or the placing on the market of open F-gas applications. 

D-5: Ban the placing on the market of certain closed applications containing F-gases, where 

energy efficient and safe alternatives are available. This option considers potential bans for 

different closed applications of F-gases starting in the period 2015-2030. 

D-6: Set quantitative limits for the placing on the market of F-gases in the EU-27. This option 

is based on stepwise limits to HFC supply, thereby drives the introduction of alternative 

technologies and hence reduces F-gas emissions. 

D-7: Development and dissemination of BAT and BREF notes and documents. 

D-8: Obligation to destroy HFC-23 by-product emissions from halocarbon production. 

Option E includes market-based approaches. 

E-1: Include additional activities under the EU-ETS. 

E-2: Tax schemes. 

E-3: Deposit and refund schemes. 

In a screening, the policy options were assessed against several criteria such as 

effectiveness (threshold of 1 million t CO2 eq), efficiency (threshold of 50 €/t CO2 eq), 

technical constraints and other qualitative criteria. The screening resulted in a short list of key 

policy options, which are subject to the subsequent impact analysis (table ES-3). 

Table ES-3: Overview of key policy options and their additional emission reduction potential in 

2030 (kt CO2 eq) 

Proposed policy option Additional emission reduction 

potential in 2030 (kt CO2 eq) 

Voluntary agreements 21,702 

Improve containment and recovery under F-gas Regulation: 

Refrigerated trucks and trailers 1,430 

Ban the placing on the market of certain open applications 

containing HFCs 5,190 

Ban the use of SF6 in open applications 250 

Ban the placing on the market of certain closed applications 

containing F-gases 47,089 

Limits for the placing on the market of HFCs in EU 71,740 

Obligation for HFC-23 by-product destruction 370 

All of these options could be supplemented by approaches under option D-2 aiming at 

improvement of the existing legislation and its application through additional information and 

guidance. Emission reduction potentials and abatement costs for such modifications are not 

quantifiable. 

In order to achieve maximum abatement of F-gas emissions, a combination of the option 

“Limits for the placing on the market of HFCs in EU”, the options “Ban the use of SF6 in open 
Executive Summary XVII

applications” and “Obligation for HFC-23 destruction” was chosen as it provides the 

maximum emission reduction potential of ca. 72,500 kt CO2 eq in 2030. 

This combination is the basis of the third scenario “With additional measures” in the model 

AnaFgas. It is shown in figure ES-8, in comparison with the WOM and WM scenario. 

EU-27 All sources

0

50,000

100,000

150,000

200,000

250,000

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050

[kt CO2eq]

Without measures With measures With additional measures

Figure ES-8: The three emission scenarios for EU-27 in the model AnaFgas. 

Likely effects of the key policy options were considered in terms of their environmental, 

economic and social impacts on the basis of quantitative or qualitative analyses. 

With regard to emission reductions, the option “quantitative limits for the placing on the 

market of fluorinated gases” shows the highest potential (direct: 71.7 Mt CO2 eq; indirect: 1.6 

Mt CO2 eq), followed by the option “ban of the POM of certain closed applications containing 

F-gases” (direct: 47.1 Mt CO2 eq; indirect: 0.7 Mt CO2 eq) and the option “voluntary 

agreements” (direct: 21.7 Mt CO2 eq; indirect: 0.5 Mt CO2 eq). The abatement costs for these 

three policy options with high emission reduction effects are comparable and range at 14 - 17 

€/ t CO2 eq. 

The direct net costs for affected sectors are the highest in the option “quantitative limits for 

the placing on the market of fluorinated gases” (1,083 M€/year), followed by the option “ban 

of the POM of certain closed applications containing F-gases” (675 M€/year). The investment 

costs are also the highest for the option “quantitative limits for the placing on the market of 

fluorinated gases” (5,613 M€/ year in 2030) and comparably high for the option “ban of the 

POM of certain closed applications containing F-gases” (2,860.2 M€/ year). Due to the fact 

that these options result in the largest new investments in the affected subsectors, they are 

expected to also have the highest positive effects on employment via the creation of new 

jobs. 
Chapter 1 Introduction 1

1. Introduction 

Fluorinated greenhouse gases (F-gases) are used in numerous applications and include 

three types of gases: HFCs, PFCs and SF6. Their emissions are released from various 

sources (table 1-1). 

HFC emissions account for large shares of F-gas emissions and are projected to increase in 

the next decades. HFCs were widely introduced as substitutes for ozone depleting 

substances (ODS) in recent years since the Montreal Protocol controls production and 

consumption of chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) in order 

to reach global phase-out. Therefore, HFCs are used in the same sectors of application as 

CFCs and HCFCs, such as refrigeration and air conditioning equipment, foams and fire 

protection systems. 

PFCs, in contrast, are mostly used and emitted during industrial processes such as 

semiconductor manufacture and aluminium production (inadvertent emissions). To limited 

extent, they are also used as solvents, fire fighting agents and refrigerants. Their contribution 

to total F-gas emissions has decreased in past years. 

Emissions of SF6 occur from certain industrial applications, e.g. magnesium casting, TFTLCD and photovoltaic manufacture, but are also released from large banks contained in 

sound-proof windows and switchgear equipment for the transmission and distribution of 

electricity. 

Table 1-1: Main sectors of intended application (and inadvertent production) of F-gases 

Refrigeration: 

Domestic refrigeration, commercial refrigeration, industrial refrigeration, transport 

refrigeration 

Air conditioning: 

Mobile air conditioning, stationary air conditioning, heat pumps 

Foam blowing: 

XPS foam, PU rigid foams, PU canned foam (OCF) 

Aerosols: Metered-dose Inhalers (MDI), technical aerosols, novelty aerosols 

Solvents 

Fire protection 

Manufacture of HCFC-22: HFC-23 as by-product (inadvertent production) 

HFCs 

others 

Semiconductor manufacturing 

Aluminium production (inadvertent production) 

PFCs 

Others: Fire protection, solvents, refrigerants 

Transmission and distribution of electricity 

Non-ferrous metal industry: Magnesium casting 

Secondary Aluminium cleaning 

Soundproof windows 

Particle accelerators 

Production of optical fibres 

Vehicle tyres 

Footwear 

TFT-LCD and photovoltaic 

SF6

others 
Chapter 1 Introduction 2

F-gases are greenhouse gases and accelerate global warming. They often have high global 

warming potentials. They are addressed by international conventions such as the United 

Nations Framework Convention on Climate Change (UNFCCC) and its Kyoto Protocol, as 

well as by European policies and at national level in EU Member States and other countries 

internationally (chapter 3.2). The Kyoto Protocol promotes emission reductions of 

greenhouse gases such as carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), 

hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulphur hexafluoride (SF6). 

The EU committed to reduce overall greenhouse gas emissions by 8% compared to the base 

year 1990 during the first commitment period 2008-2012. In order to comply with these 

commitments, the European Commission identified and developed an EU strategy through 

the European Climate Change Programme (ECCP). In 2003, a legislative framework to 

reduce projected F-gas emissions by 23 million tonnes of CO2 eq by 2010 (EU-15) was 

proposed. Based on this proposal, a package of two elements was adopted in 2006: 

Directive 2006/40/EC relating to emissions from air conditioning systems in motor vehicles, 

the so-called MAC Directive, and Regulation (EC) No 842/2006 on certain fluorinated 

greenhouse gases, the so-called F-gas Regulation. 

The F-gas Regulation applies since 4 July 2007 with the exception of Article 9 and annex II, 

which apply since 4 July 2006. The regulation has been implemented by 10 Commission 

Regulations adopted between December 2007 and April 2008, which establish certain 

technical elements of the provisions4

. Provisions have been directly applicable in the Member 

States; however few elements needed implementation at EU or Member State level (chapter 

4). Measures of the MAC Directive are expected to reduce F-gas emissions from 2011 

onwards. 

At international level, discussions on how to effectively reduce F-gas emissions also take 

place under the Montreal Protocol (chapter 7). The approach of the Montreal Protocol 

focuses on control and stepwise decrease of consumption and production. It presently 

applies to 96 chemicals including chlorofluorocarbons (CFCs), halons, 

hydrobromofluorocarbons (HBFCs), hydrochlorofluorocarbons (HCFCs), and others. Most of 

the fluorinated ozone depleting substances (CFCs, HCFCs) are being phased out which has 

resulted in a significant decrease of ODS production and supply all over the world since the 

1980s. Developed countries (“A2 countries” in the terminology of the Montreal Protocol) have 

already completed the phase out of CFCs and will reach full phase out of HCFCs by 2020. 

Developing countries (“A5 countries” in the terminology of the Montreal Protocol), in contrast, 

have phased out CFCs by 2010 and will phase out HCFCs by 2030. 

However, the phase-out of these substances has resulted in increased use of HFCs globally 

as they were developed as substitutes for ODS. Due to the potent global warming potentials 

of HFCs and the high growth rates of relevant sectors, this trend has caused concern 

internationally. Figure 1-1 illustrates the link between ozone depleting substances covered by 

the Montreal Protocol and HFCs and PFCs covered by the climate regime. 

 

4

 Commission Regulations (EC) No 1493/2007, 1494/2007, 1497/2007, 1516/2007, 303/2008, 

304/2008, 305/2008, 306/2008, 307/2008, 308/2008. 
Chapter 1 Introduction 3

Figure 1-1: CFCs, HCFCs and halons contribute to climate change and ozone depletion while 

HFCs and PFCs contribute to climate change only and have been used as alternatives to ODS. 

Source: UNEP TEAP/IPCC SROC Report 2005. 

Current international discussions are based on proposals by the EU, North American 

countries and the Federated States of Micronesia for action to address HFCs under the 

Montreal Protocol. Since 2009, two detailed proposals submitted under the Montreal Protocol 

by North American (NA) countries and by the Federated States of Micronesia (FSM) include 

schedules to limit and reduce the production and consumption of HFCs in the next decades. 

In the context of this discussion, the current work provides relevant input such as a businessas-usual (BAU) scenario for future demand of HFCs by sectors and types of end-uses in A2 

and A5 countries, as well as a detailed assessment of technical options for abatement to 

reduce HFC demand consumption including an analysis of marginal abatement costs for the 

time horizons 2015, 2020 and 2030. Scenarios further to those proposed already (FSM/NA) 

are based on the maximum technical feasibility of abatement of HFC demand consumption 

in different end-uses (RED scenario) and also take into account costs of abatement of HFC 

demand (RED10 scenario; abatement costs <10 €/t CO2 eq) (chapter 7). 

Article 10 of the Regulation requires the Commission to publish a report based on the 

experience of the application of the Regulation by 4 July 2011 also assessing the need for 

further action in the light of the evolving policy context. In this context the Commission is 

called upon to present appropriate proposals for revision of the relevant provisions of the 

regulation, where necessary. Aspects for review have been identified based on Article 10 

and the results of work undertaken within the current project. These options and their key 

environmental, economic and social impacts in EU-27 are assessed (chapter 8). 

The overall purpose of this project is to assist the Commission in reviewing Regulation (EC) 

No 842/2006 by providing technical data, analyses and general support. A service contract 
Chapter 1 Introduction 4

carried out by Öko-Recherche and partners since December 2009 includes the following 

tasks5

: 

- A review of relevant F-gas markets and policies internationally as well as in the EU-27, 

including investigation of possible interactions, complementarities or overlaps amongst 

the EU F-gas policy framework (F-gas Regulation and MAC Directive) and other EU or 

international policies. 

- An assessment of the effectiveness of current EU F-gas policy, through the development 

of appropriate models and datasets for emission scenarios in EU-27 and an ex-post 

assessment of the key elements of the current EU F-gas policy. 

- An assessment of the feasibility of emerging options for an international emission 

reduction arrangement for HFCs and, if appropriate, other F-gases by assessing the 

feasibility and cost-effectiveness of the replacement of F-gases, developing and 

comparing of scenarios for the control of consumption and/or production of HFCs and 

while considering any other elements that could be appropriate to complement a 

possible international reduction arrangement for HFCs. 

- The development of options and recommendations for further action at EU level and an 

assessment of key impacts. 

The project was guided by a Steering Group from the European Commission. In addition, an 

Expert Group consisting of experts on fluorinated gases from authorities in EU-27, industry 

and non-governmental organisations has commented and provided further input to the work. 

This process has enabled the authors of this report to substantially improve the model 

assumptions and background data. 

 

5

 European Commission: Specifications to tender ENV.C.4/SER/2009/0033 Service contract to provide 

technical support for conducting a review of Regulation (EC) No 842/2006 on certain fluorinated 

greenhouse gases. 
Chapter 2 Methodology 5 

2. Methodology 

2.1 Collection of data and information 

The work undertaken is based on various sources of information in order to cover the 

different needs for quantitative or qualitative data, historic time series or trends and 

projections, policy measures including legislation, sectoral and country information, data for 

certain Member States, EU-27, developed countries, developing countries or the world. 

2.1.1 Basic and background information 

Existing and on-going studies and scientific articles serve as important sources of sectoral 

details and approaches, as well on global and regional concepts and trends. Major sources 

include recent reports by UNEP TEAP, the IPCC Special Report on Safeguarding the Ozone 

Layer and the Global Climate System as well as the IPCC 4th Assessment Report. 

General expertise on F-gases, their alternatives and sectoral expertise are available through 

the project team lead by Öko-Recherche holding long-term experience and archives on the 

use of F-gases and methodologies required for the analysis to be undertaken. 

Data from the Member States reported according to Article 6 of the F-gas Regulation have 

been complemented and cross-checked with the latest national communications under the 

UNFCCC6

. In addition, national greenhouse gas inventory submissions by the Member 

States and the EU to the UNFCCC served as data input, in particularly CRF data were used 

for modelling purposes and are indicated in the model description (annex III). 

2.1.2 Data on the status of implementation and application of the F-gas 

Regulation

An assessment of the status of implementation of the F-gas Regulation and the application of 

its most important measures in the Member States has been undertaken. It should be 

underlined that the implementation of the F-gas Regulation is delayed to some extent and 

not completed in all Member States yet. Therefore, this section is not an ex-post assessment 

in a strict sense but rather an assessment of the status of implementation and first results of 

the application of the Regulation. 

The assessment analyses 

• to what extent the current EU F-gas policy and in particular the relevant provisions of 

the F-gas Regulation have been implemented (chapter 4.1) and applied (chapter 4.2) 

in the EU-27 Member States and which costs arise from implementation and 

application of the Regulation (chapter 4.3). 

• Whether qualitative and quantitative findings can already be made, whether the 

application of the F-gas Regulation has already lead to results in terms of its general 

objectives and whether it will continue to do so. 

 

6

 Annex I parties to the UNFCCC were requested to submit their fifth national communications to the 

UNFCCC Secretariat by 1 January 2010 (Decision 10/CP.13 of December 2007). 
Chapter 2 Methodology 6 

The outcome of this assessment provides important background information for the 

identification of options for further action including through a potential revision of the F-gas 

Regulation (chapter 8). The survey is based on the following sources besides the evaluation 

of literature: 

− Evaluation of a basic questionnaire (March 2010) which has been submitted to the 

competent authorities in all Member States. All Member States replied to this 

questionnaire and additional questions in oral and written form. Some of them also 

submitted more comprehensive documentation such as national assessments and 

studies already available. Although for some Southern and small Member States only 

limited data are available, the information on status of implementation and application of 

the F-gas Regulation in most of the EU-27 is quite detailed. The last survey amongst 

Member States (and industry) on the status of implementation and application of 

certification provisions of the Regulation dates from June 2011. 

− Stationary refrigeration, air conditioning and heat pump sector: Evaluation of a 

questionnaire designed for industry stakeholders, who produce, design, install and 

maintain heating, cooling and refrigeration technologies (March 2010). These include 12 

national and multinational companies who are members of EPEE (European Partnership 

for Energy and the Environment). The companies introduced their own knowledge and 

partly consulted their clients (operators). The questionnaire has also been answered by 4 

national industry associations (AFCE/France, ATF/Italy, FETA/UK, and NRF/Poland). 20 

completed questionnaires were analyzed encompassing details for 10 EU-Member 

States (Belgium, Denmark, France, Germany, Greece, Italy, Netherlands, Poland, Spain, 

and United Kingdom). EPEE submitted additional data on the status of implementation 

and application of the F-gas Regulation in the Member States including data on 

certification and training from 10 Member States. 

A consolidated report from the European-wide association of small and medium-sized 

service companies and contractors, AREA, has been evaluated within a discussion with 

AREA. This report is a summary of replies on a questionnaire designed for companies 

from the national AREA member associations and includes information on and by 18 EUMember States (Austria, Belgium, Czech Republic, Denmark, Finland, France, Germany, 

Greece, Hungary, Ireland, Italy, Netherlands, Poland, Portugal, Sweden, Slovakia, Spain, 

and United Kingdom). 

Evaluation of a consolidated report from ECSLA, the European Cold Storage and 

Logistics Association, including data from France, Germany, Greece, Netherlands, and 

Spain. The report is based on replies from ECSLA member associations to the 

questionnaire designed for companies from the stationary refrigeration, air conditioning 

and heat pump sector. 

− High voltage switchgear sector: Evaluation of a questionnaire (March 2010) to industry 

which has been answered by national associations (Austria, France, Germany, Italy, and 

Spain) as well as the European umbrella organization T&D Europe. Data was obtained 

on all EU-Member States and additional background information from T&D Europe. The 

data were evaluated during a discussion with T&D Europe. The European association of 

network operators EURELECTRIC joined the responses of T&D-Europe. Additional 

information was submitted by the company EATON corporation. 
Chapter 2 Methodology 7 

− Fire protection sector: Evaluation of a questionnaire (March 2010) to the umbrella 

organizations EUROFEU and ASSURE. Replies and additional information were received 

from national associations of EUROFEU (Germany, Italy, the Netherlands, Spain, 

Sweden, and UK) as well as from companies from some Member States. The data were 

analysed in a meeting with EUROFEU, section Fire Extinguishing Installations. ASSURE 

submitted a consolidated report. 

− F-gas based solvents sector: Information was provided by the manufacturer (DuPont) 

and by DEFRA (UK). 

− Manufacturers of F-gases: Evaluation of replies from manufacturers of F-gases from 

the association EFCTC (European Fluorocarbon Technical Committee, CEFIC-member) 

and from EFCTC member companies to some questions of the questionnaire designed 

for companies active in the stationary refrigeration, air conditioning and heat pump 

sector. 

− Additional country information: A separate survey of companies and organizations 

from the sectors of SRAC/HP, Fire Protection Systems, High-Voltage Switchgear and 

Mobile AC in the Baltic Member States Estonia, Latvia, and Lithuania was carried out by 

the EERC (Estonian Environmental Research Centre). 

− Cost data: Information on costs came from the above mentioned sources, from 

certification bodies and from training centres from several Member States. 

− Methodological issues: Discussions with representatives from the Dutch STEK 

organisation on methodological aspects of data calculation in the STEK system. 

The level of detail and quality of responses to the questionnaires and follow-up questions 

varied considerably. Information from industry stakeholders for the stationary refrigeration, air 

conditioning and heat pump sectors are available from all Member States with the exception 

of Bulgaria, Cyprus, Luxembourg, Malta, Romania and Slovenia. Data for the sectors HighVoltage Switchgear and Fire Protection Systems is available from some Member States and 

mainly from industry. F-gas based solvents are not applied to a relevant extent in any 

Member State with the exemption of France and UK. The information from companies in this 

sector is limited to the one relevant manufacturer. 

The data quality and comprehensiveness is relatively higher in the stationary refrigeration, air 

conditioning and heat pump sector and the high voltage switchgear sector, compared to the 

other sectors. All stakeholders involved in the investigation underlined with regard to the 

assessment of the effectiveness of the F-gas Regulation that the timeframe since the entry 

into force of the F-gas Regulation and since the start of its implementation and application is 

far too short to allow judgements in terms of quantitative data, in particular with regards to 

containment measures. Insofar qualitative information and subjective assessments had to be 

carefully considered. 

Based on these sources the status of implementation of certain provisions of the F-gas 

Regulation and of its application were assessed at three points in time: 1st quarter 2010, 

January 2011 and July 2011. 
Chapter 2 Methodology 8 

2.1.3 Role of the Expert Group

An Expert Group established by the Commission to provide additional expertise during the 

preparatory phase of the review comprises representatives of competent authorities, of 

industry associations from all sectors and non-governmental organisations active in the field 

of fluorinated greenhouse gases. The Expert Group has been invited to comment on the 

data, assumptions and results derived throughout this project, on the basis of three Working 

Documents (September-October 2010, February 2011, May 2011) aiming at improving the 

quality of the final outcome. This report takes into account those comments, suggestions and 

input, as and where considered appropriate. 

Where necessary, the project team has solicited direct follow-up input to the ongoing work by 

several members of the Expert Group and other experts. 
Chapter 2 Methodology 9 

2.2 Compilation of sectoral data and modelling 

2.2.1 Compilation of data and development of models 

Quantitative data were compiled for each sector relying on F-gases and for the halocarbon 

production and primary aluminium sectors in which F-Gases are emitted as by-products or as 

fugitive emissions. The classification of sectors follows the structure for the emissions 

reporting under UNFCCC (CRF tables) and includes the following subsectors: 

- Domestic refrigeration (HFCs) 

- Commercial refrigeration: Stand-alone equipment; Condensing units; Centralised 

systems (HFCs) 

- Industrial refrigeration: Small refrigeration plants, Large refrigeration plants (HFCs) 

- Refrigerated transport: Refrigerated vans; Refrigerated trucks & trailers; Refrigerated 

containers; Refrigerated fishing vessels (HFCs) 

- Stationary air conditioning and heat pumps: Moveable air conditioners; Split air 

conditioners; Multi split air conditioners; Rooftop air conditioners; Displacement 

chillers; Centrifugal chillers; Heat pumps (heating only) (HFCs) 

- Mobile AC: Passenger Cars; Trucks; Buses; Rail vehicles; Cargo ships; Passenger 

ships (HFCs) 

- Foam sectors: One-component foam (canned); XPS and PU insulation foam for the 

construction sector; PU insulation foam for refrigeration applications; Non-insulating 

integral foams for automotive, furniture sectors, shoe soles, etc. (HFCs) 

- Fire protection sectors: Fire protection (HFC-227ea and HFC-23) 

- Aerosols: technical and novelty aerosols; MDIs (HFCs) 

- Primary Aluminium production (PFCs) 

- Semiconductor industry (PFCs) 

- Electrical switchgear (SF6) 

- Magnesium casting and secondary Aluminium (SF6) 

- Soundproof glazing (SF6) 

- Car tyres (SF6) 

- Sport shoe soles (SF6) 

- Production of halocarbons (HFCs, PFCs, SF6) 

For each sector, historic data, expert estimates of the current situation as well as for short 

term and long term trends were compiled for EU-27, developed countries and developing 

countries. 
Chapter 2 Methodology 10 

2.2.2 The model AnaFgas 

The model AnaFgas (Analysis of Fluorinated greenhouse gases in EU-27) is a bottom-up 

stock model to derive demand and emission scenarios for F-gases in relevant sectors and 

sub-sectors for the EU-27 Member States. It models demand for and emissions of HFCs, 

PFCs and SF6 as well as HCFC-22 for the period 1995 to 2050 based on market data and 

estimates of the quantity of equipment or products sold each year containing these 

substances, and the amount of substances required in the EU to manufacture and/or 

maintain equipment and products over time. 

All emission and demand estimates are derived from bottom-up approaches, i.e. by 

estimating demand and emissions per sector through the use of underlying driving factors. 

These include annual changes in equipment stock, composition and charge of the 

equipment, leakage during equipment lifetime and during disposal. Some of these 

components are driven by other factors such as population development, GDP growth or 

technological changes. Based on these drivers, annual emissions and banks as well as use 

can be calculated for each year, sub sector and EU Member State. 

AnaFgas makes use of market information to build an inventory of the in-use stocks of the 

equipment in each of the end-uses in each country. This includes the percentage of the 

equipment stock that contains each F-gas. These modelled stock inventories are maintained 

through the annual addition of new equipment/new F-gas quantities and the retirement of 

equipment after an appropriate number of years. Annual leak rates, servicing emissions, and 

disposal emissions are estimated for each of the end-uses. 

Figure 2-1: Scheme of the sectors and sub-sectors covered by AnaFgas 

Through these emissions which occur during the lifetime of equipment, the lag between use 

of a chemical and actual emission of this chemical is reproduced. Aggregating emission and 

use over the different end-uses, the model produces estimates of total year-specific annual 

demand for and emissions of each substance expressed in metric tonnes or GWP-weighted 

(kt CO2 eq). 
Chapter 2 Methodology 11 

Seven sectors with a total of 29 sub sectors are separately represented in the model (see 

figure 2-1). In total 21 different fluorinated gases (excluding ozone-depleting gases) are 

included in the model (11 HFCs, 5 PFCs, 2 unsaturated HFCs, 1 fluoroketone, SF6, NF3) and 

calculations can either be based on metric tonnes or global warming potential (GWP) (table 

2-1). 

In addition, the GWP included in the second, third or fourth IPCC Assessment Report (2nd, 

3rd, 4th AR) can be chosen. Use and emissions are calculated annually for all years between 

1995 and 2050. 

Table 2-1: List of gases and global warming potentials included in the model AnaFgas7

Industrial Designation or 

Common Name Chemical Formula

2nd AR 3rd AR 4th AR 

Carbon dioxide CO2 1 11

404A 44% 125, 4% 134a, 52% 143a 3,260 3,784 3,922

407C 23% 32, 25% 125, 52% 134a 1,526 1,653 1,774

507 50%125, 50% 143a 3,300 3,850 3,985

410A 50% 32, 50% 125 1,725 1,975 2,088

CFC-11 CCI3F 3,800 4,600 4,750

CFC-12 CCI2F2 8,100 10,600 10,900

HCFC-22 CHCIF2 1,500 1,700 1,810

HCFC-141b CH3CCI2F 600 700 725

HCFC-142b CH3CCIF2 1,800 2,400 2,310

HFC-23 CHF3 11,700 12,000 14,800

HFC-32 CH2F2 650 550 675

HFC-125 CHF2CF3 2,800 3,400 3,500

HFC-134a CH2FCF3 1,300 1,300 1,430

HFC-143a CH3CF3 3,800 4,300 4,470

HFC-152a CH3CHF2 140 120 124

HFC-227ea CF3CHFCF3 2,900 3,500 3,220

HFC-236fa CF3CH2CF3 6,300 9,400 9,810

HFC-245fa CHF2CH2CF3 950 1,030

HFC-365mfc CH3CF2CH2CF3 890 794

HFC-43-10mee CF3CHFCHFCF2CF3 1,300 1,500 1,640

Sulphur hexafuoride SF6 23,900 22,200 22,800

Nitrogen trifuoride NF3 – 10,800 17,200

PFC-14 CF4 6,500 5,700 7,390

PFC-116 C2F6 9,200 11,900 12,200

PFC-218 C3F8 7,000 8,600 8,830

PFC-318 c-C4F8 8,700 10,000 10,300

PFC-3-1-10 C4F10 7,000 8,600 8,860

HFC-1234yf

HFC-1234ze

290 propane C3H8

600a isobutane C4H10

pentanes C5H12

fluoroketone FK 5-1-12 C6F12O

3

4

5

1

4

6

Hydrocarbons and other compounds - Direct Effects

Substances controlled by the Montreal Protocol

unsaturated Hydrofuorocarbons

Hydrofuorocarbons

HFC blends

GWP (100yr)

Not listed in IPCC AR

 

7

 The GWPs of unsaturated HFCs in this list are not included in any IPCC report. 
Chapter 2 Methodology 12 

The model output can be expressed in three different ways (see figure 2-2): 

1) emissions and use per chemical substance, 

2) emissions and use per source, and 

3) emissions and use per (sub-)sector. 

The stock model requires input regarding the market growth for each of the end-uses, as well 

as a history of the market penetration of F-gases. For the purpose of projecting the use and 

emissions of F-gases into the future, AnaFgas incorporates the available information about 

probable evolutions of the end-use market, trends of F-gas substitution and trends of 

emission factors. It also requires assumptions on future growth trends in different areas such 

as population development, growth in transport (passenger and freight), change in social 

structure, consumer habits and lifestyle. 

EU-27

Fourth AR 1995 2000 2010 2020 2030 2050

Without measures (Emissions)

Total by Gas [kt CO2eq] 1,628.1 13,471.1 39,346.9 52,883.7 54,832.9 56,861.5

HFC 134a [kt CO2eq] 68.9 531.9 2,644.3 2,512.8 1,785.6 1,956.2

HFC 143a [kt CO2eq] 344.4 7,219.3 21,537.6 30,007.6 31,907.4 33,025.1

HFC 125 [kt CO2eq] 228.2 4,783.0 14,424.6 20,290.6 21,139.8 21,880.3

HFC 32 [kt CO2eq] 0.0 0.0 27.5 72.6 0.0 0.0

R22 [kt CO2eq] 986.6 936.9 712.8 0.0 0.0 0.0

Total by Source [kt CO2eq] 1,628.1 13,471.1 39,346.9 52,883.7 54,832.9 56,861.5

Manufacturing Emissions [kt CO2eq] 13.9 8.3 0.0 0.0 0.0 0.0

Lifetime Emissions [kt CO2eq] 1,614.2 13,462.8 35,704.7 44,584.2 47,078.9 48,614.9

Disposal Emissions [kt CO2eq] 0.0 0.0 3,642.2 8,299.5 7,753.9 8,246.7

Total by Sector [kt CO2eq] 1,628.1 13,471.1 39,346.9 52,883.7 54,832.9 56,861.5

Domestic Refrigeration [kt CO2eq] 30.6 58.0 1,149.8 527.0 15.4 15.5

Commercial Refrigeration [kt CO2eq] 66.9 9,118.2 24,473.3 32,301.2 34,001.8 34,815.2

Industrial Refrigeration [kt CO2eq] 522.1 2,886.2 9,778.2 15,414.4 15,843.2 15,859.4

Road transport Refrigeration [kt CO2eq] 1,008.4 1,408.8 2,932.5 3,437.3 4,066.7 5,325.7

Shipping Refrigeration (fisheries) [kt CO2eq] 0.0 0.0 1,013.2 1,203.8 905.8 845.8

Refrigeration

Country

GWP

Figure 2-2: Model output by substance, source and sector. 

Projections by Member States and IPCC/TEAP SROC Report8 and the recent TEAP reports 

are included in the growth assumptions for the model scenarios until 2050. For the 

projections of activity data including charges and F-gas split, and emission factors until 2050 

AnaFgas generally distinguishes between two different time periods: 

• Near future (5-10 years) is modelled on known policies and measures, technological 

changes, substitution patterns and expected changes in use patterns, and 

• distant future (until 2050) is based on a continuation of trends observed, external 

projections of driving forces such as GDP and population and follows a business as 

usual trend as the model does not consider changes in technologies which are likely to 

happen within such a long timeframe. 

Underlying assumptions for each sector in the model AnaFgas are outlined in detail in the 

model description in annex III. Specific information on each sector for EU-27 is summarized 

in the EU sector data sheets (annex V). 

 

8

 IPCC/TEAP Special Report on Safeguarding the Ozone Layer and the Global Climate System: 

Issues Related to Hydrofluorcarbons and Perfluorcarbons. 2005 Prepared by Working Group I and III 

of the Intergovernmental Panel on Climate Change, and the Technology and Economic Assessment 

Panel. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, 488 pp. 
Chapter 2 Methodology 13 

The scenarios calculated by the model AnaFgas for EU-27 include the following scenarios: 

• Without measures (WOM) scenario: A counter-factual demand and emission 

scenario for the EU-27 and each MS reflecting the situation that would likely have 

occurred since 1995 (baseline year for F-gases under the Kyoto Protocol) without the 

2006 EU policy intervention (F-gas Regulation, MAC Directive). The projected 2050 

quantities of use emissions are based on sub-sector specific growth assumptions, 

which in most cases do not include technological change or introduction of alternative 

fluids (“frozen technology”). Often the use level of the last year, or the trend over the 

last years before enforcement of the European F-gas legislation is extrapolated to the 

future. Details are given in the model description in annex III to this report. 

• With measures (WM) scenario: A scenario of actual or baseline demand and 

emission trends for the period 1995-2050 taking into account the existing policies and 

measures to reduce F-gas use and emissions at EU-27 level and for each Member 

State. The ‘with measures’ scenario is based on the same underlying growth trends 

as the WOM scenario, but varies those parameters of the estimation that are 

influenced by the European legislation for the period since Member States started to 

implement the respective policies and measures. These parameters include leakage 

rates, recovery efficiency and the substitution of certain gases in certain applications 

which would not have occurred without a policy intervention. 

By comparison of the WOM scenario and the WM scenario it is possible to estimate the 

impact of the F-gas Regulation on the current and future emissions. 

With additional measures (WAM): A scenario for the demand and emission trends in the 

EU and Member States with additional measures to mitigate F-gas emissions. This scenario 

is developed in chapter 8 where options for such measures are presented and analysed. 
Chapter 2 Methodology 14 

2.2.3 Two scenarios for global HFC consumption 

In addition to the EU scenarios of the model AnaFgas, two further scenarios are calculated 

and include a business-as-usual (BAU) projection of global HFC use for the period 2010-

2030, and scenarios of reductions of global HFC consumption in the same period. Each 

scenario is calculated for both developed (A2) and developing countries (A5)9

. Europe forms 

part of the group of developed countries. 

• Business as usual (BAU) scenario: A global HFC consumption scenario reflecting 

the situation that will likely occur from 2010 onwards based on current industry 

trends. It includes the accelerated HCFC phase out under the Montreal Protocol in 

developing countries and integrates alternative technologies to the extent they likely 

replace conventional HFCs without additional policy measures10. 

• Reduction (RED) scenario: An abatement scenario reflecting the maximum 

technically feasible replacement of HFC technology by different types of abatement 

technology from 2010 onwards regardless costs. It is assumed that abatement 

options are chosen for all new equipment and production lines from 2010 onwards 

wherever feasible. A modification of this reduction scenario is RED10, which reflects 

replacement of HFC technology by different types of abatement solutions from 2010 

onwards only when below an abatement cost threshold of 10 € / t CO2 equivalent. 

The two scenarios are put into the context of international action to reduce F-gas emissions 

by comparing them to the schedules of the amendment proposals on HFC phase down 

discussed under the Montreal Protocol (chapter 7). The difference between the baseline 

scenario (business-as-usual) and the reduction scenario defines the maximum potential to 

reduce HFC consumption until 2030 in A2 and A5 countries. 

In contrast to AnaFgas, the calculation of the two global scenarios is not intended to estimate 

how containment and recovery measures reduce F-gas emissions but it shall help quantify 

the possible use of HFCs in their various applications. 

Both business-as-usual and reduction scenarios are calculated bottom up on the level of 

sectors and sub sectors of HFC/HCFC application. The calculation includes for both A2 and 

A5 countries 

- 7 sub sectors of stationary refrigeration 

- 2 sub sectors of transport refrigeration 

- 8 sub sectors of stationary air conditioning and heat pumps 

 

9

 Developed countries are called A2 countries in this report based on the terminology of the Montreal 

Protocol. Developing countries are called A5 countries accordingly. Under the Montreal Protocol, the 

decision whether a particular country is considered A5 or Non-A5 country depends on the annual per 

capita consumption of ODS. Countries where the annual per capita consumption of ODS is <0.3 kg 

are considered developing countries (A5 countries). The Russian Federation, Eastern European 

transformation countries and certain Arab countries are hence classified as developed countries (A2 

countries). This classification might not be consistent with the classification of developed and 

developing countries under other multilateral environmental agreements, e.g. the UNFCCC/Kyoto 

Protocol which refers to Annex 1 countries (developed countries) and Non-Annex 1 countries 

(developing countries). 

10 The EU MAC Directive, which leads to alternatives to conventional HFCs, is an existing political 

measure and therefore included in the BAU scenario. 
Chapter 2 Methodology 15 

- 3 sub sectors of mobile air conditioning 

- 12 sub sectors of XPS/PU foam 

- 2 sub sectors of fire protection 

- 1 sector of aerosols11. 

At the sector level, the calculation of the business-as-usual scenario is based on following 

data which are collected for both A2 and A5 countries: 

- New units per year12

- Total stock units 

- Average technical characteristics per unit including lifetime, charge size, HFC/HCFC 

types, leakage rates, rated capacity, annual energy use, costs 

- HFC/HCFC bank in 2006/2010 

- Annual growth rates until 2030 

- Possible change in refrigerant/blowing agent composition for new units 

On the basis of these data the size of HFC bank and the annual use of HFCs for 

manufacturing (first fill) and servicing (refill) can be estimated. It is assumed that production 

capacities will follow the demand. 

The calculation of the baseline scenarios was carried out by the sector experts in the project 

team widely using the relevant UNEP TEAP reports of RTOC, FTOC, and CTOC, and of the 

IPCC/TEAP SROC, evaluated market studies, and interviewed industry experts which 

provided first-hand information e.g. on cost. 

For the reduction scenario, the calculation includes (a) identification of technically feasible 

abatement options for each sub sector, (b) assessment of their incremental cost compared to 

conventional HFC technology, and (c) analysis of application constraints and possible market 

penetration of alternative solutions. 

A basic prerequisite for alternative technical options identified by the experts was energetic 

equivalence with conventional HFC technology. Only those abatement options are 

considered further that can show better or at least the same energy performance as the 

reference HFC technology. This criterion is important because additional energy 

consumption would negatively impact the total climate performance of a system (TEWI) up to 

the point where reductions of direct F-gas emissions by replacement of HFCs could be 

reversed by additional CO2 emissions from energy use and production (indirect emissions). 

This important methodological aspect and the work result are comprehensively presented in 

chapter 6 of this report; detailed information on all sector assumptions and abatement 

options is given in annex V (global data input sheets) and annex VI (Abatement technologies 

 

11 The BAU scenario and the Reduction scenario for HFCs include also MDIs but do not specifically 

analyse this sub sector. Reductions to the MDIs are not considered because substitution of HFCs in 

MDIs needs specialised investigation. Therefore in the models the BAU and RED scenarios for MDIs 

are identical. Health aspects related to the application of MDIs as compared to potential abatement 

technology should be investigated by experts from the medical and pharmaceutical industry. It should 

be mentioned that MDIs with ODS propellants are “essential uses” under the Montreal Protocol. 

12 In refrigeration and air conditioning and fire protection the units are discrete pieces of equipment. In 

the foam sector the “units” are production lines of average size, output and lifetime. 
Chapter 2 Methodology 16 

by sectors). The determined penetration rates represent best estimates. Further technical 

developments (e.g. hybrid systems) are not included as empirical data are lacking widely. 

Differences between the EU scenarios and the global scenarios 

Although the same approach (bottom up stock calculation) is applied to the scenarios for 

Europe (WOM and WM scenario), which are based on the model AnaFgas, and to the global 

HFC use scenarios (business-as-usual and reduction scenario), several important 

differences of content and background assumptions need to be noted, and are shown in 

tabular form below. 

Table 2-2: Differences between the F-gas scenarios for Europe and the global HFC scenarios 

EU scenarios (AnaFgas) Global scenarios 

Content Quantities for manufacturing and 

servicing. 

Emissions in use phase and at 

disposal 

Quantities for manufacturing and 

servicing 

Substances HFCs, PFCs, SF6, HCFC-22 HFCs and HCFCs 

Sectors 40 sectors with HFCs, PFCs, SF6

and production of halocarbons 

21 HFC based key sectors 

Foam sector 

differentiation 

4 sectors (only of EU relevance) 2 x 9 sub sectors, in A2 and A5 

Geographic scope EU-27 Developed countries (A2; incl. EU27) and developing countries (A5) 

Leakage rates In EU sometimes lower than in A2 

(incl. USA and Japan) due to the 

application of containment provisions 

under the F-Gas Regulation 

A2 average sometimes higher than 

in EU 

Recovery efficiency Considered Not considered 

Reduction measures Containment and recovery, 

some use and placing on the market 

prohibitions by F-gas Regulation 

(WM scenario) 

Application of alternative technical 

solutions with low GWP 

Alternative technical 

solutions 

Third scenario “With additional 

measures” 

Reduction scenario RED 

Containment and 

recovery 

Content of WM scenario Not considered 

Cost estimates For containment and recovery 

measures of F-gas Regulation (WM 

scenario), and for low-GWP 

alternative technologies 

For alternative, low-GWP 

technologies 

Baseline Existing trend to alternative solutions 

only exceptionally considered 

Alternative technologies partly 

included in BAU trend 
Chapter 2 Methodology 17 

2.2.4 The terms demand, supply and consumption

This study analyses and discusses emissions primarily from use and disposal of F-gas 

containing applications. The annual quantity of F-gases that flows into individual application 

sectors at the level of individual Member States, at EU level, and globally for A2 and A5 

countries is calculated. In the sector by sector approach (bottom up) the annual F-gas flow is 

the amount required for new systems (“first fill”)13 plus the amount for refilling of existing 

closed systems during servicing (“refill”) to compensate for leakage. The equation for 

demand is: 

Demand (D) = First fill + Refill. 

The annual demand for first fill and refill is completely based on sector specific charges and 

emission factors. Charges and emission factors, which are included e.g. in the model 

AnaFgas, are the only determinants of the demand of a particular sector, of a Member State, 

of the EU, or of A2 and A5 countries. 

Based on the bottom-up approach used in this study, the definition of demand which includes 

first fill and refill does not depend on 

- whether the F-gases are domestically manufactured or imported 

- whether the F-gases are virgin material from chemical manufacture or used material 

from recycling or reclamation 

- whether or not at end of equipment life used F-gases are released to the atmosphere 

or recovered for recycling or reclamation, or for destruction. 

Qualitative difference between demand and consumption 

The term demand which is calculated as the total of sectoral first fills and refills must not be 

confused with the term consumption as defined under the Montreal Protocol for ozonedepleting substances representing the supply in bulk quantities which serves the demand for 

bulk quantities. Consumption is clearly defined in Article 1 of the Montreal Protocol and has a 

particular meaning: It represents for a country the total amount of substances that are 

supplied to emissive end-uses and includes production of controlled substances plus imports 

minus exports of controlled substances, and minus the amount for destruction and the 

amount used as feedstock in the manufacture of other chemicals. Like exports, the latter are 

no part of the supply to emissive end-uses in the country. 

The equation for consumption (under the Montreal Protocol) is: 

Consumption (C) = Production + Imports – Exports – Feedstock – Destruction. 

Consumption is therefore not measured on a bottom-up basis like demand but from a topdown perspective. It defines for a country the overall emission potential (“potential 

emissions”) regardless whether the produced and imported quantities of substances are 

used for first fill or for refill, and, vice versa, the term demand does not account for the 

distinction of the annual flow of substances into production, import, destruction or feedstock. 

 

13 The quantity per new system includes not only first fill into closed equipment of air conditioning, 

refrigeration, fire protection, and electrical switchgear or filling of aerosol and OCF cans, but also the 

quantity for the manufacture of XPS/PU foam and of semiconductors, as well as use as solvent or 

cover gas. 
Chapter 2 Methodology 18 

Quantitative differences between demand and consumption 

The quantities of F-gases used as feedstock and subject to destruction are much lower than 

feedstock quantities and destroyed quantities of ozone-depleting substances. Under the 

Montreal Protocol, feedstock is primarily HCFC-22 as intermediate for PTFE plastics and 

represents a considerable part of the worldwide production of ODS. In contrast, the use of Fgases as feedstock plays a marginal role only. The same applies to destruction. Unlike the 

Montreal Protocol, which aims at complete phase-out of controlled substances, the Kyoto 

Protocol aims only at reduction, and the objective of the proposals for an international HFC 

agreement as an amendment to the Montreal Protocol (see chapter 7) is not phase-out but 

phase-down. So far, deliberate destruction of F-gases is not envisaged apart from 

contaminated quantities which cannot be recycled or reclaimed. Reuse, recycling and 

reclamation of F-gases are explicitly supported by the F-gas Regulation. 

Considering the relatively low importance of destruction and feedstock for annual 

consumption of F-gases, the quantitative difference between consumption (including 

production and imports while excluding destruction and feedstock) and demand (including 

first fill and refill) is small. Both terms refer to amounts of almost the same size. As a 

consequence, it could be assumed that the first fill plus refill (demand) equals production plus 

import minus export (consumption). 

There is, however, another fact which does not allow the equation of demand as calculated 

in the models of this study with consumption as defined under the Montreal Protocol. 

Consumption accounts for recycling and reclamation insofar as domestic recycling and 

reclamation for domestic reuse causes reduction of production and/or imports14. The higher 

the extent of recycling for domestic use is, the lower the need for imports or production for 

domestic use. In this study, for the term demand it does not matter whether the supply for 

first fill or refill is domestically produced, imported or recycled. It thus follows that the 

modelled demand for first fill and refill is higher than consumption/supply which includes 

production and imports minus exports when recycling for domestic reuse takes place in a 

country. 

The equation for demand and consumption, specifically in this study is 

Demand (First fill + Refill) = Consumption (Production + Imports – Exports) + Recycling (feedstock and 

destruction = 0). 

As a consequence, in this report the term consumption is carefully used, even if all produced 

and imported F-gas quantities represent supply that serves the calculated demand. 

Consumption is a top-down category, which rarely matches the bottom up modelled demand. 

First extension of the terms demand and supply (import of prefilled systems) 

It has to be noted that the demand as well as the consumption of a country (or the EU) does 

not represent exactly the amount of substances which can potentially be emitted in the 

country if there is a considerable quantity of substances contained in imported or exported 

pre-charged equipment. The first fill of such equipment is carried out in one country but after 

installation of the equipment the quantity causes use-phase (and disposal) emissions in 

another country. 

 

14 In the theoretical limit, recycling can serve all first fill and refill (emissions = 0, first fill = amount for 

disposal), without any production or import of substances. 
Chapter 2 Methodology 19 

So far, first fill and refill as part of the demand as well as production and import as part of the 

consumption refer to F-gases in bulk quantities. In order to account for the emission potential 

of equipment which is first charged outside the country considered (e.g. the EU), the term 

demand as well as the term supply must also include F-gas quantities in imported precharged systems. As a result, the term supply no longer corresponds to the term 

consumption under the Montreal Protocol. 

The demand includes not only first fill and refill of systems that are manufactured in the EU 

for domestic use but also first fill outside the EU in systems which are imported into the EU 

and the domestic refill into these imported systems during their use-phase and disposal. 

The equation for the extended demand for F-gases (1st extension) in the EU is 

Demand ext1 = First fill of systems for domestic use + First fill of systems imported in the EU + Refill

of systems for domestic use + Refill of imported pre-charged systems. 

Correspondingly, the term for the respective supply changes and includes not only 

production and import (minus export, minus feedstock, minus destruction) in bulk quantities 

to serve the demand for first fill and refill of domestically manufactured systems and the refill 

of imported equipment but also the import of F-gases in pre-charged imported systems. 

However, this supply does not include the quantity of F-gases in pre-charged systems 

exported from the EU. 

The corresponding equation for the extended supply of F-gases is 

Supply ext1 = Production + Imports (bulk) – Exports (bulk) – Feedstock – Destruction.+ Imports (pre-charged) – 

Exports (pre-charged) . 

In chapters 1-5 of this study no need arises to use the extended terms of demand and 

supply. This also applies to chapter 7 on a potential international HFC agreement, where the 

term consumption is used in its Montreal Protocol definition, bearing in mind that the annual 

HFC flow in A2 and A5 countries has been calculated in this study as a demand category, 

based on the estimation of first and refill in the individual application sectors. 

In chapter 6, however, HFCs in imported pre-charged equipment as part of the supply (or 

first fill into imported pre-charged equipment as part of the demand) must be accounted for in 

one particular sector. This sector is stationary air conditioning where most systems of the 

moveable and split type for use in Europe are first filled in Asia. For this sector, the extended 

terms demand and supply are used. 

Second extension of terms demand and supply (export of prefilled systems) 

In chapter 8 on further EU action, amongst other policy options the possibility is discussed to 

reduce the demand for HFCs within the EU by limitation of the supply of HFCs. As this option 

refers to all HFC application sectors, the demand for first fill must include not only the 

domestic first fill in equipment for EU use, and the first fill into pre-charged equipment which 

is imported in the EU (= demand ext), but also domestic first fill into equipment which is precharged for export. Domestic first fill for export equipment is relevant with regard to mobile air 

conditioners of motor vehicles (passenger cars, trucks, busses) and medical aerosols 

(MDIs). Like the refill in the first extension of demand, refill includes now both refill of systems 

manufactured in the EU for domestic use and refill into imported systems. 
Chapter 2 Methodology 20 

The equation for the second extension of demand for HFCs is 

Demand ext2 = First fill of systems for domestic use + First fill of systems imported in the EU + First 

fill of systems pre-charged for export from the EU + Refill of systems for domestic use + Refill of 

imported pre-charged systems. 

The second extension of demand includes the first fill of pre-charged systems for export. It 

does not include the refill of those systems in the use-phase as this takes place in another 

country. 

The supply of HFCs which serves the demand for the different types of domestic first fill and 

refill consists of bulk quantities from domestic production and/or imports of HFCs. This also 

applies to the supply for first fill of systems pre-charged for export. In addition, supply 

includes HFCs in imported pre-charged systems. 

The equation for the extended supply of HFCs is 

Supply ext2 = Production + Imports (bulk) – Exports (bulk) – Feedstock – Destruction.+ Imports (pre-charged). 
Chapter 2 Methodology 21 

2.3 Measurability of emission reductions in 2011 and emission 

factors in AnaFgas 

F-gas emissions are caused by the interplay of stocks and leakage which is expressed by 

emission factors. Hence two general policy strategies to reduce emissions are evident: 

reducing banks and reducing leakage rates. Both strategies are already implemented at 

European and Member State level: 

- Containment strategies aim at reducing emission factors of new and existing equipment. 

The underlying principle is that F-gases do not cause environmental impact as long as 

they are contained within their applications. 

- Substitution strategies aim at reducing the total bank of products and equipment 

containing F-gases, thereby targeting emissions at the source. 

The choice between containment and substitution strategies has been considered to be a 

choice between minimizing short-term or long-term emissions15, although this evaluation 

finds that this does not apply in the case of the F-Gas Regulation (see chapter 5). 

2.3.1 Lack of empirically verified data on emission factors

In order to determine the containment of various measures set out by the F-gas Regulation, 

emission factors in relevant sectors and sub sectors need to be determined and compared to 

emission factors prior to the introduction of these measures. Emission factor reductions in 

the time period since entry into force of the F-gas Regulation in mid 2006 are hard to 

quantify. This section assesses whether the different reporting and monitoring systems for Fgas use and emissions established within EU-27 are suitable to indicate reductions of F-gas 

emissions in recent years. 

By 2008, use-phase emissions accounted for 90% of all emissions; only 10% were disposal 

emissions (source AnaFgas). An assessment of the effectiveness of the F-gas Regulation 

hence needs to ask particularly whether and to which extent reductions of use-phase 

emissions can be empirically verified. It must be pointed out that absolute emissions do not 

only reflect the development of leak tightness but also the development of the underlying 

bank which is influenced by the number of installations, charges, installed shares of 

alternative refrigerants, economic cycle, etc. The appropriate indicator of changing leakage 

rates are changes of emission factors. Different reporting and monitoring systems for F-gas 

use and emissions are assessed with regard to this type of information. 

Data from CRF tables 

EU Member States annually report amounts of F-gases for new products, in the stocks and 

in products at decommissioning as well as the emissions from these to the UNFCCC and the 

European Commission. The common reporting format (CRF) distinguishes six refrigeration 

sub sectors: domestic refrigeration, commercial refrigeration, industrial refrigeration, 

transport refrigeration, stationary air conditioning, and mobile air conditioning. 

 

15 Hekkenberg, M. & Schoot Uiterkamp, A.J.M. 2007: Exploring policy strategies for mitigating HFC 

emissions from refrigeration and air conditioning; International Journal of Greenhouse Gas Control I, 

pp.298-308. 
Chapter 2 Methodology 22 

The F-gas Regulation focuses on stationary systems only rather than transport refrigeration 

and mobile air conditioning. Furthermore the key containment provisions of the F-gas 

Regulation (Article 3) do not apply to stationary equipment containing charges <3 kg. 

Therefore, use-phase emissions from domestic refrigeration, which are already quite low, are 

not likely to decrease further as a result of the Regulation. Commercial and industrial 

refrigeration and stationary air conditioning16 are the main sectors where emission reduction 

might occur and could possibly be identified. 

By April 2011, CRF tables for 2008, the last year reported so far, were available from all 25 

Member States who are obliged to reporting (excluding Malta and Cyprus). This implies that 

reported data only cover the early period of application of the F-gas Regulation. Analysis of 

the national reports does not provide sufficient information in this regard: 10 Member States 

do not report about any of the 3 relevant sectors, another 9 Member States report on only 1 

of the 3 sectors. Data on emissions from industrial refrigeration and air conditioning are 

widely lacking, as well as emissions from refrigerants other than R-134a. CRF tables from 7 

Member States refer to each of the three sectors17 individually and include the reports from 

Austria, Denmark, Estonia, France, Germany, the Netherlands and the UK. Incomplete 

information is, however, not the main reason why the existing CRF tables do not indicate 

possible emission reduction from 2006 onwards. 

The methodology of CRF reporting does not require annual empirical survey, but calculations 

of reported emissions are based on fixed sector-specific emission factors. In most national 

submissions, emission factors have been kept constant since 1995. Some countries have 

updated (mostly lowered) the factors, often based on national studies, but only at intervals of 

several years18, which is not expected in the next few years in most cases. Emission factors 

for the same sectors vary widely between Member States, e.g. in commercial refrigeration 

from 5% to 22%. Hence CRF reporting, in its present state, is not an appropriate tool for 

reliable indication of short-term changes of emissions. 

Data from national F-gas surveys 

In a number of Member States the total national consumption of F-gases is assessed 

annually and usually based on statistics on external trade and domestic chemical production. 

The data are entered in CRF tables as so-called “potential emissions”, in addition to socalled “actual emissions”. These “top-down” data sets are useful tools for a rough plausibility 

 

16 In commercial refrigeration charges <3 kg are also used. Equipment charged <3 kg is even more 

common in stationary air conditioning where moveable and split room air conditioners, and heat 

pumps are charged below the threshold for application of Art 3. The model, developed in this study, 

accounts for these facts but CRF tables do not. Nevertheless, emission estimation for the entire 

sectors makes sense when looking for a possible reduction trend from 2006 onwards. 

17 It must be noted that the Netherlands do not break stationary refrigeration and air conditioning into 

sectors, and do not distinguish between different HFC types. They report only an “unspecified HFC 

mix” in CO2 equivalents. This is done also by UK. Authorities from the Netherlands argue that breaking 

down the number would increase uncertainty significantly taking into account the activity data based 

on which the emission estimates have been assessed. The figures have been verified by the amount 

of refrigerants sold in the Netherlands for the specific sectors. 

18 UK reduces the emission factors for stationary refrigeration and air conditioning every year by the 

same amount, implying a steep decrease in the overall emission factor from 22.6% to 10.6%, between 

1995 and 2008. We do not consider this reduction empirically backed up but based on plausibility 

assumptions of the inventory compilers. The Netherlands have used an emission factor of 5% which 

was established in 1999 and remained unchanged since then. 
Chapter 2 Methodology 23 

check of the bottom up data in the tables. However, the different types of F-gases cannot be 

assigned to particular applications. The F-gas reporting according to Art 6(1) of the F-gas 

Regulation19, which represents a survey of the above mentioned type on an EU wide level, 

tries to compensate this lack of information through the question to producers, importers and 

exporters about the intended application categories. However, the relevant category 

“Refrigeration and Air Conditioning” is too wide to allow emission reduction estimates in the 

sectors that are subject to containment provisions of the F-gas Regulation. 

In a few countries, surveys on refrigerants are carried out. For instance, in France the branch 

association of companies in the refrigerant sector, SNEFCCA, has compiled a complete time 

series of data on the national consumption of R-22 and of the HFC refrigerants R-134a, R404A/507, R-407C and R-410A for the period 2000-2009. As the HFC-blends and R-22 do 

not occur in mobile air conditioning, they can be assigned reliably to refrigeration and 

stationary air conditioning. It must be pointed out that national or EU wide surveys of the 

above mentioned types may be useful in some respects but cannot provide insight in 

emissions directly because they do not distinguish between F-gas use for new equipment 

and use for servicing needs. 

In the following, examples for national surveys are briefly discussed. National empirical 

surveys on the use of HFCs as refrigerants, foam blowing agents and aerosols have been 

carried out in the Netherlands, Germany and Austria for several years. F-gas quantities used 

for new equipment and for servicing are distinguished which allows the allocation of 

particular types of refrigerants to stationary or mobile applications. This type of survey can 

provide insight in emission trends, and could also be used to monitor short-term emission 

reductions in the sectors subject to key containment provisions of the F-gas Regulation. 

Similar monitoring and reporting systems are intended or being established in some Eastern 

European Member States (Bulgaria, Estonia, Hungary, Lithuania and Poland). 

Case: STEK system in the Netherlands

Certified companies, who represent virtually the total number of companies active in the 

refrigeration sector of the Netherlands, report the quantities of HCFC and HFC refrigerants 

used in a year for new tailor-made installations and for refills into existing tailor-made and 

pre-charged equipment to the STEK organisation. It is possible to separate the refrigerants 

for mobile air conditioning so that the refills into stationary refrigeration and air conditioning 

equipment can be calculated (even though the reported refills still include the relatively small 

sector of transport refrigeration and the very small sector of domestic refrigeration). Under 

the generally accepted assumption that refills equate use-phase emissions, a time series of 

the HCFC/HFC emissions from the relevant sectors can be shown for 1998-2007. However, 

further data are not available yet. 

The reports cannot be used to update emission factors because they do not include the 

refrigerant banks. 1999 is the only year when the size of the bank was estimated in a 

comprehensive survey20. Since then, only absolute emissions are surveyed which do not 

differentiate between changes in leakage rates and changes in the refrigerant bank. HCFC 

emissions follow a downward trend, HFC emissions have increased since 2001 (figure 2-3). 

 

19 See also chapter 4.2.7 on reporting requirements. 20 ITM Research, Monitor Koudemiddelenstromen 1999, Amsterdam, May 2001. This important 

document, on which all STEK emission factor estimates since 1999 are based, and which forms the 

general basis for the expected emission reduction effects through the F-gas Regulation, is only 

available in Dutch language. 
Chapter 2 Methodology 24 

Refrigerant emissions in the Netherlands acc to STEK

1999-2007, in kg/a

0

100.000

200.000

300.000

400.000

500.000

600.000

700.000

800.000

900.000

1.000.000

1999 2000 2001 2002 2003 2004 2005 2006 2007

HCFC

HFC

Total 

Figure 2-3: Refrigerant emissions in the Netherlands in 1999-2007. The graph shows the refills 

(=use-phase emissions) for all stationary equipment containing charges >3 kg. HCFC 

emissions (R-22) decreased from 400 t to 200 t, HFC emissions increased from 150 to 300 t in 

the same time. The upper curve displays the overall emissions; its shape reflects changes in 

the bank size much more than in leakage rates21. 

Total refrigerant emissions (HCFCs + HFCs) had increased until 2006, as a result of growing 

banks22, and decreased significantly in 2007. Without data on further years, the decline in 

2007 cannot be considered the beginning of downward trend. Although emission factors are 

not updated in the STEK system a trend in absolute emissions can be seen.23 

The STEK system is suitable to provide data on absolute use-phase emissions over a long 

time in the sectors subject to key containment measures of the F-gas Regulation. However, 

the Dutch emission figures ironically cannot be used as indicators of the effect of the F-gas 

Regulation. Containment measures of the STEK system and the F-gas Regulation are 

largely identical, which implies that the Netherlands have been subject to them not as 

recently as 2006 but for much longer. A decline in F-gas emissions after 2006 would not 

indicate effects of the F-gas Regulation but relate to other influencing factors. 

Case: National F-gas survey in Germany

In 2006, a comprehensive and legally binding annual survey of the F-gas use in all industrial 

sectors (approx. 50) was introduced in Germany24 and is carried out by the Federal Board of 

 

21 In the data analysis by STEK for Öko-Recherche “Emissions in the Netherlands - based on STEK 

figures, Baarn, 20 May 2010” the trend is explained by “smaller volume per installation, more newly 

pre-charged installations, introduction of alternative refrigerants (instead of F-gases)”. 

22 See footnote before, and communication of Dan De Bruyckere (STEK) to Öko-Recherche, Brussels, 

4 May 2010 and 18 January 2011. 

23 In the Netherlands, figures from the STEK foundation have only been used for verification of the 

emissions calculated under UNFCCC for some years and are not part of the QA/QC of the national 

inventory. Also the STEK information is based on assumptions of the installed base (as well as the 

CRF data, based on the NOKS study of 1999/2000). However it appears according to the authorities 

from the Netherland that the outcomes of the different data sources have been following similar trends 

during the past period. 

24 Law on Environmental Statistics (Umweltstatistikgesetz) of 16 August 2005. 
Chapter 2 Methodology 25 

Statistics. The questionnaire on HFCs/PFCs distinguishes between refrigerants, foam 

blowing agents, aerosols, and other, and classifies the refrigerant use by first fill into new 

equipment, first fill in converted equipment and by refill in existing equipment. Data analyses 

allow separating mobile applications from stationary applications so that use-phase 

emissions from stationary refrigeration and air conditioning can be analysed by individual 

HFC and PFC types. 

Like the STEK system, the German statistics do not allow an assessment of the size of the 

banks, which would be needed to establish emission factors and could be used to indicate 

effects of containment measures. Furthermore, the German data focus on F-gases. The time 

series 2006-2009 shows a clear increase of absolute emissions of HFC refrigerants from 

985 t (2006) to 1,049 t (2007), to 1,103 t (2008), and to 1,221 t (2009)25. This trend, however, 

does not reflect higher leakage rates or growing banks but first of all the replacement of R-22 

by HFCs in the banks. A trend in containment cannot be identified since R-22 is not 

monitored. Once no R-22 equipment is covered by the reporting any more, the underlying 

approach could be used to estimate the trend in absolute use-phase emissions and effects of 

the F-gas Regulation. This could be possible for the reporting years from 2014 onwards. 

Case: F-gas reporting system in Austria 

The Austrian Ordinance on HFCs, PFCs and SF6 requires companies who manufacture, 

maintain and service stationary refrigeration and air conditioning equipment and other 

sectors (foams, aerosols, solvents, fire protection, high-voltage switchgear, manufacturing of 

electronics) to report annually used HFC and PFC quantities to the competent ministry since 

2003. The reporting includes quantities for new fill and re-fill and disposal, and is basically 

suited to monitor emission trends over time. 

Like the German survey, the Austrian reporting system does not provide data on refrigerant 

banks and hence does not allow empirical calculation of emission factors. Furthermore, the 

Austrian system does not cover HCFCs, which impedes realistic estimation of emission 

factors. The main problem related to the Austrian reporting system, however, is the low level 

of compliance. The share of companies in the stationary refrigeration and air conditioning 

sector who do report is estimated to range at 30% at maximum and has been steadily 

decreasing since 2003. The data of submitted company reports cannot be considered 

representative because the share of their F-gas quantities in the total F-gas quantities can 

only be estimated roughly. 

Case: New monitoring and reporting systems in Eastern European Member States

Some new Member States who entered the EU since 2004 are currently establishing or 

planning F-gas monitoring and reporting systems which allow calculation of emission rates 

based on empirical data. The systems shall primarily build a link to national F-gas emission 

inventories according to Article 6(4) of the F-gas Regulation26. The key component of these 

systems is a central database of all stationary refrigeration and air conditioning equipment 

with charges >3 kg, which allows determination of the refrigerant bank. Annual use of Fgases and ODS are to be reported to the database by operators and service companies, as 

 

25 By far mostly used refrigerants in the stationary sectors are R-404A/507, R-134a, R-407C, and R410A, with together 97% share in the total. 

26 Article 6(4) requires Member States “to establish reporting systems for the relevant sectors referred 

to in the F-gas Regulation, with the objective of acquiring, to the extent possible, emission data”. 
Chapter 2 Methodology 26 

well as the quantities for recovery, recycling, reclamation and destruction. Such systems are 

planned or being established in Bulgaria, Estonia, Hungary, Lithuania and Poland. 

The most ambitious monitoring system for the refrigeration and air conditioning sectors exists 

in Hungary: It is being established since 2009 and is operated by the Hungarian Monitoring 

and Certification Body (HMCB). The renewal of company certification by HMCB is conditional 

upon reporting. By mid-2010 about 70% of the companies concerned had reported for the 

previous year. Over 21,000 refrigeration circuits >3 kg are registered in the electronic data 

base and it is intended to extent the database to all types of mobile AC systems. Electric 

switchgear and fire protection systems are not covered. 

HMCB recently presented an evaluation of the leakage rates of 11,000 refrigeration 

systems27 (table 2-3). The average leakage rate in 2009 amounted to 10% for stationary 

refrigeration and air conditioning equipment >3 kg. A time series which could reliably 

establish a real trend in leakage rates would require datasets for additional years. The new 

Hungarian monitoring systems can indicate the development of leakage rates caused by the 

F-gas Regulation over time. However, verification of an impact of the Regulation on general 

leak tightness would be expected to be possible only a couple of years later. 

Table 2-3: Installed F-gas refrigerant banks and leakage rates in 11,000 refrigeration systems 

>3 kg in Hungary 2009. Source: HMCB, September 2010 

 Refrigerant bank /kg Leaked /kg leakage rate /% 

 R-134a 45,807.5 2,108.0 4.6 

 R-404A 194,998.1 21,023.1 10.78 

 R-407C 68,221.5 8,016.1 11.75 

 R-410A 10,303.8 468.0 4.54 

 R-413A 116.1 8.0 6.89 

 R-507 216.0 20.0 9.26 

 Others 169.9 255.4 150.0 

 Total 319,833 31,898.5 10.0 

The new monitoring systems are not only appropriate to support national CRF reporting but 

are also appropriate to verify possible containment effects of the F-gas Regulation in the next 

years. It is essential that the systems include a comprehensive database of the F-gas bank 

contained in operating refrigeration equipment (charges >3 kg). 

Data from selected installations 

Currently estimates of the trends of emission factors in stationary refrigeration and air 

conditioning seem to be possible on sub-national level only. At present, data on banks and 

emissions exist for individual installations only. These data are based on the recording of 

refrigerant charges, added and recovered refrigerant quantities according to Article 3(6) of 

the F-gas Regulation28. The introduction of recording in most Member States has taken some 

 

27 Zoltán Attila (Hungarian Monitoring and Certification Body: Országos Monitoring és Képesítö 

Testület), Fgas Certification and Monitoring. Implementation of the ODS and FGG regulations in 

Hungary. ECOCOOL'10, Budapest 16/09/2010. 

28 Recording requirements of Article 3(6) follow the approach of the STEK system in the Netherlands. 

Records (“logbooks”) are obligatory there since 1994, first for ODS, and later also for F-gases. This 

also applies to Sweden, where records must be kept since the 1990s, not only for stationary but also 

for mobile equipment with refrigerant charges >3 kg (refrigerated vehicles and air conditioned buses). 
Chapter 2 Methodology 27 

time to become established. In early 2010, about half of the operators in EU-27 did not 

maintain records as required. Large differences between geographic regions and between 

large and small operators need to be noted (see chapter 4). 

The records can also serve as information basis for the monitoring of emissions and the 

calculation of emission factors on the basis of empirical data. National legislation planned or 

in force in certain Member States requires operators of equipment (F-gas charges >3 kg) to 

report to authorities which run centralized equipment registers (e.g. Poland, Hungary as 

described above). However, this is not the case in all Member States. It should be noted that 

such centralized systems are not supported by all Member States due to the high 

administrative efforts for establishment of such databases and input of data, which 

sometimes are not electronically available. 

Hence the main obstacle to the use of records as monitoring instrument for emission factors 

is not only their limited dissemination and the slow pace of their introduction, but the 

significant amount of time and effort needed for their evaluation. Few assessments of 

records have been undertaken to date29,30 as the workload for the analysis of handwritten 

records is high. In contrast, evaluation of electronic records is much easier. However, even in 

case of identical software programmes for all users (contractors, operators, etc.), records are 

not kept in central databases. Data delivery for research purposes is voluntary apart from 

exceptions in the Member States mentioned above, and service companies and operators 

are often found to be reluctant to release data for centralized analysis for confidentiality 

reasons. 

The difficulties related to central evaluation of records from individual installations are 

illustrated by an example from Germany: The Association of German Refrigeration and Air 

Conditioning Companies (VDKF) developed the recording software „VDKF-LEC Leakage & 

Energy Control” in 2004/2005, and requested the German service companies to apply the 

tool for all upcoming European and national reporting and monitoring requirements. At the 

end of 2008, about 700 of the 2,100 contractors were licensed users of the programme. The 

first data evaluation for refrigerant banks and emissions could be carried out in 2008, on the 

basis of only 31 companies who had made their 2006 data available to the VDKF31. By 2010, 

the number of users has grown to more than 840 (including some operators of large 

facilities). However, no further evaluation has been performed due to a lack of awareness of 

 

Record keeping for mobile refrigeration and air conditioning systems is also mandatory in the 

Netherlands under the STEK system. 

29 In the Netherlands the only assessment of logbooks in the history of STEK dates back to 

1999/2000: ITM Research, op. cit. Contrary to common opinion this study is mainly based on 

questionnaires, not on records (“logbooks”) of individual installations. Logbooks had been used 

complementarily only. “In many cases it was not the questionnaire but a copy of the log book that was 

sent back. Contrary to what we had expected, the log books turned out to be in many different 

formats. In cases where there was uncertainty about the data to fill in, contact was sought with the 

respondent” (Translation for this study by Jason Anderson). 

30 Assessment of records in Sweden: For a study for the European Commission, Öko-Recherche 

analysed in 2006 ca. 2,000 report forms on inspections of mobile air conditioners of 309 buses and 

coaches in a specialised garage in South-East Sweden during the period 1996-2005. The evaluation 

took 3 months time of two researchers. See: Establishment of Leakage Rates of Mobile Air 

Conditioners in Heavy Duty Vehicles, Part 2 Buses and Coaches (ENV.C.1/SER/2005/0091r), 

prepared for DG Environment), January 2007. 

31 The results are published in the technical journal DIE KÄLTE + Klimatechnik, 11/2008. Bank 58,488 

kg; refills: 1,980 kg; average leakage rate 3.4%. 
Chapter 2 Methodology 28 

operators and contractors for such analyses, and concerns about confidentiality32, even if 

data were used in encoded form, and the additional work necessary for the assessment. 

Despite confidentiality concerns, two Austrian companies active in the servicing of 

supermarket refrigeration and AC systems and one large German industrial company made 

data available to the project team in the context of this work, which allow compilation of time 

series. 

Case: Supermarket systems 1

Banks and use of HFCs for refill are shown in table 2-4 for the period 2005-2010. The time 

series of the emission factor (bottom line) shows a downward trend until 2007. The refill rate 

increased again in 2008 and declined in 2010. 2009 data have not been available (ITproblems, data loss). One of the reasons for the peak refills in 2008 was total refrigerant loss 

of one installation (R-404A). 

Table 2-4: Refrigerant banks and refills of an Austrian service company for supermarkets, 

2005-2010, in kg33 

2005 2006 2007 2008 2010 

No of supermarkets 56 56 50 44 41 

 bank refill bank refill bank refill bank refill bank refill 

R-22 2,190 31 2,190 192 1,460 148 876 285 584 10 

R-134a 292 15 292 1.5 146 1.5 146 16 146 2 

R-404A 528 185 528 30 528 41 528 301 

R-507 6,336 1,467 6,336 1,339 6,336 1,073 5,984 1,209 

6160 767 

R422D - - - - - - - - 146 66 

Total 9,346 1,698 9,346 1,563 8,470 1,264 7,534 1,811 7,036 845 

EF total 18.2% 16.7% 14.9% 24.0%. 12,0% 

Aside the 2008 values, which are the highest in the 6-years-period, the time series shows a 

certain decrease in emission factors, from 18.2% to 12.0%. The sample, however, is rather 

small and limited to one servicing company. Therefore, the trend cannot yet be extrapolated 

to all EU-27. The example illustrates that such time series should be longer and need to be 

based on a larger number of installations. 

Case: Supermarket systems 2

Another international service company provided data on leakage rates (refill rates) from over 

1,100 discount markets, supermarkets and hypermarkets with a total bank of ca. 201 t of 

HFCs and HCFCs. Data from 2004 and 2009 could be compared. The leakage rates (i.e. 

refill for loss of refrigerant during use, including accidents) of one quarter of the installed 

stock (new systems) were reduced by almost 50% through technical measures and regular 

leakage control measures like those prescribed in Article 3 of the F-gas Regulation. 

 

32 Communication of Volker Hudetz from VDKF (Bonn, Germany) submitted on 27 August 2010. 33 The sample includes only equipment that has been serviced over all six years. Therefore the total 

decreases by retired installations. In 2007, 5 R-22 and 1 R-134a installations were decommissioned; 

in 2008, 4 R-22 systems and 2 R-507 systems, and in 2010 2 R-22 installations and 1 R-507 

installation. In 2010 1 system was converted from R-22 to R422D. Data for 2009 has not been 

available. The name of the company is not disclosed (confidential information). 
Chapter 2 Methodology 29 

Table 2-5: Refrigerant banks and refills of an international operating service company for 

supermarkets, 2004-2009, in kg 

Number of Refill rate (%) 

systems 

Average 

charge/system 

(kg) All systems in 

2004 

All systems in 

2009 

New systems 

(25% of all 

systems) 2009 

1,124 179 17.9 15.3 7.7 

The name of the company is not disclosed (confidential information). 

Emission rates of the total stock (old and new systems) were reduced from 17.9% (2004) to 

15.3% (2009). However, emission reductions result only from decreasing emission factors (-

50%) of new systems while emissions from old equipment have not been lowered, so far. 

Assuming systems lifetime of 10-12 years, emission factors of the total equipment stock 

might be reduced by 50% in 2015. 

Case: Refrigeration and air conditioning systems in a large industry group

A large international industry group systematically collects data from refrigeration and air 

conditioning equipment containing charges from <3 kg to >300 kg. In 2008, more than 1,200 

systems containing HCFC and HFC refrigerants were included and in 2010 the system had 

been expanded to more than 1,500 systems (+23%). Refrigerant losses (quantities refilled) 

decreased from 2008 to 2009 by almost 50% and increased again in 2010 to 190% of the 

quantity in 2008. Although the systems are well maintained and provisions of the F-gas 

Regulation are fully applied, these data show no trend. The time series are too short to draw 

serious conclusions. 

2.3.2 Assumptions on emission factors in AnaFgas

The lack of empirically verified data on emission factors, which are sufficiently long, leads to 

the need for expert assumptions on changes of emission factors subsequent to the 

introduction of the F-gas Regulation. In the model AnaFgas, the following assumptions on 

impacts of provisions of different measures have been established for the WM scenario, 

which the application of the measures of the F-gas Regulation. 

Containment measures according to Article 3: For stationary refrigeration, stationary air 

conditioning, fire protection systems and electrical switchgear containing charges >3 kg, it is 

assumed that containment measures carried out by certified personnel (Article 3) lead to a 

stepwise decrease in the use-phase emission factors by 40% in total during the period 2010 

to 2015. From 2015 onwards, the emission factor is kept constant until 2050. 

This reduction of the emission factor is not validated by empirical data but constitutes an 

estimate for possible emission reductions if the F-gas Regulation will be fully applied in EU27. The estimate of a decrease of emission factors by 40% is based on reports referring to 

the Dutch STEK system, which is the model behind the key containment provisions of the Fgas Regulation with regard to the stationary refrigeration and AC sector. These assumptions 

about decreasing emission factors have also been used in a preparatory study for the 
Chapter 2 Methodology 30 

European Commission in 200334. It is reported that the measures set out by STEK have cut 

the annual leakage rate in the Netherlands from more than 11% to less than 5% within 5 

years in this sector. The IPCC/TEAP SROC Report assumes a similar reduction potential in 

2015 in the mitigation scenario. 

Moreover, the assumed 40% decrease of the use-phase emission factor does not account 

for the different extent of containment activities carried out in certain sectors prior to the Fgas Regulation. The actual increase in containment activities varies between sectors. 

Recovery measures according to Article 4 (1): For all types of equipment covered by 

Article 4(1) on recovery by certified personnel, it is assumed that recovery efficiency 

increases. Disposal emission factors in stationary refrigeration and air conditioning are 

estimated to stepwise decrease by ca. 33% in high-charged equipment and by 50% in small 

systems, from 2010 to 2015. From 2015 onwards, the reduced emission factor is kept 

constant until 2050. 

This reduction of the emission factor is not validated by empirical data either, but needs to be 

considered an estimate for possible emission reductions if the F-gas Regulation will be fully 

applied. It should be noted that information on recovery, recycling, reclamation and 

destruction of F-gases and/or equipment containing F-gases is available to very limited 

extent in most Member States and for EU-27. 

 

34 Enviros, 2003: Assessment of the Costs & Impact on Emissions of Potential Regulatory 

Frameworks for Reducing Emissions of HFCs, PFCs & SF6, report on behalf of the European 

Commission. 
Chapter 2 Methodology 31 

2.4 Emission factors used in this report 

Emission factors are essential for the quantitative assessment of emissions both in the 

counterfactual scenario (WOM) and in the scenario including measures of the F-gas 

Regulation and the MAC Directive (WM scenario). All emission factors used in the model 

AnaFgas are presented in overview tables (table 2-6 and 2-7). 

Table 2-6 presents the emission factors applied to stationary refrigeration, air conditioning 

and heat pumps and to mobile air conditioning in the WOM and WM scenario of AnaFgas. 

Table 2-7 shows the emission factors in the other F-gas sectors. 

In both tables the model emission factors are compared with the relevant recommendations 

of the IPCC Guidelines for National Greenhouse Gas Inventories 2006, in the column on the 

right. In addition, table 2-6 shows use-phase emission factors for the two global consumption 

scenarios. Disposal emission factors are not considered there because disposal is not 

relevant when modelling consumption which includes first fill and refill only. 

In the foam sector, use-phase emission factors are also not relevant for the global scenario 

because emissions from foam are not refilled. 
Chapter 2 Methodology 32 

Table 2-6: Emission Factors for refrigerants [%] in WOM and WM scenario (AnaFgas) for 

Europe compared with the two global scenarios of this study (chapter 7) and the IPCC 2006 

Guidelines. (Empty cells in the WM scenario mean no change vs. WOM scenario. Empty cells in 

other columns indicate that there is no emission factor available.) 

Refrigeration, 

AC and heat 

pump sub 

sectors 

Type of 

emission factor 

EU 

WOM 

scenario 

and WM 

scenario 

pre-2010 

EU 

WM 

scenario 

post-2015 

Global 

consumption 

scenarios 

(A2) 

IPCC 

GL 2006 

Domestic Lifetime factor 0.3 (default) 0.3 0.3 0.1-0.5 

Refrigeration Disposal factor 40 30 30-100 

Lifetime factor 10 6 8 

food industry 9 5.4 8 

other industry 12 7.2 8 7-25 

Industrial 

Refrigeration 

Disposal factor 30 20 10-100 

Lifetime factor 

Centralised systems 15 9 15 10-35 

Condensing units 10 6 10 [10-35] 

Stand-alone; hermetics 1 1 1 1-15 

Disposal factor 

Centralized systems 30 20 30-100 

Condensing units 50 25 30-100 

Commercial 

Refrigeration

Stand-alone; hermetics 70 35 30-100 

Lifetime factor 

 Trucks, Trailers 20 20 15-50 

 Vans 30 15-50 

Transport 

Refrigeration 

Disposal factor 30 30-100 

Lifetime factor 40 Fishing vessels Disposal factor 30 

Lifetime factor 3.5 3.5 5 1-10 Heat Pumps Disposal factor 70 35 20-100 

Lifetime factor 3 3 5 1-10 Moveable AC Disposal factor 70 35 20-100 

Lifetime factor 5 5 5 1-10 Split AC Disposal factor 70 35 20-100 

Lifetime factor 8 5.6 8 1-10 Multi-split AC Disposal factor 30 20 20-100 

Lifetime factor 5 3 5 1-10 Rooftop AC Disposal factor 30 20 20-100 

Chillers (incl. Lifetime factor 4 2.4 5 2-15 

centrifugal) Disposal factor 30 20 5-100 

Passenger Car Lifetime factor 10 10 10-20 

AC Disposal factor 70 50-100 

Lifetime factor 10/15 10-20 Truck AC Disposal factor 70 50-100 

Lifetime factor 15 15 10-20 Bus AC Disposal factor 30 50-100 

Lifetime factor 7 Rail AC Disposal factor 30 

Lifetime factor 40 Ship AC Disposal factor 30 
Chapter 2 Methodology 33 

Table 2-7: Emission Factors in other sectors in the WOM and WM scenario of the model 

AnaFgas compared with IPCC 2006 Guidelines. (Empty cells in the WM scenario mean no 

change vs. WOM.) 

Sub sectors 

Type of 

emission factor 

EU 

WOM scenario 

and WM 

scenario pre2010 

EU 

WM 

scenario 

post-2015 

IPCC 

GL 2006 

OCF Lifetime factor 100 100 95-2.5-2.5 

Manufacturing 152a 100 50-25-25 

XPS Manufacturing 134a 30 25 

Lifetime factor 134a 0.75 0.75 

Manufacturing 134a 10 10 (tier 1) 

Manufacturing 

245fa/365mfc 

10/15 4-15 

Lifetime factor 134a 4.5 4.5 (tier 1) PU rigid 

Lifetime factor 

245fa/365mfc 

1/1.5 0.25-1.5 

PU integral skin Manufacturing 100 95-2.5-2.5 

Aerosols, Solvents Lifetime factor 100 100 50-50 

Lifetime factor 

227ea/23 

2.5 2.3 1-3 

Lifetime factor 236 

(portable) 

>5 4 2-6 Fire extinguishers 

Disposal factor 10 9 

Manufacturing 5 5 7/8.5 

Switch gear Lifetime factor 1 0.7 0.2/2.6 

Disposal factor 5 1.5 

Manufacturing 33 33 33 

Soundproof glazing Lifetime factor 1 1 1 

Disposal factor 100 100 100 

Shoe soles, Car tyres Disposal factor 100 100 100 

Aluminium smelting Manufacturing 1.5 

Magnesium casting Manufacturing 100 5.4 (134a/SF6) 100 

Photovoltaic Manufacturing 4 4 
Chapter 2 Methodology 34 

2.5 Identification of policy options 

Policy options for further international and EU action to reduce F-gas emissions are 

assessed in chapters 7 and 8. The impact of certain policy options on F-gas use and 

emissions is calculated in the WAM scenario for EU-27, based on the model AnaFgas, and 

the two global scenarios, based on assessment of sector experts, described in section 2.2. 

2.5.1 Policy options at international level

Under the Montreal Protocol, it is currently discussed on how to link the work on HFCs done 

under the Kyoto and post-Kyoto regime and further phase out of ODS more closely. 

Two proposals for an amendment of the Montreal Protocol in this respect have been 

resubmitted in 2011, one by the Federated States of Micronesia and one by the Northern 

American countries USA, Canada and Mexico. Both proposals suggest control of production 

and consumption of HFCs. These proposals are presented in chapter 7 of this report. 

Elements for further action at international level to reduce F-gas emissions focus on HFC 

phase down scenarios. 

2.5.2 Policy options in EU-27 

The identification of policy options for further EU action addressing emissions of fluorinated 

greenhouse gases is based on the modelling work and the assessment of the projected 

effectiveness of the F-gas Regulation and includes the options listed in Article 10. 

The scenario integrating all measures introduced by the MAC Directive and the F-gas 

Regulation (WM) reflects the current situation and illustrates the F-Gas emission 

development under option A of this report (no policy action, see chapter 8). 

The options identified finally lead to a third scenario with additional measures (WAM) 

addressing future F-gas emissions. The development of emissions in this third scenario 

depends on the choice of policy options (see chapter 8). 
Chapter 3 F-gas markets and policies 35 

3. F-gas markets and policies 

3.1 Global and European F-gas markets 

3.1.1 Montreal Protocol as main driver of growing use of HFCs 

Control of production and consumption of fully halogenated ozone-depleting substances 

(CFCs) under the Montreal Protocol started in the early 1990s. Subsequently, the chemical 

industry in the USA, Western Europe and Japan invested in large scale in the production of 

HFC-134a (GWP 1,430; ODP 0) as the main replacement for CFC-12 (GWP 10,900; ODP 

1), which had been the most important CFC for decades. 

The relevant market for HFC-134a was and still is the mobile air conditioning sector and to 

smaller extent refrigeration, while large parts of the refrigeration sector and the stationary air 

conditioning sectors have been relying on HCFCs (R22). The three main sectors using 

refrigerants, i.e. refrigeration, mobile and stationary air conditioning, currently use 

approximately two thirds of the global annual HFC/HCFC-production at almost equal parts. 

HFC-134a successfully replaced ODS also in medical and technical aerosols, and later-on in 

XPS foam blowing. In the early 1990s, further HFC species came to the market as 

replacements for fully halogenated ODS. These included HFC-227ea and HFC-236fa, which 

were introduced as substitutes for halons in fire protection equipment, and HFC-43-10mee 

as alternative to CFC-113 in solvents applications. The market potential of these HFC 

species was of limited size, since the sectors of fire protection, solvents, aerosols and to less 

extent the foam sector35, which accounted for half of the ODS production in the 1980s, did 

not experience a similar transition to HFCs, but mostly conversion to hydrocarbons or not-inkind technologies. Overall, the market for HFCs does not match the former size of the ODS 

market. 

The only field of ODS application with a high replacement rate (relation of HFCs to former 

ODS) turned out to be the refrigeration and air conditioning sectors. This was partly due to 

the fact that most halocarbons, which are fluorinated gases with and without chlorine in the 

molecule, are not flammable like hydrocarbons or ammonia. Nevertheless, the sub sector of 

domestic refrigeration gradually changed to hydrocarbons, first in Europe and subsequently 

at international level. 

3.1.2 HCFC phase-out drives use of HFC refrigerant blends 

A couple of years after the decision to fully phase-out halogenated ODS a new decision was 

taken to also control and phase out HCFCs under the Montreal Protocol. As pure HFC 

species could not reach the refrigeration performance of R22, blends containing two or three 

of the HFC types HFC-32, HFC-125, or HFC-143a, i.e. R407C, R404A, or R507 were offered 

as HCFC substitutes. Some years later another blend, R410A, came to the market. However 

the phase out schedule allowed developed countries more than 15 years to continue the use 

of HCFCs, and developing countries over 35 years (2030). This schedule is the main reason 

 

35 In the polyurethane foam sector; introduction of HFC blowing agents substituting the prevailing 

HCFC-141b took a longer time than the introduction of the R-22 replacing refrigerants. HFC-245fa and 

HFC-365mfc started production first after 2000, when the advanced HCFC prohibition in Europe had 

already entered into force. 
Chapter 3 F-gas markets and policies 36 

why the new HFC based refrigerant mixtures soon brought to the market as HCFC 

replacements did not gain substantial market shares for a long time. 

Sales of HFC refrigerant blends and thus the production of HFC-125, HFC-143a, and HFC32 have significantly increased from 2000 onwards, first in Europe, then in Japan, and with 

some delay in the remaining industrialised countries including the USA. Since 2005, growth 

in HFC production of the Western and Japanese chemical companies has mainly been 

driven by refrigerant blends which have already exceeded the decrease in the HCFC-22 

refrigerants36. In this study it is estimated that the global demand for HFC-32 and HFC-125 

will soon exceed the demand for HFC-134a. 

3.1.3 Strong increase of HFC production in developing countries

Two global trends have strongly influenced current HFC markets are expected to continue 

doing so in the future under business-as-usual: 

(1) Strong growth in use of refrigerant blends and small growth in use of HFC-134a; 

(2) Slight increase in HFC production in developed countries and strong increase in 

developing countries, mainly in Asia where growing demand for HFCs is projected. 

Production of HFC-134a by Western and Japanese chemical companies, which had steadily 

been increasing since 1991, stopped growing in 2004 and had been decreasing until 2009 

(see table 3-1). 

In 2009, AFEAS37 stopped collecting data on halocarbon production explaining that the 

member companies “accounted for less than half of global sales”. The interpretation of 

industry experts is that developing countries, primarily China, started and quickly increased 

domestic production of HFC-134a38 not only to cater for domestic demand but also for the 

world market. China, which is today by far the largest producer of HCFCs, will presumably 

gain world market leadership also in HFC blend components, primarily because of the high 

demand for HFC blends by the stationary air conditioning sector. 

Table 3-1 illustrates three different aspects of the halocarbon production of the Western and 

Japanese manufacturers. 

- First, HFC-134a production decreases from 2004, after continuous growth from 1995. 

- Second, production of HCFC-22 dropped by 40%, beginning in 1999/2000 (left 

column). 

- Third, the decrease in HCFC-22 was counteracted by additional production of the 

refrigerant blend components HFC-125 and HFC-143a. 

Together with HFC-32, (data is not included in the table for confidentiality purposes), the 

growth of HFCs for blends exceeded the decline of HCFC-22 completely. In contrast, the 

sharp drop in HCFC-141b, which serves as a PU foam blowing agent, is not at all 

compensated by HFCs (HFC-245fa and HFC-365mfc) (not shown for confidentiality 

reasons). 

 

36 In contrast, the sharp drop in HCFC-141b is not offset by new HFCs (HFC-245fa and HFC-365mfc). 37 AFEAS is an organisation of Western and Japanese Chemical companies. 38 The present production numbers are not known outside of China. Expert estimates range from 

20,000 to 100,000 metric tons per year. 
Chapter 3 F-gas markets and policies 37 

Table 3-1: Global annual production reported by AFEAS companies* (metric tons). Source: 

AFEAS 2009. Data does not include China and India. 

HCFC-22 HCFC-141b HFC-134a HFC-125 HFC-143a

1995 243,468 113,154 73,769 

1996 267,523 121,085 83,674 0 794 

1997 246,937 122,356 97,949 296 339 

1998 271,980 129,037 112,174 698 557 

1999 248,552 130,415 131,710 1,243 750 

2000 239,197 132,476 130,056 7,400 5,396 

2001 213,328 121,757 133,956 12,583 9,151 

2002 193,955 116,673 156,987 16,190 9,656 

2003 187,262 74,596 166,899 22,631 12,972 

2004 189,545 40,417 173,851 32,734 14,053 

2005 176,373 25,619 169,999 31,819 16,321 

2006 165,478 22,548 156,573 38,537 16,257 

2007 165,862 21,835 158,161 42,573 18,325 

* Note that data on HFC-32 are not published. In our estimate, the trend of is similar to that of HFC143a, which means considerably growing. 

Figure 3-1 illustrates the historic development of the global halocarbon market (fluorinated 

gases with and without chlorine) over 40 years and includes also a projection established by 

the project team until 2030, which shows a downward trend for HCFCs and CFCs since the 

end of the 1990s. From 2000 onwards, the growth of HFCs is strongly supported by 

components for refrigerant blends substituting HCFC-22, while the global market of HFC134a is projected to grow only slowly. 

The pie charts below figure 3-1 illustrate the changes of end-use applications of halocarbons. 

While refrigerants, foam blowing agents, aerosol propellants and solvents were consumed at 

almost equal parts during the 1980s, refrigerants account for three quarters of the worldwide 

production and sales at present and most likely also in the future. 
Chapter 3 F-gas markets and policies 38 

Figure 3-1: Global market for halocarbons including ozone-depleting gases like CFCs and 

HCFCs from 1970 to 2030 (incl. own forecast). After 1990, CFCs show rapid decline, not fully 

replaced by HCFCs. From 2000, HFCs replace HCFCs and will grow continuously until 2030. 

From 2004 onwards, the increase in HFC sales is no longer driven by HFC-134a but by those 

HFCs that form R-22 substituting refrigerant blends, primarily HFC-32 and HFC-125. Over the 

five decades, refrigerants have become the most important application of halocarbons. The 

quantities are presented in metric tons, which makes the trend clearer than CO2 equivalents. 

Source: AFEAS until 2006, 2030 projection by Öko-Recherche. 

The shift between the halocarbon species from CFCs to HFC blend components is one 

important trend. The second main trend, the structural market shift from developed countries 

to developing countries, is illustrated in the next graph (figure 3-2) which presents a 

projection elaborated within this project for the halocarbon demand by A2 (developed 

countries) and A5 countries (developing countries) until 2030 (detailed information on these 

projections are included in chapter 7). 
Chapter 3 F-gas markets and policies 39 

Global HCFC and HFC consumption 

in a BAU scenario in 2010-2030

0

500

1,000

1,500

2,000

2,500

2010 2015 2020 2025 2030

metric kilotonnes

HCFC A2 HFC A2 HCFC A5 HFC A5

Figure 3-2: Business-as-usual projection of the global sales (metric kilo tonnes; kt) of HFCs 

and HCFCs until 2030 by the authors of this study. While demand and sales of HFCs grow 

moderately in developed countries (A2), demand and sales will rise steeply in developing 

countries (A5). 

In this business as usual scenario, the global demand will more than double over the next 

twenty years, from 800 kilo tonnes (2010) to 1,300 kilo tonnes (2020) and even 2,000 kilo 

tonnes (2030)39. The market growth in A2 countries is slow as markets are being saturated 

widely. The global increase will almost completely be driven by A5 countries as of 2020. 

Quantitative demand for HFCs in A5 countries will by far exceed the demand of A2 countries 

in 2030. This development will be the result of overall population and economic growth, 

expressed through a strong demand for refrigeration and stationary air conditioning 

applications. 

3.1.4 Slow market growth in developed countries: F-gas demand in EU-27

Since F-gases were included in the basket of greenhouse gases covered by the Kyoto 

Protocol in 1997, measures to improve containment, leak tightness and recovery have 

gained importance, and alternative fluids and not-in-kind technologies are increasingly 

discussed, developed and applied. 

• Higher awareness of personnel and technical or regulatory measures improve leak 

tightness of equipment, and contribute to reduction of operating emissions. E. g. the 

 

39 For details see chapter 7 of this report. 
Chapter 3 F-gas markets and policies 40 

EU legislative framework addressing F-gases from 2006 requires strict containment 

measures. This decreases demand from the aftermarket. 

• Recovery at end-of-life shows first signs of progress. 

• Hydrocarbons, ammonia and CO2 (subcritical and transcritical use) are penetrating 

into the sectors of refrigeration and, in part, stationary air conditioning. 

• Several European countries impede the use of F-gases through regulatory and fiscal 

measures40; e.g. the EU legislative framework addressing F-gases from 2006 

eventually bans the use of HFC-134a in the large sector of mobile air conditioning of 

passenger cars. 

These measures show impact upon the future demand for F-gases, in particular HFCs. After 

successful implementation of the HCFC-phase-out, there are signs that the growth in 

demand for HFCs slows down. 

Table 3-2: Sales41 of F-gases (metric tonnes) by F-gas types in EU-27 in 2007-2010 based on 

reported data (Art 6 of the F-gas Regulation) 

Sectors 2007 2008 2009 2010 

 t t t t 

HFC-134a 51,693 48,123 42,005 45,373 

HFC-32 4,186 5,545 4,328 5,408 

HFC-125 12,933 15,427 13,438 18,308 

HFC-143a 9,605 10,487 8,940 10,118 

HFC-152a 4,301 2,782 5,182 6,213 

HFC-227ea 0,857 2,336 2,075 2,199 

HFC-365mfc n.r. 3,785 3,054 3,554 

SF6 2,223 3,011 1,928 1,851 

- thereof to electrical equip. 1,568 2,386 1,284 1,614 

Other 7,338 2,547 4,164 4,645 

Total sales 93,127 94,043 85,114 97,669 

Note: F-gas quantities in pre-charged equipment are not included here, but are discussed in chapters 

4 and 8. 

Table 3-2 shows a slight increase in total F-gas sales from 2007 to 2008, and a sharp decline 

of 10% in 2009. The severe drop in 2009 is clearly a result of the economic crisis in that year, 

because in 2010 the total sales increased again, to a level which is 5% higher than in 2007. 

Looking at the sales of HFC-134a only which is by far the most important single F-gas type, 

representing more than half of the F-gas market, one can see that the demand declined 

more sharply than the total F-gas demand in the period 2007-2009, and the re-rise in 2010 

was lower than that of most other HFCs. From 2007 to 2010 the sales reduction was 12%. In 

contrast, sales of the blend components HFC-32, HFC-125, and HFC-143a strongly 

increased in the same period of time by 26% and over compensated the reduction in sales of 

HFC-134a. 

 

40 See chapter 3.2. 41 Sales include only F-gases in containers or cylinders (bulk quantities). Import in prefilled equipment 

like stationary air conditioners is excluded even though they significantly contribute to emissions in 

Europe (see chapter 2). Source: 2007-2009: http://ec.europa.eu/clima/studies/fgas/docs/statistical_factsheet_2010_en.pdf. Data for 2010 are preliminary, subject to validation. 
Chapter 3 F-gas markets and policies 41 

The demand for other F-gases like HFC-227a (fire protection) and HFC-365mfc (PU foam) is 

stable, while sales of HFC-152a (XPS insulation foam) are rising. SF6 is the only F-gas with a 

clear down trend; the sales dropped 2007-2010 by 17%. As the demand from the most 

important SF6 sub sector, electrical switchgear, was stable, the sales drop can be attributed 

to prohibitions of several open applications by the F-gas Regulation (magnesium die casting, 

sport shoe soles, car tyres; soundproof windows). 

For the future, stagnation of the EU market of F-gases is anticipated. Mobile air conditioning 

(first fill and refill) is by far the most important single F-gas sector, accounting for two thirds of 

the annual sales of HFC-134a (ca. 35 kt per year). Restrictions in the mobile air conditioning 

sector (MAC Directive) are likely to impact the overall HFC-134a market substantially, in 

particular as both XPS foam and aerosol sectors will not remain stable HFC sales areas in 

the long run. It is not certain whether demand for the blend components HFC-32, HFC-125, 

and HFC-143a will actually balance the reduction of demand for HFC-134a once the R-22 

phase-out is completed. 

Figure 3-3 indicates that the EU demand for virgin and recycled F-gases would increase by 

25,000 t (+30%) within 40 years under the WOM scenario which disregards all 2006 EU Fgas legislation. However, the application of the MAC Directive and the F-gas Regulation lead 

to a reduction by 14% in 2050 vs. 2010, to 72,000 t. 

EU Demand for F-gases 2010-2050 without and with F-gas Regulation 

and MAC Directive (metric tonnes)

0

20,000

40,000

60,000

80,000

100,000

120,000

2010 2015 2020 2025 2030 2035 2040 2045 2050

metric tonnes

WOM

WM (MAC Dir + F-gas Reg)

Figure 3-3: Demand for virgin and recycled F-gases (metric tonnes) in the EU-27 under the 

WOM scenario and the WM scenario, which includes MAC Directive and F-gas Regulation. 

Under the 2006 F-gas legislation the demand for F-gases will significantly decrease until 2025, 

and remain stable afterwards. (Source: model AnaFgas) 

In the period 2005-2009, 2 of the 4 plants for HFC-134a production have been closed (Italy, 

UK), and the closure of one of these facilities lead to discontinuation of the production of 

HFC-125, which had been captured as by-product. Although traditionally European HFC 

demand is covered to large extent by imports, mostly from the USA, the reduction in EU HFC 

production capacities seems to be based on projections of the HFC market potential in 

Europe. 
Chapter 3 F-gas markets and policies 42 

3.1.5 HFC markets in North America, Japan, and Asia-Pacific

In other regions of the world, the market trends differ from those in Europe. 

In the USA, the production of F-gases is more than twice as high as in Europe and the 

domestic demand is much larger, in particular for refrigeration and mobile air conditioning. 

Stationary air conditioning is also important and represents a strong market for HFC blends. 

The phase-out of HCFC-22 and transition to HFC blends is still in progress. Regulatory 

measures for containment or prohibition of F-gases currently do not exist. Alternative fluids 

and not-in-kind technologies do not yet attract such high interest as they do in Europe for 

most applications42. 

In Japan, the phase-out of HCFCs follows a tight schedule similar to that in Europe. The 

market potential for HFC blends replacing R-22 is not fully saturated yet. Like the USA, 

Japan has a large sector of stationary air conditioning, which generates high demand. In 

contrast, the potential for the use of HFC-134a in mobile air conditioning is unlikely to 

increase. The Japanese PU industry recently decided to waive HFCs in spray foam (the 

largest sub segment of foam in Japan)43. 

The most evolving markets for F-gases in the future are the developing countries, in 

particular China. In China the use of HFC-134a in mobile air conditioning is still in its initial 

stages within the car industry. The stationary refrigeration sector is still ahead of HCFC-22 

phase out and thus the transition to HFC blends. The large-scale production of room air 

conditioners for the domestic and the world market causes high demand for HFC blend 

components, in particular for HFC-32 and HFC-125 used for production of the refrigerant 

blend R410A. In China an unknown but growing number of small HFC plants emerge 

competing with the Western and Japanese chemical companies to meet this growing 

demand. In addition, low-GWP refrigerants such as propane (R290), iso-butane (R600a), 

carbon dioxide (R744) or ammonia (R-717) and foam blowing agents such as pentanes or 

organic solvents plus CO2 attract interest in developing countries, partly supported by the 

Montreal Protocol. 

From a global perspective, the development of global F-gas markets is not consistent. On the 

one hand new demand arises, and on the other hand the market potential of HFC technology 

is limited by national and international regulatory action. Alternative fluids and not-in-kind 

technologies are increasingly available, usually at low cost. 

It must be pointed out that even very strict regulatory measures on the use of F-gases, like 

the EU ban for HFC-134a in air conditioning systems in passenger cars do not necessarily 

influence the global HFC market. 

Furthermore, the development of alternatives to HFCs with low global warming potential, 

such as unsaturated HFCs like HFC-1234yf or HFC-1234ze (see chapter 5.4), and numerous 

blends of unsaturated HFCs and HFCs is ongoing. However, quantitative data on production 

and market potential of these substances and preparations are not available yet. 

 

42 In industrial refrigeration ammonia plays a greater role in the USA than in Europe. 43 Japan Urethane Industries Institute (JUII): “Phase-out of hydro fluorocarbons (HFC) as a blowing 

agent of Polyurethane (PU) rigid spray foam for the residential building insulation” by the end of 

August, 2010; press release 26th January 2010. 
Chapter 3 F-gas markets and policies 43 

3.2 Policies addressing F-gas emissions 

F-gas policies analyzed at international, European and Member State level as well as at 

national level in countries outside of EU-27 were identified. The underlying approaches 

include regulatory action, market-based mechanisms and voluntary initiatives. 

3.2.1 International level

Multilateral Environmental Agreements (MEAs) 

The EU has ratified several international conventions, which impact use and emissions of Fgases while not addressing them exclusively. 

The United Nations Framework Convention on Climate Change (UNFCCC) and its 

Kyoto Protocol are covering HFCs, PFCs and SF6 emissions since 1997. Measures for 

monitoring and reporting of emissions apply and they are subject to greenhouse gas 

emission reduction targets. The Kyoto Protocol lays down such national targets for 

developed countries (Annex I countries) until 2012, which also include F-gas emissions. 

Through Council Decision 2002/358/EC44, the European Community and its Member States 

accepted the Kyoto Protocol and committed to reduce overall greenhouse gas emissions by 

8% compared to the base year 1990 during the commitment period 2008-2012. 

While COP 15 failed to produce an international agreement involving binding greenhouse 

gas emissions reduction targets, most Annex I countries pledged quantifiable emission 

reductions under the Copenhagen Accord45, and several developing countries submitted 

nationally appropriate mitigation actions (NAMAs) listed in Appendix II of the Accord. In total, 

countries which submitted pledges under the Copenhagen Accord account for ca. 80% of 

global greenhouse gas emissions. For most countries, pledges under the Copenhagen 

Accord are quite similar to those made prior to COP 15, for example, the EU pledged to 

reduce GHG emissions by 20% compared to 1990 levels and to cover 20% of energy 

consumption by renewables. On condition that other major emitting developed and 

developing countries commit to do their fair share under a global climate agreement, the EU 

offered a more ambitious reduction target of 30%. The European Commission has analyzed 

the effects of moving unilaterally to an unconditioned 30% reduction target but maintains that 

the conditions to do so are not met yet46. The recent roadmap for moving to a competitive 

low carbon economy in 205047 confirmed the EU objective of reducing greenhouse gas 

emissions by 80-95% by 2050 compared to 1990. 

 

44 Council Decision 2002/358/EC concerning the approval, on behalf of the European Community, of 

the Kyoto Protocol to the United Nations Framework Convention on Climate Change and the 

fulfillment of commitments thereunder. 

45 UNFCCC 2009: Decision 2/CP15 Copenhagen Accord of 18 December 2009. 46 European Commission: Communication from the Commission to the European Parliament, the 

Council, the European Economic and Social Committee and the Committee of the Regions: Analysis 

of options to move beyond 20% greenhouse gas emission reductions and assessing the risk of carbon 

leakage. COM(2010)265final, 26.05.2010. 

47 European Commission: Communication from the Commission to the European Parliament, the 

Council, the European Economic and Social Committee and the Committee of the Regions: A 

roadmap for moving to a low carbon economy in 2050. COM(2011)112final, 08.03.2011. 
Chapter 3 F-gas markets and policies 44 

European policies addressing all types of GHG emissions including F-gases will hence need 

to be adapted in order to meet these new commitments. 

In addition to the UNFCCC, the Montreal Protocol on ozone depleting substances under the 

Vienna convention is linked to F-gases which were introduced as substitutes to ODS. This 

link is reflected in a series of decisions of the Meetings of the Parties to the Montreal Protocol 

taken in recent years (table 3-3). 

Current discussion treats the question on how to link the work on HFCs done under the 

Kyoto and post-Kyoto regime and further phase out of ODS under the Montreal Protocol 

more closely. Two proposals for an amendment of the Montreal Protocol in this respect have 

been re-submitted in 2011, one by the Federated States of Micronesia (FSM) and one by 

Northern American countries including the USA, Canada and Mexico (NA). Both proposals 

suggest control of production and consumption of HFCs and are currently being discussed at 

international level. Detailed analyses of these proposals are outlined in chapter 7 of this 

report. 

The Basel Convention of 1989 on the control of transboundary movements of hazardous 

wastes and their disposal entered into force in 1992. It defines hazardous wastes and 

establishes a global control system for transboundary shipment of hazardous wastes in order 

to improve waste management and minimize risks for health and the environment. 

As for applications of F-gases, this convention is relevant with regard to imports and exports 

of used equipment and products containing F-gases, for example household refrigerators, 

freezers and air conditioning equipment, to and from EU-27 either during or at the end of 

product life. The Basel Convention came into force in EU in 1994 and has been transposed 

in European legislation (see chapter 3.3.2) and Member State national legislation. 

In recent years, the cooperation with the Vienna Convention/ Montreal Protocol was 

enhanced: The Secretariat of the Basel Convention participated in meetings of the Openended Working Group of the Parties and Meetings of the Parties to the Montreal Protocol, 

and a workshop on management of ozone depleting substance banks and implications for 

climate change in 200948. 

 

48 Open-ended Working Group of the Basel Convention, Seventh Session May 2010: International 

cooperation and coordination: review of the implementation of decision IX/11. Document 

UNEP/CHW/OEWG/7/17. 
Chapter 3 F-gas markets and policies 45 

Table 3-3: Decisions under the Montreal Protocol illustrating the link between the UNFCCC and 

the Vienna Convention 

Decision Issue 

MOP decision X/16 

(1999)49

Implementation of the Montreal Protocol in the light of the Kyoto Protocol: 

- Report by the Technology and Economic Assessment Panel (TEAP) of 

the Montreal Protocol on implications to the Montreal Protocol of the 

inclusion of HFCs and PFCs in the Kyoto Protocol, critical and desirable 

uses of HFCs, and replacement potential of HCFCs by HFCs. 

- Start of formal interaction with the Intergovernmental Panel on Climate 

Change (IPCC) and first workshop. 

MOP decision XIV/10 

(2002) 

Relationships between efforts to protect the stratospheric ozone layer and 

efforts to safeguard the global climate system: issues relating to 

hydrofluorocarbons and perfluorocarbons: Common special report of the 

IPCC and the TEAP.50 

MOP decision XIX/6 

(2007) 

Adjustments to the Montreal Protocol with regard to Annex C, Group I 

substances (hydrochlorofluorocarbons): Accelerated phase out of 

production and consumption of HCFCs. Preparation of funding criteria by 

the Executive Committee which include i.a. “substitutes and alternatives 

that minimize other impacts on the environment, including on the climate, 

taking into account global warming potential, energy use and other 

relevant factor” (11b). 

MOP decision XX/8 

(2008) 

Workshop for a dialogue on high global warming alternatives for ozone 

depleting substances. 

- TEAP report on alternatives to HFCs and HCFCs including use patterns, 

costs and market penetration of alternatives51. 

- Report by the Ozone Secretariat on current control measures, limits and 

reporting requirements for high-GWP alternatives for ODS52. 

- Dialogue on high GWP alternatives to ODS organized by the Ozone 

Secretariat to discuss technical and policy issues on how the Montreal 

Protocol experience can be used to address the impact of HFCs and 

maximize the ozone and climate benefit of the HCFC early phase out53. 

ExCOM Decision 60/44 

(2010) 

Agreed funding criteria for HCFC phase out in the consumption sector in 

A5 countries were adopted by the Executive Committee: “Funding of up to 

a maximum of 25% above the cost effectiveness threshold will be provided 

for projects when needed for the introduction of low global warming 

potential (GWP) alternatives” (Annex I (f) (iv)). 

 

49 Document UNEP/OzL.Pro11/2 of 19 July 1999. 50 IPCC/ TEAP 2005: Special Report – Safeguarding the Ozone Layer and the Global Climate System: 

Issues related to Hydrofluorocarbons and Perfluorocarbons. 51 TEAP Task Force decision XX/8 report: Assessment of alternatives to HCFCs and HFCs and 

update of the TEAP 2005 Supplement report data. May 2009. 

52 Document UNEP/OzL.Pro/Workshop.4/2 of 19 May 2009. 53 The Workshop was held in Geneva in July 2009. 
Chapter 3 F-gas markets and policies 46 

Market based mechanisms 

In the context of the Kyoto Protocol, three market-based mechanisms were established, 

which cover all types of greenhouse gases including F-gases. 

− The International Emissions Trading (IET) describes a regime that allows Parties 

subject to quantified emissions limitation or reduction commitments (“caps”) to buy and 

sell emission credits among them. Authorities assign certain numbers of emission credits 

to each participating entity. Entities whose emissions exceed the amount of credits 

assigned to them, must buy additional credits to cover their actual emissions. 

− The Clean Development Mechanism (CDM) allows developed countries to finance 

projects avoiding greenhouse gas emissions in developing countries and receive credits 

for doing so. 

As of 1 March 2011, F-gas emissions are addressed under several methodologies 

applying to different sectors54: 

25 CDM projects address HFC emissions: Incineration of HFC-23 from HCFC-22 

production (20), recovery of HFC-134a in residential refrigerators (1) and avoidance 

of HFC emissions in PU foam manufacture (4). 

7 CDM projects address PFC emissions: Emission reduction from primary aluminium 

smelting facilities (7). 

14 CDM projects address SF6 emissions: Emission reductions in electrical grids (6) 

and during the manufacture of LCD screens (4), prevention of emissions from venting 

following tests of gas insulated electrical equipment (1) and replacement of SF6 by an 

alternate cover gas in magnesium industry (3). 

Most of the CDM projects addressing F-gas emissions take place in Asia, some in Latin 

America. 

− The Joint Implementation Mechanism (JI) refers to projects in developed countries 

reducing net greenhouse gas emissions in another developed country in order to receive 

credits. 

As of 1 March 2011, F-gas emissions are addressed under several methodologies 

applying to different sectors55: 

6 JI projects address HFC emissions: Co-destruction of HFC-23 and SF6 at a polymer 

plant (1; Russia); HFC-23 destruction (2; Russia); thermal oxidation of the gas 

effluents of from manufacture of trifluoroacetic acid (1; France). 

2 JI projects address PFC emissions: Emission reductions at primary aluminium 

smelting facilities (2; Germany, Russia). 

The European Emissions Trading System will be outlined in subchapter 3.2.2. 

 

54 UNEP Risoe: CDM/JI pipeline analysis and database. http://cdmpipeline.org/ 55 See above. 
Chapter 3 F-gas markets and policies 47 

Voluntary programmes and initiatives 

In the environmental field, decision-makers increasingly opt for alternative forms of regulation 

including voluntary agreements and other industry self-regulation, instead of using traditional 

legislative instruments. 

International voluntary action addressing use and emissions of F-gases has been taken by 

different industries: 

Semiconductor industry: An international voluntary agreement of the semiconductor 

industry (including all the countries where production is located) includes the commitment to 

reduce absolute total emissions of HFC-23, PFCs, SF6 and NF3 by 10% by 2010 (baseline 

1995). This target has been reached and a new voluntary agreement for the post-2010 

period is currently being elaborated56. 

LCD industry: This voluntary agreement of the LCD industry (located in Japan, Korea and 

Taiwan) from 2003 intends to reduce aggregate absolute PFC and SF6 emissions from LCD 

fabrication facilities to at least 0.82 million tonnes CO2 eq by 2010. 

Aluminium industry: Global agreement to reduce PFC production emissions by 50% per 

tonne of production by 2020 (baseline 2006). 

Refrigeration: In November 2010, the Consumer Goods Forum, an organization of 400 

global consumer goods manufacturers and retailers, announced an initiative to phase out the 

use of HFC refrigerants as of 2015 where natural refrigerant alternatives “are legally allowed 

and available for new purchases of point-of-sale units and large refrigeration installations”. 

Global initiatives such as “Refrigerants, Naturally!” and “The Natural Voice” provide platforms 

for companies committing to the use of natural refrigerants and thereby prevention of 

emissions of ozone-depleting substances and fluorinated greenhouse gases. 

3.2.2 European level 

Regulatory measures 

In the context of additional commitments for GHG emission reductions, a new stage of 

European climate and energy policy has been initiated when the so called “climate and 

energy package” was agreed in 2008. It consists of four pieces of legislation: a revision of 

the 2003 Emissions Trading Directive, a Decision on sharing the effort on GHG emission 

reductions in the non-Emissions Trading System (ETS) sectors among Member States 

(406/2009/EC), a new and comprehensive Renewable Energy Directive (2009/29/EC), and a 

Directive on carbon capture and storage (CSS). 

The Effort Sharing Decision 409/2009/EC lays down binding national GHG emission 

reduction targets in the sectors not covered by the European Emissions Trading System 

(EU-ETS), i.e. all sectors relying on F-gases except for aluminium casting and related PFC 

emissions. These national targets were set for the period 2013-2020 in order to contribute to 

the overall reduction objective by 2020. The reference year is 2005 and the targets take into 

account the Member States’ per-capita GDP. 

 

56 Confirmed by ESIA (Shane Harte) via Email on 16.02.2011. 
Chapter 3 F-gas markets and policies 48 

An important element is the revised Renewable Energy Directive 2009/28/EC, which lays 

down mandatory national targets for the Member States’ use of renewable energy in 

electricity, heating, cooling and transport, which are adding up to 20% of the EU’s total 

energy consumption by 2020. 

A potential review of the F-gas Regulation and/or the MAC Directive will need to take into 

account this context of commitments for GHG emission reductions (see chapter 3.3.3). 

Interactions with European legislation relevant in the context of F-gases are set out in 

chapter 3.3. 

Market based mechanism 

The European Emissions Trading System (EU-ETS) is a “cap and trade” program and 

commenced operation in 2005. It currently only covers CO2 emissions from installations from 

more than 10,000 energy-intensive facilities across EU-27 including oil refineries, power 

plants over 20 megawatts in capacity, coke ovens, and iron and steel plants, along with 

cement, glass, lime, brick, ceramics, and pulp and paper installations. 

Within the “climate and energy package”, the European Emissions Trading Directive was 

subject to revision (Directive 2009/29/EC). From 2013, the scope will be extended to other 

sectors and gases and will then also include PFC emissions from the aluminium sector. 

Other F-gases and/or sources of emissions are not addressed by the EU-ETS in the period 

until 2020. 

Furthermore, caps placed on industrial emissions under the EU-ETS create a link between 

European and international market-based mechanisms as demand for credits generated 

through CDM and JI projects under the Kyoto Protocol is created. Exchange and substitution 

of international emission reduction certificates is limited by the setting of a facility-related 

upper limit for the use of CDM/JI credits57. 

However, the first phase of EU-ETS (2005-2007) has suffered from the high number of 

allowances resulting in little demand and low prices for offsets. For the second phase (2008-

2012), different caps apply, which might eventually lead to increasing demand for 

international credits as it might be cheaper for industry to import emission reduction credits 

from CDM/JI projects than achieving emission reductions domestically. 

For the third phase in the period 2013-2020, the Effort Sharing Decision (406/2009/EC), 

which is also part of the “climate and energy package”, has introduced more flexibility for the 

Member States in how to achieve their national GHG emission reduction targets. The share 

of international emission offsets will also be limited, while the exact percentage compared to 

the 2005 baseline remains to be determined. 

Emission offset credits generated through HFC-23 destruction projects through the CDM are 

currently being discussed. The EU Climate Change Committee, which includes 

representatives from the Member States, voted for a ban of such credits from the EU-ETS 

from May 2013. 

 

57 Linking Directive 2004/101/EC connects European Emissions Trading and the Kyoto Protocol 

mechanisms. 
Chapter 3 F-gas markets and policies 49 

Voluntary programmes and initiatives 

The following list gives some examples of voluntary programmes and initiatives but does not 

intend to give a complete overview. 

General: In Europe, voluntary action can be taken by industry sectors or within the European 

Eco-Management and Audit Scheme. The EMAS scheme (Eco-Management and Audit 

Scheme) is a voluntary environmental management system, under which companies and 

other public organisations evaluate, manage and continuously improve their environmental 

performance. EMAS has been operative since 1995 and the latest revision (EMAS III) came 

into effect on 11 January 2010 (Regulation (EC) No 1221/2009). The core indicators for 

environmental performance include several aspects relevant for use and emissions of Fgases (Annex IV C): 

- Emissions: Total annual emission of greenhouse gases and total annual air emission. 

- Waste: Total annual generation of waste and total annual generation of hazardous waste. 

- Energy efficiency: Total annual energy consumption with percentage of renewable energy 

use. 

- Material efficiency: Annual mass-flow of different materials used. 

Semiconductor industry: European semiconductor industry has agreed to a European 

emission reduction target in order to meet the global reduction target (1995-2010). 

3.2.3 Member State level

Regulatory measures 

Early national policy measures addressing F-gases were based on existing ODS legislation, 

which was extended to F-gases or applied to sectors relying on both ODS and F-gases. 

In France, recovery of CFCs, HCFCs and HFCs was mandatory from 1992 onwards58. In 

Sweden, personnel and companies had to be trained and accredited by the Swedish Board 

of Accreditation and Conformity Assessment (SWEDAC) since 1992. Since 1992, the Danish 

KMO system and the Dutch STEK system have been working on the prevention of emissions 

of all types of halogenated refrigerants and on training and certification of personnel and 

companies. 

After the European commitments for reduction goals of GHG emissions under the Kyoto 

Protocol, the EU Burden Sharing Decision (Council Decision 2002/358/EC)59 redistributed 

the target among the Member States. Subsequently and in addition to European legislation, 

Member States have individually implemented their measures addressing GHG emissions. 

They might hence have been ahead of the EU concerning the reduction of certain emissions. 

Early legislation on F-gas emissions entered into force in Denmark (March 2001) and Austria 

(December 2002). On the basis of the clause laid down in Article 9(3) of the F-gas 

 

58 Decree of 7 December 1992. 59 This agreement is based on an arrangement under Article 4 of the Kyoto Protocol whereby Annex I 

Parties can fulfil their emission targets jointly by pooling their individual emissions in a common 

'bubble.' The EU (EU-15) has used this provision and sub-divided its target of -8% into differentiated 

targets for each Member State that take account of their different national circumstances. 
Chapter 3 F-gas markets and policies 50 

Regulation, these Member States were allowed to maintain their stricter provisions until 

201260. 

For the accounting of F-gas emissions in the national GHG emission reduction targets, the 

baseline year in EU-15 generally is 1995 (except for Austria, France, and Italy: 1990). 

Some Member States decided to establish provisions of national legislation which are stricter 

than the requirements of the F-gas Regulation with regard to scope and mechanisms of 

different measures. 

Measures stricter than the F-gas Regulation that have been imposed by national legislation 

include for example 

- Lower minimum charges: Equipment containing lower minimum charges of F-gases 

than set out by the F-gas Regulation is subject to rules for containment in Denmark 

(minimum charge of 2.5 kg) and France (minimum charge of 2 kg). 

- Mandatory leakage checks for mobile equipment: Leakage checks of certain 

types of mobile equipment are mandatory in Germany (refrigerated trucks containing 

charges of >3 kg of F-gases), Sweden (refrigeration and AC systems installed on 

ships containing charges of >10 kg of F-gases), and the Netherlands (mobile 

refrigeration and AC equipment including ships according to schedule set out by the 

F-gas Regulation). 

- Maximum annual leakage rates for stationary equipment have been established in 

Germany (refrigeration and AC equipment; depending on charge and date of 

manufacture), Belgium (new equipment: 5%) and Luxembourg (5%). 

- Mandatory storage of equipment records is required in Czech Republic (5 years), 

France (5 years), the Netherlands (5 years) and Germany (5 years). Electronic 

recording is mandatory in Hungary and Slovakia. 

- Registration of equipment in a database for monitoring and enforcement purposes 

in Hungary (cooling circuits), Slovenia (charges >3 kg of ODS or F-gases), Estonia 

(charges >3 kg of F-gases). 

- Mandatory reporting of records of equipment containing charges of >10 kg of Fgases to local authorities is required in Sweden (charge, F-gas quantities refilled and 

recovered, dates and results of mandatory leakage checks, contact details of 

servicing company, discarded equipment); mandatory reporting of equipment records 

by operators and service companies (charges >3 kg) is planned or in place in some 

Member States (e.g. Hungary, Poland) and intends to build a link to national F-gas 

emission inventories according to Article 6(4) of the F-gas Regulation (also see 

chapter 2). 

- Producer responsibility schemes requiring producers and suppliers of F-gases to 

take back recovered bulk F-gases for further recycling, reclamation and destruction 

are in place in Sweden (legally binding for fluorinated greenhouse gases since 2007, 

for ODS since 1989) and Germany (legally binding since 2008). 

 

60 Recital (11) to articles of the F-gas Regulation: “Annex II to Decision 2002/358/EC lays down 

different targets for individual Member States and Member States have adopted different strategies to 

achieve these targets. Member States should be able to maintain existing national measures adopted 

in order to meet those targets for a limited period of time in accordance with Article 95 of the Treaty.” 
Chapter 3 F-gas markets and policies 51 

- Certification of groups of personnel and companies not subject to certification 

requirements of the F-gas Regulation, e.g. in the Netherlands personnel and 

companies servicing mobile equipment containing charges of F-gases >3 kg are 

subject to certification. In France, certification requirements were extended to 

companies of the MAC sector. 

Furthermore, it should be noted that other European legislation implemented at national level 

might also address F-gases and set stricter requirements than related European rules. For 

example, 

- Take back systems for domestic and small commercial refrigeration and AC systems 

need to be developed and implemented at national level under the WEEE Directive 

(see chapter 3.3.2). In the Netherlands, national rules have extended this take back 

scheme to large commercial and industrial refrigeration and AC systems. 

- The European Directive on integrated pollution prevention and control (IPPC 

Directive) requires industrial and agricultural activities with high pollution potential to 

have a permit. In the Netherlands, maximum F-gas emission thresholds were 

established in the permits for aluminium industry, semiconductor industry, HCFC-22 

manufacturing facilities. 

Under the 2008 climate and energy package, new national GHG emission reduction targets 

have been laid down through the Effort Sharing Decision 409/2009/EC. These legally binding 

national targets were set for the period 2013-2020 in order to contribute to the EU’s overall 

reduction objective by 2020. They are based on the reference year 2005 and set the 

framework for further EU and national policy measures. 

Market-based mechanisms 

In addition to regulatory measures, financial incentives established at Member State level 

can reduce demand and improve containment and recovery of F-gases. 

A recent study on behalf of the EU Commission61 (2010) assessed taxes on virgin refrigerant 

sales and rebates on the return of used refrigerants for destruction as a policy option for 

promoting the recovery and destruction of ODS/HFCs from banks. It is suggested to promote 

reclamation for reuse in certain cases instead of strict destruction since it was often more 

cost effective and less energy-intensive to reclaim used refrigerant than to produce virgin 

refrigerant. Moreover, if the reclamation of used refrigerant could displace the production of 

new refrigerant in EU or abroad, this was an important benefit that should not be overlooked. 

For recovery of F-gases from products and equipment at end of life, a lack of economic 

incentives, in particular for smaller companies, has been identified as main influencing factor 

in a recent study for the European Commission62, “as currently the only driver compelling 

 

61 ICF International: Identifying and Assessing Policy Options for Promoting the Recovery and 

Destruction of Ozone Depleting Substances (ODS) and Certain Fluorinated Greenhouse Gases (Fgases) Banked in Products and Equipment; Final Report prepared for the European Commission, May 

2010; p. 57. 

62 ICF International, ibid. p. 54. Other barriers perceived by stakeholders include legal issues arising 

from waste shipment legislation (Regulation (EC) No 1013/2006) and unclear roles and responsibilities 

for recovery of F-gases from large equipment in some Member States. 
Chapter 3 F-gas markets and policies 52 

recovery at end of life is compliance with EC and national regulations”. This finding has also 

been confirmed by stakeholders contacted within this project. 

Reclamation of F-gases is a complex technical process which leads to higher costs for 

reclaimed substances than for virgin gases. 

The types of financial incentive schemes established in certain Member States include: 

- Taxes and tax rebates 

- Deposits and refunds 

If linked to the climate impact of the specific substance (GWP), financial incentives might 

also support the choice of low or zero GWP alternatives. 

Experiences from several Member States are available: Denmark (deposit-refund scheme 

since 1992; tax since 2001), Slovenia (tax since 2009) and Sweden (deposit scheme; legally 

binding producer responsibility scheme since 2007). Sweden is planning to introduce a tax 

on import and production of HFCs, Poland will impose a tax on F-gas quantities placed on 

the market. 

The schemes applied in Denmark and Slovenia are chosen as case studies since they have 

been in place for several years already. 

Case: Deposit-refund scheme and tax in Denmark

A deposit-refund scheme has been established in Denmark through the Danish 

Refrigeration Installers’ Environmental Scheme (KMO system) in 1992 in order to work on 

the prevention of emissions of all types of halogenated refrigerants and on training and 

certification of personnel and companies. Major measures of this voluntary scheme include: 

- Only service companies being members of KMO can purchase new refrigerants from 

importers of synthetic refrigerants (no domestic production). 

- End users pay a fee for refrigerants charged into the equipment, of which certain shares 

remain with the service company (expenses for training, recovery equipment) and the 

KMO (funding of secretariat, infrastructure for reclamation and destruction, refund). 

- The service companies receive a refund when returning used refrigerants to KMO 

reclamation and destruction facilities. The level of the refund depends on purity of the 

recovered refrigerant. 

- KMO undertakes reclamation and destruction of used refrigerants. Reclaimed gases are 

sold to service companies for ca. DKK 4/ kg (ca. €0.5) and contribute to the funding of 

KMO. 

Data on recovery of HFCs for reuse and recycling on-site are not available. Preliminary data 

show a stable share of returned refrigerants by KMO Members for reclamation and 

destruction compared to refrigerant sales (table 3-4). 
Chapter 3 F-gas markets and policies 53 

Table 3-4: Estimated refrigerant sales to KMO Members (including all types of synthetic 

refrigerants) and returned quantities for reclamation and destruction in Denmark (t) 

Refrigerant sales by KMO 

Members Refrigerants returned to KMO % 

1998 ca. 400-500 t ca. 23 t ca. 5 

2010 ca. 300 t ca. 9-15 t 3-5 

 

Based on previous experiences made with a tax on new CFCs from 1989 onwards, Denmark 

also introduced a tax on F-gases in March 2001 through the “Law on Tax on certain ozone 

depleting substances and certain industrial greenhouse gases”. 

The tax on F-gases is based on the Danish CO2-tax per t CO2 eq which applies to potential 

emissions. The base tax per t CO2 eq emitted will be increased from DKK100 (ca. €13.50) to 

DKK150 (ca. €20) from January 2011 onwards63. Fluorinated greenhouse gases and blends 

with high GWP are hence subject to higher taxation than low GWP gases (table 3-5). The 

maximum tax is currently DKK400/ kg (ca. €53). 

Table 3-5: Examples of Danish tax for specific substances (DKK/kg; €/kg) 

F-gas type Tax per kg (DKK) Tax per kg (€) 

HFC-134a 130 ca. 17 

R-404A 378 ca. 50 

R-407C 165 ca. 22 

PFCs 400 ca. 53 

SF6 400 ca. 53 

As Denmark does not produce any F-gases domestically, taxes are generally imposed on 

imports of bulk F-gases and F-gases contained in products but several exemptions apply for 

F-gas quantities contained in equipment64. The tax is also applicable to servicing quantities. 

Quantities contained in pre-charged refrigeration and air conditioning equipment, switchgear 

(<36 kV), XPS foam, mobile air conditioning equipment in cars, buses and trucks, are 

exempted from this tax. 

It was estimated in an Effort Analysis that the tax in combination with the effect of bans 

introduced through regulation will lead to emission reductions of 49 kt CO2 eq in 2001, 150 kt 

CO2 eq in 2005 and 370 kt CO2 eq in 2010 as compared to a business as usual scenario. 

The socio-economic reduction costs were estimated at ca. DKK200/ tonne CO2 (ca. €27/ 

tonne CO2), costs and effects of taxes and regulations were not calculated separately.65 

Absolute quantities of F-gas imports decreased since introduction of the tax and regulatory 

bans (metric tonnes; table 3-6)66,67. Reclaimed quantities of F-gases are not subject to 

taxation which potentially provides an incentive for reclamation. 

 

63 Ministry for Climate and Energy 2009: Denmark’s Fifth National Communication on Climate Change 

under the United Nation’s Framework Convention on Climate Change and the Kyoto Protocol; p.151. 

64 List of exemptions: https://www.retsinformation.dk/Forms/R0710.aspx?id=18091 (last checked on 

04.03.2011). 

65 Ministry for Climate and Energy 2009: Denmark’s Fifth National Communication on Climate Change 

under the United Nation’s Framework Convention on Climate Change and the Kyoto Protocol; p.150. 

66 Plan Miljo 2010: The greenhouse gases HFCs, PFCs and SF6; Danish consumption and emissions 

2008; Report for the Danish Ministry of the Environment. 
Chapter 3 F-gas markets and policies 54 

Table 3-6: Import of HFCs (pure and blends), PFCs and SF6 to Denmark 1995-2009 (t) 

1995 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

HFCs 745 1,027 676 713 510 702 484 559 402 399 363 

HFC134a 565 711 473 402 241 307 235 281 161 165 175 

HFC404A 119 193 126 189 145 253 162 176 130 114 107 

PFCs 1.5 6.9 3.7 2 0.5 0.3 0.5 0 0.7 0.8 0.9 

SF6 17 9 4.7 1.4 2.2 2.3 3.6 4.2 5.4 5.9 4.3 

Total 763.5 1042.9 684.4 716.4 512.7 704.6 488.1 563.2 408.1 405.7 368.2 

Table 3-7: Emissions of HFCs, PFCs and SF6 in Denmark 1995-2009 (kt CO2 eq)68,69 

1995 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

HFCs 217.8 606.2 649.6 675.3 699.7 754.1 801.0 822.0 848.7 851.3 797.6 

HFC134a 194.4 320.7 341.4 355.0 334.4 353.2 344.3 343.2 346.9 342.9 n.a. 

HFC404A 15.3 239.6 236.8 256.5 290.0 312.7 351.1 375.4 391.6 393.0 n.a. 

PFCs 0.5 17.9 22.1 22.2 19.3 15.9 13.9 15.7 15.4 12.8 14.2 

SF6 107.3 59.2 30.4 25.5 31.9 33.1 21.8 36.0 30.3 31.6 36.7 

Total 325.6 683.3 702.1 723.0 750.8 803.1 836.7 873.7 894.3 896 845 

n.a.: not available yet

F-gas emissions increased since 200170, mostly driven by HFC-404A, which is used as 

substitute for R-22 (GWP 3260; IPCC 2nd AR), and HFC-134a (GWP 1300; IPCC 2nd AR) and 

reached a peak in 2008 (table 3-7). Emissions in 2009 decreased and ranged at about the 

level of emissions in 2005. Although F-gas imports and F-gas emissions decreased, large 

quantities are still placed on the market71. It seems that the level of taxes might be low 

compared to continued use of HFCs in large refrigeration and air conditioning systems, which 

hence might not provide sufficient incentive for all operators to opt for low or zero GWP 

alternatives. Furthermore, several tax exemptions are to be noted. Reported emissions also 

reflect the long lifetime of the equipment stock containing F-gases. The revenues from the 

tax have partly been used to support research and development of technologies not relying 

on F-gases. 

Case: Tax scheme in Slovenia72

In 2008 Slovenia adopted a regulation on an environmental tax on the use of fluorinated 

greenhouse gases, which entered into force on 1 January 200973. The tax is calculated on 

 67 Plan Miljo 2010: The greenhouse gases HFCs, PFCs and SF6; Danish consumption and emissions 

2009; Draft Report for the Danish Ministry of the Environment (preliminary data for 2009). 

68 Plan Miljo 2010: The greenhouse gases HFCs, PFCs and SF6; Danish consumption and emissions 

2008; Report for the Danish Ministry of the Environment. 

69 Denmark: National Inventory Report 2009. 70 It should be noted that PFC emissions from aluminium industry are not subject to taxation. 71 Imports also include substances which are exempted from tax. 

72 Input provided by Dr. Tanja Markoviþ Hribernik, University of Maribor, Faculty of Business and 

Economics, Slovenia, via Email on 1 June 2011. 
Chapter 3 F-gas markets and policies 55 

the basis of pollution units, which refer to CO2 equivalents, The Slovenian government 

defines the price per pollution unit each year; for 2009, 2010, and 2011 the price per pollution 

unit remained the same and was €0.0125. 

When it introduced the tax on the use of F-gases, the Slovenian government anticipated a 

transition period during which the tax burden would gradually increase in the following 

manner: 

– For 2009, 10% of the full price per pollution unit (or 1/10 of the full price per pollution unit; 

€0.0125 × 0.1 = €0.00125) 

– For 2010, 20% of the full price per pollution unit (or 1/5 of the full price per pollution unit; 

€0.0125 × 0.2 = 0.0025) 

– For 2011, 40% of the full price per pollution unit (or 1/2.5 of the full price per pollution unit; 

€0.0125 × 0.4 = €0.005) 

– For 2012, 80% of the full price per pollution unit (or 1/1.25 of the full price per pollution 

unit; €0.0125 × 0.8 = €0.01) 

– For 2013 onwards, the full price per pollution unit (= €0.0125) 

The level of the tax depends on the purpose of the use of F-gases: The first fill of precharged equipment and stationary equipment is taxed 5% while F-gas quantities used for 

servicing and maintenance of equipment are taxed 100%. 

First data on F-gas quantities used and tax revenues show high increase of the use of Fgases and related increase of tax (table 3-8). 

 Table 3-8: Quantities of F-gases used in Slovenia and related tax revenues in 2009 and 2010. 

Source: Customs Administration of the Republic of Slovenia (General Customs Directorate) 

2009 2010 

Total quantity of F-gases (kg) 187,057.05 277,465.90 

- Use for the production of equipment containing F-gases (kg) 79,451.00 87,352.00 

- Use for first installation of stationary equipment (kg) 10,098.60 15,275.10 

- Use for maintenance of existing equipment (kg) 97,507.45 174,838.80 

Environmental tax paid (€) 86,893.00 510,640.03 

Current problems of the scheme relate to the fact that taxes do not apply in neighbour 

countries within the EU and outside of the EU and that it is possible for companies to buy Fgases there at lower prices. Furthermore, tax rebates for recovered F-gases for reclamation 

and destruction are not part of the scheme. Amendments of the existing regulation are being 

discussed in order to improve effectiveness of the tax scheme. 

Voluntary programmes and initiatives in Member States 

Certain industries established voluntary agreements at national level in some Member 

States. The following list gives some examples but does not intend to give an exhaustive 

account: 

 73 Government of the Republic of Slovenia: Regulation on Changes and Amendments to the 

Regulation on the Environmental Tax for Polluting the Air with Carbon Dioxide Emissions, Official 

Gazette of the Republic of Slovenia 78/08, 2008. 
Chapter 3 F-gas markets and policies 56 

Producers of refrigeration, air conditioning and heat pump equipment: Voluntary takeback schemes established by industry for end of life equipment such as commercial and 

industrial air conditioning systems (Greece, UK, Belgium), heat pumps (Belgium). 

Producers of fluorinated gases: Voluntary take-back schemes established by industry for 

recovered bulk F-gases are established in the Netherlands (following a mandatory take-back 

scheme for ODS, which has been in place since the early 1990s) and in France (depositrefund scheme covering ODS and HFCs, which has been in place since 1993). 

Fire protection industry: Prior to the F-gas Regulation, voluntary agreements on monitoring 

of HFC and PFC emissions, leak detection and containment processes were in place in the 

Netherlands74 (since 1999) and the UK (since 1994, renewed in 1997)75. The agreements 

were outdated by the F-gas Regulation. 

A voluntary agreement by industry in Germany on the phase out of the use of HFC-23 as fire 

extinguishing agent from 2006 has been withdrawn by industry as one manufacturer of HFC23 equipment exerted pressure. 

Semiconductor industry: Global and European agreement to reduce emissions of HFC-23, 

PFCs, SF6 and NF3 (1995-2010), which has been transferred into national targets for all 

Member States where production is located. 

Switchgear industry: Voluntary agreements addressing use and emissions of SF6 exist in 

France (2005-2010; renewed agreement expected for the period 2011-2016), Germany 

(since 1996/ renewed in 2005), Spain (2008-2012). Measures of the earlier voluntary 

commitments preceded the provisions of the F-gas Regulation and were established through 

industry standards. Further emission reductions through the F-gas Regulation are not 

expected as these industry standards already have established the same measures as the 

regulation. 

Aluminium industry: A voluntary commitment by the only French producer of primary 

aluminium entered into force in May 1996 and aimed at reductions of absolute CF4 emissions 

(t) by 63% and specific CF4 emissions (kg/t) by 73% until 2000 (baseline 1990). 

A voluntary commitment had been made by the German primary aluminium industry in 1997 

and aimed on reduction of absolute and specific PFC emissions (CF4, C2F6) by 50% until 

2005 (baseline 1990). In 2001 the emissions were already 85% below the baseline. So far, 

the voluntary agreement has not been renewed. 

3.2.4 National level outside of EU-27

Policies addressing F-gas emissions are common in some countries outside of the European 

Union where HFCs were introduced several years ago as a consequence of ODS phase out 

under the Montreal Protocol. 

 

74 „Code of Practice for the use of HFC and PFC fire extinguishing agents“, concluded by the Ministry 

of Environment and VEBON (Association of Safety Companies in the Netherlands), August 1999. 

75 „Voluntary Agreement between the UK Government and the Fire Industry concerning the use of 

HFCs and PFCs for fire protection“ concluded by the Department of Environment and Fire Industry 

Council, September 1994, renewed in 1997. 
Chapter 3 F-gas markets and policies 57 

These countries include developed countries such as the United States of America, 

Australia, Japan, Norway, and Switzerland, which are all listed in Annex 2 of the Montreal 

Protocol (“A2 countries”). The approaches chosen comprise regulatory measures, partly 

linked to market-based instruments such as taxes. 

National policies addressing emissions of HFCs, PFCs and SF6 are hardly known from 

developing countries (“A5 countries” under the Montreal Protocol) except for few cases, e.g. 

Croatia (provisions on monitoring of imports under national ODS legislation were extended to 

imports of HFCs; fees for ODS and HFC destruction apply at the time of purchase). 

Regulatory measures 

In Switzerland, the Swiss Ordinance on Risk Reduction relates to the use of certain 

particularly dangerous substances, preparations and articles76 (SR 814.81), last amended in 

200577. The term “substances stable in air (SSA)”78 includes HFCs with GWP in the range of 

140-11,700, all PFCs, SF6 and NF3. HFC-152a is hence not covered. The Ordinance 

establishes a general prohibition for SSA but allows exemptions for specific sectors listed in 

annexes. The ban applies to residential refrigerators, freezers, dehumidifiers and airconditioners. Production and placing on the market of air conditioning systems in motor 

vehicles are exempt as long as no substitutes are available. 

The ban applies to foams unless insulation is not possible with other materials. For the 

solvents sector, exemptions from the general prohibition apply to SSA used for surface 

treatment in installations with automatic closing systems opening only when the SSA 

concentration is <1 g/ m3 at a mass flux of the SSA of <100 g/ h (according to the 

requirements of the Clean Air Ordinance, Annex 2, No 87). Aerosol products containing 

HFCs are generally banned. Exemptions exist for MDI, one component foams and sprays 

used for the cleaning of equipment under electric tension. Swiss legislation is stricter than EU 

legislation for technical aerosols containing HFCs as they are subject to a ban. 

With regard to the refrigeration and air conditioning sector, the following requirements apply 

for installations containing charges of SSA >3 kg: Annual controls for tightness, mandatory 

maintenance of records, authorization requirements for new installations79, public registration 

of equipment containing ODS and SSA. 

In Japan, current legislation on ODS and F-gases focuses on recovery and recycling of 

refrigerants, such as the Home Appliance Recycling Law, which entered into force in 2001. It 

applies inter alia to household air conditioners, refrigerators and freezers. The Fluorocarbons 

Recovery and Destruction Law entered into force in 2002 (amended in 2006) and requires 

recovery of CFCs, HCFCs and HFCs from commercial refrigeration and air conditioning 

systems during servicing (since 2006) and at end of life (since 2002) in order to ensure 

proper destruction. The End-of-Life Vehicle Law was promulgated in 2002 and entered into 

force in 2005. It aims at recycling of vehicle components and recovery of ODS and F-gases 

from mobile air conditioning systems in all vehicle types. 

 

76 Ordinance on Risk Reduction related to Chemical Products (ORRChem). 77http://www.bafu.admin.ch/chemikalien/01389/01404/index.html?lang=en; communication from the Swiss 

Bundesamt für Umwelt (Federal Office for the Environment), via Email 

78 The basic definition refers to „fluorinated VOC with vapor pressure of at least 0.1 mbar at 20°C or a 

boiling point lower than 240°C at 1013.25 mbar with T >2 years” (Annex 1.5 of the Ordinance). 

79 For further information on authorization: www.pebka.ch 
Chapter 3 F-gas markets and policies 58 

In Australia, the Ozone Protection and Synthetic Greenhouse Gas Management 

Regulations 1995 (last amended in 2010) establish licensing requirements for the placing on 

the market of F-gases: Licensing requirements apply to import, export and manufacture of 

HFCs and PFCs, (“controlled substances licenses”) and the import of refrigeration and air 

conditioning equipment containing HFCs or HCFCs (“pre-charged equipment license”). A 

controlled substances license is required to manufacture HFCs and PFCs and for the import 

and export of any amount of HFCs and PFCs. A non-refundable application fee of AUD 

$15,000 (ca. €11,000) is payable with the application. Holders of a HFC or PFC controlled 

substance license are required to maintain records, provide quarterly reports to the 

Department of Environment and pay a levy based on the quantity of substances imported at 

the end of each quarter. The levy is AUD $165/ t (ca. €120/t) for HFCs and PFCs. 

In the USA, proposals for domestic climate legislation currently pending Congress decision 

include the American Clean Energy and Security Act (formerly known as the WaxmanMarkey bill) and the American Power Act (known as the Kerry-Lieberman discussion draft) 

and introduce cap and trade mechanisms. Both set out separate chapters with supply caps 

on all HFCs and maximum allowable amounts of HFC supply. Reduction steps are relative to 

the baseline of aggregate US consumption of HFCs and HCFCs, averaged in the period 

2004-2006 and differ between the proposals. Regulatory measures already in place include 

rules established by the US Environmental Protection Agency (EPA) and the Greenhouse 

Gas Reporting Program, which requires inter alia magnesium production and HCFC 

production facilities to calculate and report their GHG emissions to EPA (first reports on 2010 

are due in 2012). 

Market-based instruments 

In Norway, a tax on HFCs and PFCs was introduced on 1 January 2003 and currently 

amounts to NOK204.99 per t CO2 eq (ca. €25) of gas imported or produced (in bulk and in 

pre-charged equipment) (approximately the tax rate on mineral oil in Norway). From 1 July 

2004, this tax was supplemented by a reimbursement scheme which applies to all HFCs and 

PFCs delivered for destruction and prescribes about a similar rebate. HFCs are not produced 

domestically.80 The tax and reimbursement scheme are reported to have resulted in better 

maintenance and improved routines during discharge of old equipment. It also gives a strong 

incentive for choosing HFCs with low GWP or alternative substances and processes, which 

is reflected by lower imports of F-gases with high GWP (figure 3-4). 

An evaluation report states that “the introduction of tax seems to have decelerated the yearly 

growth rate of imports by inducing a change in technology towards equipment using less 

chemical per unit, and by augmenting the use of alternative refrigerants like ammonia and 

CO2. These changes are mainly occurring in medium sized equipment, such as air 

conditioning and refrigeration/freezing installations in supermarkets, hotels, restaurants, etc. 

"The price increase of chemicals has made changing technology good economy.”81

 

80 Ministry of Environment 2009: 5th National Communication of Norway under the UNFCCC and the 

Kyoto Protocol; p.38. 

81 Katherine Loe Hansen 2008: Statistics Norway, Department of Economic Statistics, Environmental 

Statistics – Emissions from consumption of HFCs, PFCs and SF6 in Norway; p.3. 
Chapter 3 F-gas markets and policies 59 

Figure 3-4: Actual imports of F-gases as compared to projected imports in a business as usual 

scenario in the period 1993-2005 in Norway (MT CO2 eq)82. 

Although emissions are still growing, since the introduction of the tax, the growth trend in 

HFC and PFC emissions changed from exponential to linear83 (table 3-9). 

The estimated revenue of the tax amounts to 210 Million NOK in 2010 (ca. 25.7 Million €). 

The tax is adjusted annually. 

Table 3-9: Emissions of F-gases in Norway (t CO2 eq)84 

Emissions 

(t CO2 eq) 1995 2000 2001 2002 2003 2004 2005 2006 2007 

HFCs 15.1 124.8 157.6 188.9 215.2 240.7 274.4 303 328.7 

PFCs 301.4 198.0 199.4 215.3 135.7 131.5 124.3 110.7 119 

SF6 25.4 39.1 33.1 10 9.8 11.5 13.1 8.9 3.2 

 

82 Katherine Loe Hansen 2008: Statistics Norway, Department of Economic Statistics, Environmental 

Statistics – Emissions from consumption of HFCs, PFCs and SF6 in Norway; p.4. 83 Ministry of Environment 2009: 5th National Communication of Norway under the UNFCCC and the 

Kyoto Protocol; p.10. 

84 Ministry of Environment 2009: 5th National Communication of Norway under the UNFCCC and the 

Kyoto Protocol; p.23. 
Chapter 3 F-gas markets and policies 60 

Voluntary programmes and measures 

In Australia, the Greenhouse Gas Abatement Program (GGAP)85 is a voluntary approach 

introduced by the Commonwealth in order to support activities likely to result in emission 

reductions. 3 projects under this programme focussed on the use and emissions of HFCs, 

including “destruction of synthetic gases from refrigeration”, “inventories and projections of 

ozone depleting and synthetic greenhouse gases used in Montreal Protocol industries” 

(2002) and “synthetic gas use in non-Montreal Protocol industries” (2002; magnesium 

production, aluminium smelting, electricity transmission). 

In the USA, voluntary partnerships between industries and the US EPA are the major tool for 

reducing F-gas emissions: Since 2003, a voluntary code of practice intends to reduce HFC 

and PFC emissions from fire protection and is based on a partnership between the US EPA 

and several industry associations active in the sector. Voluntary recommended practices for 

household refrigerator and freezer producers intend to minimize HFC emissions (foam and 

refrigerants) during manufacture of appliances86. For other types of refrigeration and air 

conditioning equipment, responsible use guidelines also aim at reduced manufacturing 

emissions87. PFCs and SF6 emissions from aluminium manufacture, magnesium production, 

semiconductor and electric power industries. Another voluntary program with HCFC-22 

producers has reduced HFC-23 by-product emissions through process optimization and 

thermal oxidation (HFC-23 Emission Reduction Program). Disposal emissions from 

appliances are addressed by the Responsible Appliance Disposal Program of the US EPA 

since 2006. 

In Japan, a voluntary agreement of the Japanese Urethane Industry for a phase-out of HFCs 

as blowing agents of PU rigid spray foam for residential building insulation by end of August 

2010. The Industrial Network for Fluorocarbon Recovery Promotion has encouraged 

recovery of fluorocarbon refrigerants during repair and maintenance of equipment since the 

mid 1990s. 

In Norway, a voluntary agreement from 2002 between the Ministry of Environment and the 

most important users and producers of SF6 insulated switchgear aims at emission reductions 

by 13% in 2005 and 30% in 2010 (baseline 2000). The increased focus on emissions has led 

to less leakage during production and use. Emissions from electrical equipment were almost 

halved from 2000 to 200588. 

 

85 http://www.environment.gov.au/atmosphere/ozone/sgg/index.html (last checked on 7 September 

2010). 

86 Association of Home Appliance Manufacturers and US EPA 2005: Recommended practices for 

minimizing HFC emissions from refrigerator-freezer factories. 

87 Air conditioning and Refrigeration Institute and US EPA: Responsible use guide for minimizing 

fluorocarbon emissions in manufacturing facilities. 

88 Statistics Norway/ Department of Economic Statistics, Environmental Statistics, Katherine Loe 

Hansen 2008: Emissions from consumption of HFCs, PFCs and SF6 in Norway. 
Chapter 3 F-gas markets and policies 61 

3.2.5 Norms and standards 

A standard is a technical document designed to be used as a rule, guideline or definition, and

standardization is the voluntary process of developing technical specifications based on 

consensus among all interested parties (industry including Small and Medium-sized 

Enterprises, consumers, trade unions, NGOs, authorities, etc).89 Therefore standards are 

here considered to be voluntary but can become mandatory when referred to by national or 

European legislation. 

For all sectors relying on F-gases a number of international, European and national 

standards exist. Although they are voluntary to use and do not impose any regulation, in 

practice many governments, industry groups and trade associations require products or 

services to adhere to a standard before they can be placed on the market. 

A European Standard automatically becomes a national standard in all Member States, but 

remains voluntary to use. Through the development of European standards and the 

withdrawal of conflicting national standards, standardization has played a leading role in the 

achievement of a Single Market for goods. European Standards are highly important for 

manufacturers inside and outside Europe as they increase product safety and quality and 

lower transaction costs and prices. A standard codifies best practice and is usually state of 

the art relating to products, services or systems. 

Products and equipment relying on F-gases are addressed by various international, 

European and national standards, which set out specifications, performance requirements, 

and safety measures. Standards relating to the control of F-gas emissions exist at 

international, European and national level. For simplification, the following overview mostly 

refers to EU level as examples. Standards are relevant in the following sectors so far: 

Refrigeration and air conditioning: The main standard for refrigeration systems and heat 

pumps is the norm EN 37890 which includes safety and environmental requirements for all 

refrigeration air conditioning and heat pump equipment (domestic, commercial, industrial). 

Other standards apply to certain sub sectors or specific topics only, for example: 

- EN 60335-2-4091 set out safety requirements for any air conditioning and heat pump 

appliances. 

- EN 60335-2-8992 specifies safety requirements for electrically operated commercial 

refrigerating appliances that have an incorporated compressor or that are supplied in 

two units for assembly as a single appliance in accordance with the manufacturer's 

instructions (split system). Appliances in scope of this standard include refrigerated 

display and storage cabinets, refrigerated trolley cabinets, service counters and selfservice counters, blast chillers and blast freezers. 

 

89 European Commission: European standardization policy, 2010; 

http://ec.europa.eu/enterprise/policies/european-standards/standardisation-policy/index_en.htm 

90 EN 378: Parts 1-4 Refrigerating systems and heat pumps – safety and environmental requirements 

(2008). 

91 EN 60335-2-40: Household and similar electrical appliances - Safety - Part 2-40: Particular 

requirements for electrical heat pumps, air conditioners and dehumidifiers. 

92 EN 60335-2-89: Household and similar electrical appliances - Safety - Part 2-89: Particular 

requirements for commercial refrigerating appliances with an incorporated or remote refrigerant unit or 

compressor (2010). 
Chapter 3 F-gas markets and policies 62 

- EN 1331393 specifies activities related to the refrigeration circuits of equipment and 

associated competence profiles. It also establishes procedures for assessment of the 

competence of personnel and could thus serve as input for personnel certification 

schemes in the Member States (see chapter 4). 

- EN 1608494 specifies qualifications for the tightness of joints and components. 

Foams: Standards are specific to particular types of foams and define performance criteria. 

Important standards in this sector include for example: 

- EN 1316595 defines quality requirements for factory-made rigid PU foam panels which 

are mostly used to insulate flat roofs, ceilings, floors and walls as well as in lowenergy houses. 

- EN 1431596 applies to spray foam and sets out specifications for the foam before 

installation and after. 

- EN 1316497 sets out specifications for XPS foam products. 

High voltage switchgear: Existing standards introduced maximum leakage rates for medium 

and high voltage electric power equipment and instrument transformers. In this way, 

awareness of equipment manufacturers has been raised and has lead to significant emission 

reductions previous to the F-gas Regulation. Important standards include: 

- IEC 62271-198 defines maximum leakage rates: For closed pressure systems, which 

refers to modern high voltage electric power equipment, standardized leakage rates 

amount to 0.5% and 1% per year and per gas filled compartment. For sealed 

pressure systems, mostly modern medium voltage electric power equipment, 

tightness is specified for their expected operating life as defined by the manufacturer 

in order to avoid refill. The leakage rate of these systems is considered <0.1% per 

year (“sealed for life”). 

- IEC TR 62271-30399 defines tightness classes of equipment by referring to IEC 

62271-1. 

- IEC 61869-1100 enters into force in 2012, applies to newly manufactured instrument 

transformers and defines the leakage rate of SF6 transformers as <0.5% per year. 

- Two standards refer to the quality of SF6: IEC 60376 indicates that the gas is new and 

IEC 60480 set out that the gas is recycled and minimum specifications apply. 

 

93 EN 13313: Refrigeration systems and heat pumps – Competence of personnel (2010). 94 EN 16084: Refrigeration systems and hear pumps – Qualification of tightness of components and 

joints (2010). 

95 EN 13165 Thermal insulation products for buildings - Factory made rigid polyurethane foam (PUR) 

products. Specification (2009).

96 EN 14315 Thermal insulating products for buildings – In-situ formed sprayed rigid polyurethane 

foam (PUR) products – Part 1: Specification for the rigid foam spray before installation. Part 2: 

Specification for the installed insulation products. 

97 EN 13164 Thermal insulation products for buildings- Factory made extruded polystyrene foam 

(XPS) products– Specification. 

98 IEC 62271-1 Common specifications. 99 IEC TR 62271 High voltage switchgear and controlgear – Part 303: Use and handling of sulphur 

hexafluoride (SF6) (2008). 100 IEC 61869 Instrument transformers – Part 1: General requirements. 
Chapter 3 F-gas markets and policies 63 

Fire protection: Standards anticipated important containment measures in this sector such as 

leakage checks and records, set maximum leakage rates for certain types of containers and 

give specifications of leakage detection systems. Relevant standards include: 

- ISO 14520 requires regular leakage checks and service records to be maintained by 

the service companies since 2000. 

- EN 12094-4101 sets a maximum leakage rate of 0.5% of the mass contents on the 

smallest cylinder and fill when cycled between -20°C and +50°C over 102 days. EN 

12094-10102 is relevant for systems using a cylinder low pressure switch. 

- The standard EN 15004 came out in 2008. EN 15004-1103 relates to design, 

installation and maintenance of fixed gas extinguishing systems. EN 15004-4104 refers 

to fire fighting systems and leakage detection systems for HFC-125 extinguishant; EN 

15004-5105 refers to fire fighting systems and leakage detection systems for HFC227ea extinguishant; EN 15004-6106 refers to fire fighting systems and leakage 

detection systems for HFC-23 extinguishant. 

Standards can support reductions of F-gas emissions by transferring best practices to 

markets and thereby replacing previous technologies and methods. Regulatory mechanisms 

often refer to existing standards, which anticipated legislation, e.g. Article 3(5) of the F-gas 

Regulation refers to the ISO 14520 standard. 

With regard to flammable refrigerants, it should be noted that international standards limit the 

charge sizes for equipment placed in occupied spaces (e.g. IEC and EN 60335-2-24107 set 

the maximum charge for hydrocarbon refrigerants in domestic refrigeration at 150 g)108. 

Furthermore, national standards might set bans in certain cases, e.g. in France the use of 

flammable refrigerants in public buildings is not allowed due to local building and fire safety 

standards. 

While standards play an important role for safe handling of F-gases, their alternatives and 

product safety within Europe and in the world, analyses of the impact of particular norms and 

standards on F-gas emissions from certain appliances are not known and have not been 

carried out in the context of this project. 

Aspects where implications of standards are taken into account include: 

 

101 EN 12094 Fixed fire fighting systems – Part 4: Components for gas extinguishing systems. 

Requirements and test methods for container valve assemblies and their actuators (2004). 

102 EN 12094 Fixed fire fighting systems - Components for gas extinguishing systems - Part 10: 

Requirements and test methods for pressure gauges and pressure switches (2003). 

103 EN 15004 Fixed firefighting systems - Gas extinguishing systems – Part 1: Design, installation and 

maintenance (ISO 14520-1:2006, modified). 

104 EN 15004 Fixed firefighting systems - Gas extinguishing systems – Part 4: Physical properties and 

system design of gas extinguishing systems for HFC-125 extinguishant (ISO 14520-8:2006, modified). 

105 EN 15004 Fixed firefighting systems - Gas extinguishing systems – Part 5: Physical properties and 

system design of gas extinguishing systems for HFC-227ea extinguishant (ISO 14520-9:2006, 

modified). 

106 EN 15004 Fixed firefighting systems - Gas extinguishing systems – Part 6: Physical properties and 

system design of gas extinguishing systems for HFC-23 extinguishant (ISO 14520-10:2005, modified). 

107 IEC and EN 60335-2-24: Household and similar electrical appliances – Safety – Part 2-24: 

Particular requirements for refrigerating appliances, ice-cream appliances and ice-makers. 

108 Chapter 6 takes existing standards into account. Also see explanations for particular sectors in 

annex IV: Global DIS, and annex V: EU sector sheets. 
Chapter 3 F-gas markets and policies 64 

- Additionality of measures required by the F-gas Regulation and related additional 

costs for operators of equipment (chapter 4.3) 

- Selection of abatement options: Charges of flammable substances as alternatives to 

F-gases (chapter 6 and related annexes). 

3.2.6 Impact of policies addressing F-gas emissions

Since most ozone depleting substances are also potent greenhouse gases, the phase out of 

ODS under the Montreal Protocol has contributed largely to reducing global GHG emissions. 

It is estimated that the decrease of annual ODS emissions under the Montreal Protocol range 

around 10 Gt CO2 eq of avoided global warming emissions annually. These emission 

reductions were about five times larger than the annual emission reduction target for the first 

commitment period of the Kyoto Protocol (2008-2012).109 

In contrast to the success of the Montreal Protocol, international efforts under the Kyoto 

Protocol only had limited impact on F-gas emissions. 

In developing countries, emission reductions being achieved through CDM projects on Fgases in the first commitment period (2008-2012) amount to <5 Gt CO2 eq in total, largely 

(>90%) resulting from HFC-23 destruction projects. JI projects yield emission reductions of 

ca 12 Mt CO2 eq during the same period which are also caused by HFC-23 destruction to 

large extent. Regulatory action aiming at monitoring and reducing HFC, PFC and SF6 use 

and emissions were identified in several developed countries and contribute to specific GHG 

emission reduction targets under the UNFCCC/Kyoto Protocol. It should be pointed out that 

Europe has established, worldwide, the only comprehensive regulatory framework 

addressing use and emissions of HFCs, PFCs and SF6 from various sectors and at different 

stages of equipment lifetime. 

Voluntary approaches by industry were found to complement or replace regulatory action in 

some countries and sectors and contribute to global F-gas emission reductions. In some 

sectors, the identified voluntary approaches preceded provisions of the F-gas Regulation 

(e.g. leak checks in fire protection) and in other sectors they continue to be the only type of 

measure addressing F-gas emissions (e.g. PFC emissions from semiconductor industry). 

Voluntary approaches can allow for flexible and adjusted adaptation to technological options 

and market sensitivities110 and are sometimes taken to anticipate regulatory action. However, 

voluntary agreements are self-regulatory practices and are not legally binding at Community 

level. Furthermore, voluntary approaches are often considered to lack transparency, 

ambition, legitimacy and efficacy. Major drawbacks include limited participation, lack of 

independent control of compliance and enforcement (lack of consequences in case of noncompliance) and the rather industry-centered perspective111. 

Voluntary agreements hence need to be considered a rather “soft” instrument to raise 

general awareness and address sectors not covered by mandatory regulation. Voluntary 

approaches are estimated too weak if emission reduction targets and compliance with 

international commitments need to be achieved. 

 

109 WMO/UNEP 2010: Scientific Assessment of Ozone Depletion: 2010, p.3. 110 European Commission: http://ec.europa.eu/energy/efficiency/agreements_en.htm (last checked on 

08.03. 2011). 

111 European Consumers’ Organisation 2006: Voluntary Environmental Agreements. 
Chapter 3 F-gas markets and policies 65 

3.3 Interactions of other policies with EU F-gas policy 

framework 

The identification and analysis of interactions, complementarities and overlaps between EU 

F-gas policy and other European policies focuses on regulatory measures, since they usually 

represent the most important type of instrument at European level. 

It should be noted that the national implementation of other European policies might be 

stricter than the European legislation and cause additional interactions, complementarities 

and overlaps. However, such interactions at national level were not investigated within this 

study due to large differences between Member States and even regions within Member 

States (e.g. in Belgium). 

The list of policies does not intend to give a complete overview of all regulatory measures 

relevant in the context of F-gases but aims to identify the key interactions to the extent 

possible. 

3.3.1 ODS policy

• General links

Under the Vienna Convention, the Montreal Protocol on ozone depleting substances is 

closely linked to F-gases. Since 1981, it controls production and consumption of ozone 

depleting substances (ODS). Presently, the regulations apply to 96 chemicals including 

chlorofluorocarbons (CFCs), halons, hydrobromofluorocarbons (HBFCs), 

hydrochlorofluorocarbons (HCFCs), and others. The phase out of fluorinated ozone depleting 

substances such as CFCs and HCFCs in developed countries (“A2 countries”) and 

developing countries (“A5 countries”) under the Montreal Protocol has globally created 

demand for substitutes. HFCs were developed as replacements for ODS to be used in the 

same sectors of application and are being produced and marketed on large scale since the 

early 1990s (see chapter 3.1). Therefore, the Montreal Protocol has highly influenced global 

HFC emissions. 

ODS policy at international and European level is aiming at ozone layer protection through 

phase out of ozone depleting substances. In addition, the EU legislation is also aiming at 

emission reduction. As most ODS also show high global warming potential, the Montreal 

Protocol has significantly contributed to both ozone layer and climate protection. 

The ODS Regulation (EC) No 1005/2009 (replaced (EC) No 2037/2000) is implementing the 

Montreal Protocol and has certainly contributed to raise general awareness and improve 

capacities of personnel and companies through training measures. As usually the same 

companies deal with both ODS and F-gases, ODS policies now also support F-gas policies 

as awareness of service personnel and manufacturers for the environmental impact of their 

activities had increased already. 

The ODS Regulation (Article 23) requires leakage control of stationary equipment or systems 

to be undertaken at specific frequencies based on fluid charges (Table 3-10), which is quite 

similar to the scheme set out by the F-gas Regulation (Article 3). The installation of leakage 

detections systems, however, is not mandatory under the ODS Regulation.The remaining 
Chapter 3 F-gas markets and policies 66 

HCFC systems have to be replaced in the coming years due to the prohibition to use 

recovered HCFC for their maintenance, effective as of 1 January 2015. 

Table 3-10: Overview of requirements of Regulation (EC) No 1005/2009 and Regulation (EC) No 

842/2006 with regard to regular leakage control of stationary equipment and systems 

Frequency of leak ODS F-gases 

checking required 

by regulations 

System charge 

Normal 

System charge 

Hermetically 

sealed 

System charge 

Normal 

System charge 

Hermetically 

sealed 

None <3 kg <6 kg <3 kg <6 kg 

Annually 3 kg – 30 kg 6 kg – 30 kg 3 kg – 30 kg; 

30 kg – 300 kg 

if automatic leak 

detection system 

in place 

6 kg – 30 kg; 

30 kg – 300 kg 

if automatic leak 

detection system 

in place 

6 monthly 30 kg – 300 kg 30 kg – 300 kg 30 kg – 300 kg; 

>300 kg if 

automatic leak 

detection system 

in place 

30 kg – 300 kg; 

>300 kg if 

automatic leak 

detection system 

in place 

Quarterly >300 kg >300 kg >300kg >300kg 

In contrast to the F-gas Regulation, which does not set a time limit for the repair of detected 

leakage, under the ODS Regulation, detected leakage has to be repaired as soon as 

possible and in any event within 14 days. 

ODS recovery and destruction by approved technologies are required by Article 22, which 

refers to refrigeration, AC, heat pump and fire protection equipment, equipment containing 

ODS solvents as well as products containing ODS, such as foams. This provision thus 

supports the management of foams containing ODS while the F-gas Regulation does not 

specify recovery of HFCs from foams. 

Recording requirements under the ODS Regulation (Article 23(2)) differ from provisions of 

the F-gas Regulation as records do not include the quantity and type of refrigerants installed 

in stationary refrigeration, air conditioning and heat pump equipment and systems. Labelling 

requirements pursuant to Article 11(6), however, do include these data. 

The Montreal Protocol also sets out reporting obligations relevant for the sectors relying on 

F-gases, since F-gases are often used as substitutes for ODS. Reporting requirements 

include data on annual production, imports and exports of ODS, including quantities of the 

feedstock production, and the amounts of ODS destroyed through approved technologies. 

As CFC and HCFC phase-out are largely completed in Europe, reporting obligations are 

assumed to refer nowadays mostly to amounts of HCFCs produced for export, for feedstock 

and other exempted use (i.e. essential laboratory and analytical uses and critical uses of 

halons) and the quantities of ODS that were destroyed. The ODS Regulation implements the 

reporting requirements under the Montreal Protocol at European level through even stricter 

provisions. Article 26 requires annual reporting by the Member States to the Commission. 

The information to be submitted relates to the quantities of methyl-bromide authorized and 

halons installed, as well as to cases of illegal trade of ODS. 

Article 27 imposes reporting requirements on undertakings which have to submit a list of data 

on each controlled substance and each new substance to the Commission and the 

competent authority of the Member State concerned. The data to be reported vary depending 
Chapter 3 F-gas markets and policies 67 

on the type of undertaking. For example, producers must report quantities produced, placed 

on the market, as well as quantities recycled, reclaimed and destroyed, and stocks. 

Undertakings in the ODS database that did not produce, import, export or destroy ODS in the 

previous year are required to return a “nil” form. The recasted ODS regulation (EC) No 

1005/2009 also introduced new requirements for destruction plants to report ODS quantities 

destroyed directly to the European Commission, including quantities contained in products or 

equipment. 

• Implications

As many measures of ODS policy and F-gas policy (e.g. awareness raising, training, 

certification) affect the same companies active in service and destruction, further 

streamlining and synergies should be explored in order to build on previous experience. 

Reclamation and destruction of ODS and F-gases often take place in the same facilities or 

companies. Reporting requirements for ODS destruction could be extended to F-gases in 

order to gain information on the effectiveness of provisions on F-gas recovery and recycling 

and related disposal emissions. 

With regard to the policy options explored, this could apply inter alia to reporting obligations 

for destruction plants on the quantities destroyed. 

3.3.2 Waste policy

In the context of recovery, recycling, reclamation, destruction (RRRD) of F-gases and 

products and equipment containing F-gases, links between the F-gas Regulation and waste 

policy are to be noted. 

Article 4 of the F-gas Regulation requires operators of stationary equipment to arrange 

proper recovery of fluorinated greenhouse gases by certified personnel in order to ensure 

recycling, reclamation or destruction of F-gases. The stationary equipment in scope of this 

provision includes cooling circuits of refrigeration, air conditioning and heat pump equipment, 

equipment containing F-gas based solvents, fire protection systems and fire extinguishers as 

well as high voltage switchgear. It also applies for the recovery of residual F-gases in end-of 

life containers where technically feasible and other products and equipment, including mobile 

equipment (unless serving military operations). Article 4 applies to all equipment and 

products covered irrespective of the quantity of fluorinated greenhouse gas they contain. 

• General links

The new legal framework on waste, Directive 2008/98/EC on waste, which entered into 

force in December 2010 (previously Directive 2006/12/EC) addresses the whole waste cycle 

and emphasizes the role of recovery and recycling. Member States are required to ensure 

waste recovery, and to collect waste separately “if technically, environmentally, and 

economically practicable”, and to not mix it with other waste or material with different 

properties (Article 10). Measures to “promote high quality recycling” and “separate collections 

of waste where technically, environmentally and economically practicable and appropriate to 

meet the necessary quality standards for the relevant recycling sectors” shall be taken 

(Article 11). 
Chapter 3 F-gas markets and policies 68 

The definition of waste112 is clearly met by recovered F-gases which are no longer needed 

and cannot be recycled or reclaimed. In contrast, this definition is not met for F-gases subject 

to recycling and reclamation. However, used bulk HFCs is considered hazardous waste in 

the Waste List Decision 2000/532/EC. In most cases used SF6 intended to be reclaimed is 

considered as a product while only SF6 intended for destruction is deemed to be waste. 

Directive 2008/98/EC requires recovery of 70% of construction and demolition waste by 2020 

(by weight). This will have implications for the treatment of construction foam, which is 

currently not known to be typically separated from other materials at end of life. Separating 

foams containing ODS/F-gases at demolition of buildings and ensuring proper recycling or 

destruction is estimated to present significant challenges, in particular in cases where the 

type of blowing agent in the insulating foam is not discernable.113 Compared to appliance 

foam, construction foams have lower levels of recovery potential due to higher annual 

emission rates, longer lifetime and higher losses of blowing agent during separation and 

removal114. 

According to the Waste Framework Directive, requirements for the management of 

hazardous waste include control of hazardous waste and traceability from production to final 

destination (Article 17), the prohibition to mix hazardous waste with other categories of 

hazardous waste or other waste, substances or materials, which bans diluting of hazardous 

substances (Article 18), special labelling requirements (Article 19), as well as the 

maintenance of records and their storage for a certain time period (Article 35). 

Recovered F-gases for reclamation need to be declared as hazardous waste although they 

will be recycled or reclaimed. In addition, for transportation of recovered F-gases classified 

as hazardous waste further provisions apply, e.g. under Regulation (EC) No 1013/2006 on 

shipments of waste. These become particularly relevant in case Member States without 

reclamation and destruction facilities intend to export used F-gases for reclamation and/or 

destruction purposes to other Member States. In the case of Poland, national legislation is 

known to not treat recovered F-gases intended for reclamation as waste, which facilitates 

their handling as restrictions for hazardous do not apply. Recovered substances are only 

considered waste if reclamation is not possible due to low purity. 

Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances 

and mixtures (CLP Regulation) standardizes criteria for classification of substances and 

mixtures and requires the labelling of hazardous substances at manufacture, import and use. 

The Regulation aims to ensure protection of human health and the environment as well as 

the free movement of substances, mixtures and articles. Since waste is excluded from the 

scope of this Regulation (Article 1(3)), provisions do not apply to recovered F-gases for 

disposal. Nevertheless, it applies to F-gases for recycling and reclamation, as well as virgin, 

recycled and reclaimed gases and mixtures. The regulation makes use of two tools for the 

communication of hazards of substances and mixtures provided for in Regulation (EC) No 

1907/2006 (REACH Regulation): labels and safety data sheets. 

 

112 Article 3(1) of the Waste Framework Directive: “Waste” means any substance or object which the 

holder discards or intends or is required to discard. 

113 ICF International: Identifying and Assessing Policy Options for Promoting the Recovery and 

Destruction of Ozone Depleting Substances (ODS) and Certain Fluorinated Greenhouse Gases 

(Fgases) Banked in Products and Equipment; Final Report prepared for the European Commission, 

May 2010; p.37. 

114 ICF International, ibid, p.39. 
Chapter 3 F-gas markets and policies 69 

Since, as identified later in this report (chapter 4.2.6), reclamation and destruction facilities 

for ODS and F-gases are lacking in several Member States, used bulk F-gases and waste 

electrical and electronic equipment containing F-gases are shipped across borders. 

Therefore, at international level, a link to the Basel Convention on the control of 

transboundary movements of hazardous wastes and their disposal should be noted (see 

section 3.2). Discarded equipment containing CFCs, HCFCs, and HFCs is covered under the 

convention (Annex V). 

Regulation (EC) No 1013/2006 on shipments of waste transposes the Basel Convention

by establishing procedures and control regimes for the shipment of waste between Member 

States, within EU-27 or via third countries, for the import and export of waste in/from EU-27 

and for waste on transit through the Community. As all HFCs (including those contained in 

equipment) for disposal are considered and treated as hazardous waste (Title II, Art 3(1) b 

iii.), their shipment has to be based on prior written notification and consent. 

In addition to waste policies already mentioned, special links between the F-gas Regulation 

and waste policies appear for equipment and products containing F-gases and bulk F-gases 

recovered from products and equipment. 

• Links for equipment and products containing F-gases 

Two pieces of waste legislation need to be noted such as the WEEE Directive and the ELV 

Directive. 

Directive 2002/96/EC on waste electrical and electronic equipment (WEEE Directive, as 

amended) addresses large and small household appliances, including household 

refrigeration and AC appliances, and small commercial refrigeration equipment containing 

ODS or gases with GWP >15. It requires treatment before disposal of waste household 

appliances and small commercial refrigeration equipment, separate collection and treatment 

of ODS in accordance with Regulation (EC) No 1005/2009, as well as treatment of refrigerant 

and foam contained in appliances. 

The WEEE Directive is linked to the F-gas Regulation as it refers to equipment containing 

gases with GWP >15. All fluorinated gases subject to the F-gas Regulation have higher 

GWPs. The provisions of both legislative acts hence overlap with regard to recovery of F-gas 

refrigerants from domestic refrigeration, air conditioning and heat pump equipment. The Fgas Regulation complements the provisions of the WEEE Directive by introducing 

qualification requirements for personnel115. 

The WEEE Directive goes beyond the provisions of the F-gas Regulation since it requires, in 

its Annex on selective treatment, foams used as insulation material in domestic and small 

commercial refrigeration appliances to be treated. Recovery of F-gases used as blowing 

 

115 Commission Regulation (EC) No 303/2008 explains the special requirements for qualification of 

personnel undertaking recovery of F-gases from equipment covered by the WEEE Directive and 

containing charges <3 kg. If personnel 

- is undertaking recovery in premises covered by a particular permit for WEEE treatment and 

- is employed by the company holding the permit and 

- have completed a training course according to Category III verified by an attestation of 

competence issued by the permit holder, 

other certification requirements of the Regulation do not apply. It is explained that the level of 

qualification for personnel recovering refrigerant in plants for WEEE treatment is lower compared to 

that needed by personnel carrying out in-site recovery, because of the type of automated recovery 

equipment available in such plants. 
Chapter 3 F-gas markets and policies 70 

agents is not required by provisions under Article 4 of the F-gas Regulation. However, the 

labelling provisions of the F-gas Regulation (Article 7) support recovery and proper treatment 

of F-gas insulation foams as they require marking equipment with a label saying “foam blown 

with fluorinated greenhouse gases”, which applies to refrigeration equipment when such 

equipment also contains F-gas refrigerants. 

Although the WEEE Directive and the F-gas Regulation have been coexisting for some 

years, few quantitative data on their combined impact in terms of waste management and 

related emission reductions of ODS and F-gases are available. 

In the model AnaFgas, it is assumed that the disposal emission factor of the sectors covered 

under the WEEE Directive will decrease as recovery efficiency increases (chapter 2). As for 

decommissioning facilities, the costs for personnel certification are also taken into account. 

Directive 2000/53/EC on end-of life vehicles (ELV Directive) requires Member States to 

ensure that end-of-life vehicles are dismantled and hazardous materials are removed (Art 6). 

Air conditioning system fluids must be removed, collected and stored separately before the 

vehicle is shredded (Annex I, Art 6). The directive also requires recovery of foams at end of 

life for proper disposal. 

The ELV Directive is linked to the F-gas Regulation as it requires recovery of refrigerants (i.e. 

HFC-134a) from air conditioning systems contained in end of life vehicles. This provision 

partly overlaps with Article 4 of the F-gas Regulation which requires F-gases contained in 

mobile equipment unless it is serving military operations to be recovered by appropriately 

qualified personnel116 “to the extent that it is technically feasible and does not entail 

disproportionate cost” in order to ensure recycling, reclamation or destruction. The F-gas 

Regulation exceeds the scope of the ELV Directive since it requires recovery not only at end 

of life but also during servicing and maintenance. By introducing qualification requirements 

for recovery of F-gases from AC systems contained in passenger cars, the F-gas Regulation 

complements the provisions of the ELV Directive in order to minimise F-gas emissions during 

recovery. 

Another provision on recovery of foams from ELV vehicles usually does not interact with the 

F-gas Regulation since most types of foam currently used in automotive industry do not 

contain F-gases. 

So far, no quantitative data on the combined impact of the ELV Directive and the F-gas 

Regulation or the MAC Directive on emission reductions exist117. 

For future management of F-gas banks contained in equipment, experiences from 

environmentally sound management of ODS banks under the Montreal Protocol should be 

considered in order to identify further potentials for streamlining legislation and management 

processes. 

 

116 Minimum requirements for training programmes and attestation of personnel recovering certain 

fluorinated greenhouse gases from air conditioning systems in motor vehicles falling within the scope 

of Directive 2006/40/EC are set out by Commission Regulation (EC) No 307/2008.

117 This might partly be due to the fact that used passenger cars at the end of their registered lifetime 

in one Member State are often exported to other Member States or out of EU-27 and used as second 

hand cars for some more years. 
Chapter 3 F-gas markets and policies 71 

• Links for bulk F-gases recovered from products and equipment: 

When servicing of equipment is undertaken on-site and the recovered F-gas is not suitable 

for recycling, the gas should be collected and stored in special containers for subsequent 

reclamation or destruction. Only small quantities of F-gases are reclaimed since they need to 

be sorted by type and reclamation of blends is technically complicated (see chapter 4.2.6 on 

RRRD). For servicing companies it is often impractical to store small quantities of recovered 

F-gases separated by type. Therefore, most recovered F-gases not suitable for on-site 

recycling are mixed and considered waste. 

• Implications

Recovery for recycling, proper reclamation and destruction of F-gases by certified personnel 

according to Article 4 of the F-gas Regulation is not explicitly promoted by current definitions 

and provisions of European waste legislation. Small contractors in the refrigeration and air 

conditioning sector are not incentivized to undertake recovery for proper reclamation and 

destruction since collection, transport, storage and eventual shipment of used F-gases 

classified hazardous waste result in costs and effort for servicing companies. 

Existing legislation for the management of F-gases contained in domestic appliances as well 

as air conditioning systems of end of life vehicles preceded and now complements the F-gas 

Regulation. However, data on waste streams in these sectors are rare or not available for 

EU-27. 

While considering the benefits of the horizontal approach of European waste legislation, a 

general lack of information on current waste management practices with regard to F-gas 

reclamation and destruction needs to be stated. Large quantities of used F-gases are 

presumably not collected separately for treatment and/or not treated in specialized facilities. 

3.3.3 Climate & energy and industrial emissions policies

Strong links between climate and energy policies and the EU F-gas policy have been 

identified and might impact F-gas emissions. 

• General links

Parties to the United Nations Framework Convention on Climate Change (UNFCCC)

must submit national reports on the implementation of the Convention to the Conference of 

the Parties (COP). The required contents of national communications and the timetable for 

their submission are different for Annex I (developed countries) and non-Annex I Parties 

(developing countries). 

By 15 April each year, Annex I Parties must provide annual national GHG inventories 

covering emissions and removals of direct GHGs (including CO2, CH4, N2O, HFCs, PFCs, 

SF6) from several sectors118 and for all years from the baseline to the most recent year. 

Inventory submissions are divided in two parts: the Common Reporting Format (CRF) which 

includes standardized data tables, and the National Inventory Report (NIR), a comprehensive 

description of the results, applied methodology, the data sources etc. 

 

118 These sectors include the following main source categories: Energy, Industrial Processes, Solvent 

and Other Product Use, Agriculture, Land-Use Change and Forestry, Waste, Other, CO2 emissions 

from Biomass, International bunkers and Multilateral Operations. F-gas emissions are to be reported 

from the sector “industrial processes”. 
Chapter 3 F-gas markets and policies 72 

In addition to the annual inventories, Annex I Parties are also required to submit national 

communications periodically. Annex I Parties to the UNFCCC that have also ratified the 

Kyoto Protocol must include supplementary information in their national communications and 

annual inventories to demonstrate compliance with the Protocol’s commitments. 

Commitments made by the EU (see chapter 3.2) result in the need for monitoring and regular 

assessment of greenhouse gas emissions in the EU. Decision 280/2004/EC concerning a 

mechanism for monitoring Community greenhouse gas emissions and for 

implementing the Kyoto Protocol119 represents the basis for the compilation of the EC 

inventory in accordance with the UNFCCC and Kyoto Protocol, which includes emissions of 

HFCs, PFCs and SF6. Although each of the Member States is preparing GHG emission 

inventories in order to fulfil reporting obligations to the UNFCCC, the information gained 

through the reporting of production, import and export of F-gases according to Article 6 of the 

F-gas Regulation can rarely be linked to the information contained in the inventories (see 

chapter 2). Article 6(4) of the F-gas Regulation aims to address this problem by requiring 

Member States to establish monitoring systems for F-gas emissions. 

Furthermore, Directive 2008/1/EC concerning integrated pollution prevention and 

control (IPPC Directive) requires industrial and agricultural activities with a high pollution 

potential to have a permit. This permit can only be issued if certain environmental conditions 

are met. Hence companies are obliged to take responsibility for preventing and reducing 

pollution they may cause. The decision to issue a permit contains certain specific 

requirements including also the monitoring of substances released. Emission Limit Values 

(ELVs) for pollutants are based on best available techniques (BATs120), which take into 

account the balance between costs and environmental benefits. 

In 2010, the Council of the EU adopted Directive 2010/75/EU on industrial emissions 

(integrated pollution prevention and control) (Recast) (the IED).121 The IED recasts seven 

existing Directives related to industrial emissions, including the Directive concerning 

integrated pollution prevention and control (IPPC), into a single and coherent legislative 

instrument. Currently, around 50,000 installations are covered by existing industrial 

emissions legislation in sectors like metal production, chemical manufacture, poultry and pig 

farming, waste incineration and large combustion plants. 

The Directive does not set standards or thresholds for the prevention or control of emissions, 

or other environmental aspects, but requires Member States to refer to Best Available 

Techniques (BATs) conclusions, which form a part of BAT reference documents (BREFs), for 

setting permit conditions. Furthermore, Article 15 of the Directive requires emission limit 

values set in permits to be set at a level that ensures that emissions from the installation are 

in line with the BAT Associated Emission Levels provided in the BAT conclusions. Deviations 

from these levels are only permitted when local and technical characteristics would make it 

disproportionally costly. BREFs and BAT conclusions under IED are given a clear role in the 

setting of permit conditions and, in particular, the setting of emission limit values. 

 

119 Decision 280/2004/EC is currently under revision. 120 BAT are defined as “the most effective and advanced stage in the development of activities and 

their methods of operation which indicate the practical suitability of particular techniques for providing 

in principle the basis for emission limit values designed to prevent and, where that is not practicable, 

generally to reduce emissions and the impact on the environment as a whole”. 

121 OJ L334, 17.10.2010, p. 17. 
Chapter 3 F-gas markets and policies 73 

Emission limit values refer to polluting substances with the exception of greenhouse gases if 

the emission trading scheme applies. A permit issued in compliance with the IED is hence 

not obliged to contain emission limit values for greenhouse gases if these are subject to an 

emission trading scheme and provided that there is no local pollution problem. Hence 

emissions from aluminium industry could be addressed through BREFs but PFC emissions 

would not be in the focus of the permit as they will be included in the EU-ETS from 2013. 

Currently, several BREFs address industries relevant in the context of F-gases: 

“Smitheries and Foundries”122 (05.2005; review in 2012): Special attention is given to the 

melting process of magnesium which relies on the use of SF6 and SO2 cover gases to 

prevent the oxidation (or burning) of molten magnesium. Since SF6 is more easily to handle 

than the toxic SO2, it became the preferred cover gas after its introduction in the mid 1970s. 

The BREF states that BAT is to use SO2 as a covering gas for magnesium melting in 

installations with an annual output of >500 t, regardless of whether the plant is to be newly 

built or still runs with SF6 (p.183). For small plants (<500 t Mg parts output/year) BAT is to 

use SO2 or to minimize the use of SF6. In the case where SF6 is used, the BAT associated 

consumption level is <0.9 kg/t casting for sand casting and <1.5 kg/t casting for pressure diecasting (Executive Summary, p. ix). The BREF also states that alternative cover gases to 

replace SF6 such as HFC-134a and Novec612 had been developed and tested but had not 

found industrial implementation so far (p. 334). This information is outdated123 with respect to 

HFC-134a and is likely to be changed during the review process of the BREF. 

“Non-Ferrous Metal Industries” (12.2001, review ongoing) also recommends replacing SF6

as cover gas in magnesium industry (p. 596; 612) and refers to the Foundries BREF. 

“Energy Efficiency”124 (02.2009) follows a horizontal approach and thus addresses all IPPC 

sectors. The general BAT are intended to serve as reference point against which to judge the 

current performance of an existing installation or to judge a proposal for a new installation (p. 

269). The BREF underlines that heat pumps rely on refrigerants with greenhouse gas 

emissions in case of leakage or at decommissioning (p. 171). In the same sense and with 

regard to large scale chilling systems, it is highlighted that the refrigerants should not only 

have zero ozone-depleting potential, but also low global warming potential and lower energy 

demand in use (p. 307). 

It should be noted that the BREF on “Industrial cooling systems”125 (12.2001; review in 

2011) excludes industrial refrigeration with refrigerants and therefore is not relevant. 

 

122 European Commission: Integrated Pollution Prevention and Control – Reference Document on the 

Application of Best Available Techniques in the Smitheries and Foundries Industry, May 2005. 

ftp://ftp.jrc.es/pub/eippcb/doc/sf_bref_0505.pdf 

123 Öko-Recherche 2009: Service contract to assess the feasibility of options to reduce emissions of 

SF6 from the EU non-ferrous metal industry and analyse their potential impacts; Final Report, 

prepared for the European Commission. 

124 European Commission: Integrated Pollution Prevention and Control – Reference Document on the 

Application of Best Available Techniques for Energy Efficiency, February 2009. 

ftp://ftp.jrc.es/pub/eippcb/doc/ENE_Adopted_02-2009.pdf 

125 European Commission: Integrated Pollution Prevention and Control – Reference Document on the 

Application of Best Available Techniques to Industrial Cooling Systems, December 2001. 

ftp://ftp.jrc.es/pub/eippcb/doc/cvs_bref_1201.pdf 
Chapter 3 F-gas markets and policies 74 

With regard to the different industrial sectors emitting F-gases, permits are required e.g. for 

aluminium manufacturing facilities (PFC emissions), semiconductor industry facilities (PFC, 

SF6, NF3 emissions) and halocarbon production facilities (HFC-23 emissions). 

In the context of pollution control, Regulation (EC) No 166/2006 on the establishment of a 

European Pollutant Release and Transfer Register (PRTR) should be mentioned. This 

regulation implements the UNECE Convention on Access to Information, Public Participation 

in Decision-making and Access to Justice in Environmental Matters (Aarhus Convention), 

which was signed by the EC in 1998, and the UNECE Protocol on Pollutant Release and 

Transfer Registers, signed in 2003. It requires operators of certain industry facilities to 

annually report amounts of pollutant release to competent authorities (Article 5) starting from 

2007. Subsequently, Member States are obliged to provide the data to the Commission by 

electronic transfer (Article 7). 

The pollutants addressed by the Regulation also include HFCs (threshold of 100 kg for 

release to air/year) and SF6 (threshold of 50 kg for release to air/year) (Annex II). These 

reporting requirements apply for example to manufacturing facilities of chemicals and F-gas 

destruction facilities. The data provided through the database could hence be used for crosschecking with reported data on F-gas emissions. 

The revised EU-ETS Directive (Directive 2009/29/EC) is a core piece of the European 

climate and energy package (see chapter 3.2). It includes PFC emissions from the aluminium 

industry in emissions trading from 2013 onward. It is assumed that this decision will support 

the introduction of technological improvements aiming at emission reductions. This is 

expected to cause a decrease in PFC emissions of ca. 1.3 million t CO2 eq by 2020. 

Furthermore, it is expected that a proposal on excluding emission offset credits generated 

through CDM projects on HFC-23 destruction from the EU-ETS from 2013 will be adopted in 

2011. 

The Renewable Energy Directive 2009/29/EC is also part of the European climate and 

energy package (see chapter 3.2) and promotes the use of renewable energy sources. 

As heat pumps are considered to be using renewable energy from heat sources in the air, 

water or the ground, their installation has been fostered through this directive and additional 

market incentive programmes in several Member States. The number of heat pumps 

installed in EU-27 has been growing significantly in the last few years and is expected to 

continue increasing further. Projections of the model AnaFgas take this development into 

account. 

Article 14(3) of the Renewable Energy Directive requires Member States by 31 December 

2012 to develop specific certification schemes for installers of heat pumps (in accordance 

with Annex IV). The requirements of the certification system are more specific than those of 

the F-gas Regulation but do overlap with regard to containment. 

In this context, the European eco label for heat pumps126 is promoted (Decision 

2007/742/EC). The list of criteria includes inter alia one point on “limitation of the use of 

substances harmful to the environment” and specifies that the GWP of the refrigerant should 

be 2,000. If the GWP of the refrigerant is <150, the minimum requirements for energy 

efficiency in heating and cooling mode are reduced by 15%. In this Act, GWP values are 

 

126 Eco label for heat pumps: http://ec.europa.eu/ecolabel (last checked 15 March 2011). 
Chapter 3 F-gas markets and policies 75 

those in Annex I of the F-gas Regulation (according to 3rd AR of the IPCC). This implies that 

heat pumps running on the currently common refrigerant R410A (GWP 2,088 according to 4th

AR of the IPCC; GWP 1,890 according to 3rd AR) are currently eligible the eco label. 

The recast of the Ecodesign of Energy using Products Directive 2009/125/EC (EuP 

Directive) (previously 2005/32/EC) is a framework directive and aims at improved product 

design with regard to increased energy efficiency and environmental safety of energy related 

products. The use of energy related products has an impact on energy consumption. One 

large group of energy related products are energy using products (e.g. boilers, computers, 

industrial fans etc). Other energy related products can contribute to energy saving (e.g. 

windows, insulation material etc.) and have been included lately in the scope of the recast 

directive. Means of transport are not covered by this framework directive. 

The framework directive does not set binding requirements on products by itself, but through 

implementing measures for each product group. Article 16(1) of the directive, requires the 

Commission to set out a working plan including an indicative list of energy-using products 

which will be considered in priority for the adoption of implementing measures in the period 

2009-2011. Earlier legislation for minimum energy performance standards will be integrated 

and existing labelling requirements remain in force. 

Certain product groups which are covered by the current working plan set out by the 

Commission include equipment relying on F-gases: 

- Air conditioning and ventilation systems; 

- Refrigerating and freezing equipment including e.g. service cabinets, walk-in cold 

rooms, chillers, ice-makers, ice-cream and milkshake machines. 

Other product groups relying on F-gases which have been treated by preparatory studies 

already include: 

- Domestic refrigerators and freezers: Commission Regulation (EC) No 643/2009 

implements ecodesign requirements for household refrigerating appliances; 

- Room air conditioners; 

- Laundry driers. 

With regard to F-gases, it should be underlined that improvements of energy efficiency may 

influence the refrigerant charge size of systems, and thus the emissions127. 

Complementary legislation includes Directive 2010/30/EU on the indication by labelling and 

standard product information of the consumption of energy and other resources by energy 

related products. 

Manufacturers and importers of products need to ensure that their products meet the 

requirements of the EuP Directive and relevant implementing measures. Design and 

construction of products must comply with the eco-design requirements (which should ideally 

be based on harmonized standards existing for the products), undertake conformity 

assessments, issue technical documents and Declaration of Conformity, and label the 

product with the CE marking. 

 

127 Ecodesign criteria agreed as of July 2011 have been considered in the assessment of abatement 

options (chapter 6 and annex VI). 
Chapter 3 F-gas markets and policies 76 

Another important contribution to EU’s emission reduction targets is expected from the 

Energy Performance of Buildings Directive (EPB Directive) (recast 2010/31/EU; 

previously 2002/91/EC). Its objective is to promote the energy performance of buildings in 

EU taking into account outdoor climatic and local conditions as well as indoor climate 

requirements and cost-effectiveness. With regard to F-gases, it is particularly relevant for 

insulation foams. Due to the requirement of improved insulation, the use of construction foam 

might increase and the use of HFC-365mfc and HFC-245fa as foam blowing agents could 

potentially grow. However, as this growth is neither certain nor quantifiable the model 

AnaFgas does not include an assumption reflecting this potential impact in the long term. 

It should be noted that the EPB Directive requires Member States to establish “regular 

inspection of the accessible parts of air conditioning systems of an effective rated output of 

more than 12 kW” (Article 15128). The Directive points out that this inspection of AC systems 

should be carried out in accordance with the inspection of leakages referred to in the F-gas 

Regulation. In fact, this link is relevant for equipment containing charges >3 kg, which applies 

to air conditioning systems of an effective rated output of more than ca. 15 kW such as multisplit and VRF systems, and chillers. 

As stated by the relevant standard EN 15240129, the inspection is mainly based on 

examination of existing documentation, visual inspection and checks whether the equipment 

is well maintained and serviced regularly and that all components are functioning correctly. 

According to the EPB Directive, inspection reports need to be issued subsequent to the 

inspection (Article 16) and inspections are to be carried out “in an independent manner by 

qualified and/or accredited experts” (Article 17). 

National requirements for qualifications of such experts become a key issue when 

considering overlaps of inspections under the EPB Directive and leakage checks under the 

F-gas Regulation. 

• Implications 

In some cases, F-gas policies and various pieces of climate and energy legislation 

complement each other. For example, PFC emissions from the aluminium industry, which 

are not addressed by the F-gas Regulation, will be integrated into the EU-ETS from 2013. 

This is assumed to promote the introduction of abatement technologies in aluminium 

production facilities and emissions are expected to decrease significantly. 

Further harmonization of EU F-gas policy and other pieces of climate and energy legislation 

would be useful. For example, the EuP Directive is accompanied by implementing measures 

for different energy related product groups. These establish specific ecodesign requirements 

for products which contribute to energy consumption and energy savings. In practice, the 

implementing measures focus on products which have a high potential for reducing 

greenhouse gas emissions at low cost, through reduced energy demand. Improvements of 

energy efficiency may influence the refrigerant charge size of systems, and thus F-gas 

 

128 Article 15(1) also sets out: “The inspection includes an assessment of the air conditioning efficiency 

and the sizing compared to the cooling requirements of the building. The assessment of the sizing 

does not have to be repeated as long as no changes were made to this AC system or as the cooling 

requirements of the building in the meantime. Member States may reduce the frequency of such 

inspections or lighten them, as appropriate, where an electronic monitoring and control system is in 

place”. 

129 EN 15240: Inspection of air conditioning systems (2007-08). 
Chapter 3 F-gas markets and policies 77 

emissions. Yet, no specific trend has been identified whether the efficiency of a given system 

with a given refrigerant capacity will improve with more or less refrigerant mass.130 While the 

EuP Directive primarily focuses on energy consumption and related direct CO2 emissions, 

synergies with other environmental legislation (e.g. F-gas Regulation, WEEE Directive) are to 

be explored and enforced. 

The Renewable Energy Directive promotes the installation of heat pumps in order to reduce 

direct emissions released through incineration of fossil energy sources. As heat pumps 

contain and emit F-gases throughout their lifetime and at the end of their life, F-gas 

emissions from heat pumps are expected to increase. The encouragement of measures to 

limit F-gas emissions from this application should be supported. 

The EPB Directive could potentially contribute in increasing use of HFCs (365mfc, 245fa) as 

foam blowing agents. However, foam with low-GWP blowing agents such as hydrocarbons is 

known to provide the same energy performance as HFCs, if the thickness is increased. Thus, 

this interaction is not expected to impact F-gas emissions in the long-term. Furthermore, 

inspections of AC systems >12 kW as required by the EPB Directive (Article 15) might also 

contribute to improved leak tightness irrespective of the charges and appropriate choice of 

AC equipment. Yet this impact on F-gas emissions can hardly be quantified. 

3.3.4 Policies related to safety

Several pieces of legislation address safety issues related to the use of F-gases as 

refrigerants, propellants etc. and might also apply to alternatives to F-gases. 

Regulation (EC) No 1907/2006 concerning the registration, evaluation, authorisation 

and restriction of chemicals (REACH) aims at protection of human health and the 

environment through better and earlier identification of the properties of chemical 

substances. It entered into force in 2007 and will be implemented gradually until 2018. 

REACH streamlines several pieces of EU chemical legislation into one directive creating a 

single regulatory system for all chemicals. 

It covers all chemical substances including F-gases, whether on their own, in preparations or 

contained in equipment. Manufacturers and importers are required to register substances on 

their own (i.e. pure substances) and in preparations in quantities of >1 t per year according to 

a timetable (Article 6) and provide safety information for chemicals to properly manage the 

risks of using them (Articles 10-14). 

The ATEX Directive 94/9/EC on the approximation of the laws of the Member States 

concerning equipment and protective systems intended for use in potentially 

Explosive Atmospheres, applies to the environment in which equipment is installed but 

does not refer to certain substances contained in the systems. For example, it would apply to 

a refrigeration plant containing any flammable gases located in a refinery. 

The Pressure Equipment Directive (PED) 97/23/EC became mandatory in 2002 and 

applies to the design, manufacture and conformity assessment of pressure equipment and 

assemblies with a maximum allowable pressure greater than 0.5 bar gauge including 

 

130 Energy efficiency can be increased by use of larger conventional heat exchangers which typically 

contain greater refrigerant charge mass (due to increased internal volume), or alternatively by use of 

so-called mini channel heat exchangers which contain less refrigerant. The latter option, which is still 

more expensive, would benefit from higher refrigerant cost. 
Chapter 3 F-gas markets and policies 78 

vessels, piping, safety accessories and pressure accessories. Only products fulfilling the 

Essential Safety Requirements may be introduced to EU markets and put into service. Not all 

pressure equipment is covered by this directive as the Transportable Pressure Equipment 

Directive (TPED) and the Simple Pressure Vessels Directive (SPVD) both cover certain 

equipment and products. 

Important tools to demonstrate compliance with the Essential Safety Requirements are 

“harmonized standards”, i.e. EN standards harmonized against the PED Directive (published 

in the Official Journal). Harmonized standards are expected to conform to the Essential 

Safety Requirements stated in the PED Directive and include for example EN 378-1/2/3/4 

(refrigeration systems and heat pumps), EN 14276-1 (vessels), EN 14276-2 (piping), EN 

12284 (valves), EN 12263 (safety pressure switches). 

It should be noted that the application of harmonized standards remains voluntary. 

Manufacturers may choose to apply other technical solutions that provide compliance with 

the Essential Safety Requirements. A notified body is involved to perform an audit for 

verification of compliance. 

The PED Directive defines a number of classifications for pressure equipment, based on 

their hazard level which is determined on the basis of stored energy (pressure-volume 

product) and the nature of the contained fluid (fluid group I: dangerous fluids, which are toxic 

and/or flammable and/or explosive; e.g. R717, R600; fluid group II: all other fluids including 

HFCs and HCFCs). 

3.3.5 Consideration of interactions within the project work

The analysis of interactions between the European legislation on F-gases and legislative acts 

from other fields has led to identification of possible areas of overlaps and certain aspects, 

which might impact future F-gas emissions. Some of the aspects identified are already 

incorporated into the datasets underlying the model AnaFgas, other aspects, however cannot 

be quantified in terms of their effects on F-gas emissions. 

Certain areas where interactions of the EU F-gas policy with other policies have complicated 

the application of provisions or caused confusion are addressed to some extent in the 

assessment of policy options for a potential review of the F-gas Regulation (chapter 8). 
Chapter 4 Application of the F-gas Regulation 79 

4. Application of the EU F-gas Regulation 

Provisions of Regulation (EC) No 842/2006 are directly applicable in all Member States. 

However, a few elements needed implementation through EU and/or national legislation. 

These are the provisions on certification/ attestation systems according to Article 5(2) and on 

penalties according to Article 13. For both aspects, national legislation had to be established 

and the Commission had to be informed about. 

This chapter investigates implementation of those provisions and application of the F-gas 

Regulation: “Implementation” refers to the legal establishment of provisions at Member State 

level, where required. The relevant notifications of the Member States to the EU Commission 

serve as indicators. “Application” refers to the actual realization of the measures of the F-gas 

Regulation in the Member States. 

The costs associated with the F-gas Regulation result mostly from their application and 

enforcement in the Member States (certification, containment, recovery measures etc.) and 

are listed in chapter 4.3. 

4.1 Status of implementation of certain provisions of the F-gas 

Regulation in EU-27 

The status of implementation has been investigated during the first quarter of 2010 and again 

in January and July 2011 in all Member States and relevant industries through 

questionnaires and interviews.131 The evaluation showed that the implementation of the 

relevant provisions of the F-gas Regulation was progressing but remained incomplete at all 

times. Thus, the analysis cannot be considered an ex-post assessment of implementation 

but an interim assessment of the status of ongoing implementation (and application) of the Fgas Regulation. 

4.1.1 Requirements for implementation of Article 5 

Training, qualification and certification of personnel and companies involved in the handling 

of fluorinated gases is a central aspect of the F-gas Regulation to reduce emissions of Fgases by prevention of leakages (i.e. leakage checking by certified personnel, Article 3(2)) 

and by putting in place appropriate arrangements for the proper recovery of F-gases 

(recovery to be done by certified personnel, Art 4(1), respectively by “appropriately qualified 

personnel”, Article 4(3)). 

 

131 The status of implementation of Articles 5 (2) and 13 has been investigated based on the 

notifications of the Member States to the European Commission in early 2010, in January 2011 and in 

July 2011. Additional information was submitted by Member States via questionnaires. The status of 

application of the certification provisions (Article 5) has been investigated during the first quarter 2010 

and January 2011 in all Member States and industry. It was updated as of July 2011 by questionnaires 

to all Member States (SRAC and MAC sector) and industry (FPS, HVS). Information on the status of 

application of the provisions of Article 3 (containment) and 4 (recovery) is based mostly on the first 

inquiry among Member States and industry (first quarter 2010). Data on the status of application of 

Article 6 provisions refer to 2007-2010 and are based on the respective reports to the Commission 

and additional information from Member States and industry. Information on the application of labelling 

provisions (Article 7) and bans (Articles 8 and 9) is based on information from industry and special 

investigations as outlined in chapter 4.2.8 and 4.2.9 (reference date 2010/2011). 
Chapter 4 Application of the F-gas Regulation 80 

The obligations of the operators of equipment according to Article 3 (containment) and Article 

4 (recovery) became directly applicable in the Member States when the F-gas Regulation 

entered into force. Training and certification of personnel play a particularly important role for 

effective application of the provisions of the F-gas Regulation. 

According to Article 5(2), by July 2008, Member States had to establish or adapt their training 

and certification requirements for both companies and relevant personnel involved in 

installation, maintenance or servicing of the equipment and systems covered by Article 3(1) 

as well as for personnel involved in the activities provided for in Article 4. Minimum 

requirements as referred to in paragraph 1 of Article 5 and conditions for mutual recognition 

are laid down in the following implementing Commission Regulations: 

- Regulation (EC) No 303/2008: Certification of companies and personnel with regards 

to stationary refrigeration, air conditioning and heat pump equipment containing 

certain fluorinated greenhouse gases; 

− Regulation (EC) No 304/2008: Certification of companies and personnel with regards 

to stationary fire protection systems and fire extinguishers containing certain 

fluorinated greenhouse gases; 

− Regulation (EC) No 305/2008: Certification of personnel recovering certain fluorinated 

greenhouse gases from high-voltage switchgear; 

− Regulation (EC) No 306/2008: Certification of personnel recovering certain fluorinated 

greenhouse-gas based solvents from equipment; 

− Regulation (EC) No 307/2008: Minimum requirements for training programmes with 

regards to air conditioning systems in certain motor vehicles containing certain 

fluorinated greenhouse gases. 

The Member States had to notify the Commission of their training and certification 

programmes. They must recognize the certificates issued in other Member States in 

accordance with the implementing Regulations and not restrict the freedom to provide 

services or the freedom of establishment for reasons relating to the issuance of certifications 

in another Member State. 

According to Article 5(3), the operator of the relevant application had to ensure that the 

technical personnel involved has obtained the necessary certification referred to in Art 5(2), 

which implies appropriate knowledge of the applicable regulations and standards as well as 

the necessary competence in emission prevention and recovery of F-gases and safe 

handling of the relevant type and size of equipment. 

According to Article 5(4), by 4 July 2009, Member States had to ensure that the companies 

involved in carrying out the activities provided for in Articles 3 and 4 shall only take delivery 

of fluorinated greenhouse gases where their relevant personnel held the certificates 

mentioned in Article 5(2). 

To enable the training and certification of personnel currently active in the sectors of stationary 

refrigeration, air conditioning and heat pumps as well as fire protection systems and fire 

extinguishers without interrupting their professional activity, the Regulations (EC) No 303/2008 

and (EC) No 304/2008 allow Member States to make use of interim certification of personnel 

and companies. The interim certificates expired on 4 July 2010 for the fire protection sector 

and on 4 July 2011 for the stationary refrigeration, air conditioning and heat pump sector at the 

latest. 
Chapter 4 Application of the F-gas Regulation 81 

Temporary interim-certification of personnel could have been issued based on approval of 

past employment (“professional experience”)132 or existent, comparable certification (“existing 

qualification schemes”)133. Interim certificates for companies are issued to companies 

certified under existing certification schemes134 or to companies employing personnel holding 

a certificate135. 

In contrast to interim certification, final (“full”) certification relies upon the existence of a 

certification body. The establishment of certification bodies and attestation bodies must have 

been notified to the Commission and implementing provisions should have been adopted at 

national level where appropriate. Final personnel certification is issued after theoretical and 

practical examination organised by an evaluation body. In Member States where an existing 

examination-based certification system covers the minimum skills and knowledge, a 

certification body may issue a certificate to the holder of this qualification without repeating 

examination. 

In the case of training attestations for personnel recovering F-gases from air conditioning 

systems in motor vehicles, Regulation (EC) No 307/2008 also allowed a transitional period 

until 4 July 2010 at the latest, for which personnel holding an attestation issued under 

existing qualification schemes or with professional experience should have been deemed 

appropriately qualified. 

If F-gas based solvents were not used in a Member State, this Member State could have 

decided not to designate the requested certification or evaluation body until the need for such 

certification arises. In this case, Member States must already provide for the necessary 

arrangements under their national legislation in order to ensure the timely issuance of such 

certificates in case such certification would be requested in the future. 

 

132 In this case the personnel should have been issued with an interim certificate document by an 

entity designated by the Member State. See Regulation (EC) No 303/2008, Art 6(3) and Regulation 

(EC) No 304/2008, Art 6(3). 

133 Personnel holding an attestation issued under existing qualification schemes could have been 

deemed holders of an interim certificate and don’t need an additional document. See Regulation (EC) 

No 303/2008, Art 6(2) and Regulation (EC) No 304/2008, Art 6(2). 

134 Such companies could have been deemed holders of an interim certificate. (EC) No 303/2008, Art 

9(2), (EC) No 304/2008, Art 9(2). 

135 In this case the companies need an interim certificate issued by an entity designated by the 

Member State. (EC) No 303/2008, Art 9(3), (EC) No 304/2008, Art 9(3). 
Chapter 4 Application of the F-gas Regulation 82 

4.1.2 Implementation of Art 5(2): status of notification by Member States 

The notification obligations of the Member States regarding training and certification systems 

in the various sectors are laid down in detail in the respective Regulations136. Table 4-1 

summarizes important deadlines for notifications. 

Table 4-1: Training and certification systems – obligation of the Member States for notification 

Date Subject Regulation (EC) No 

Intention to apply an interim certification system for personnel 

and/or companies 

303/2008 

304/2008 

4 July 2008 

Identification of existing qualification systems or conditions 

based on professional experience on the basis of which 

personnel are deemed appropriately qualified 

307/2008 

Entities entitled to issue interim certificates; 

Certification bodies for personnel and companies 

303/2008 

304/2008 

Certification bodies for personnel 305/2008 

Certification bodies for personnel or decision not to designate 

any certification bodies 

306/2008 

4 January 

2009 

Attestation bodies for personnel 307/2008 

A delay in the notifications indicates difficulties encountered within the implementation 

process in the Member States. The following development since 2009 can be noted: 

Until January 2009 only 3 and until January 2010, only 12 Member States had submitted final 

notifications for all sectors, one Member State had notified partly (France). 

Stationary refrigeration, air conditioning and heat pumps are common applications in every 

Member State, as is the necessity for recovery of F-gas from AC systems in motor vehicles 

(based on European legislation; see chapter 3). Nevertheless, as of 30 April 2010 about 40% 

of the Member States (10 out of 27) had not yet notified the required certification and 

attestation systems for these sectors. These 10 Member States account for about 44% of the 

2008 F-gas emissions from commercial refrigeration, industrial refrigeration and stationary air 

conditioning (calculated by the model AnaFgas). The Member States who had not 

implemented the provisions on training and certification at that time thus include not only 

small countries with low emissions. 

The status as of 4th July 2011, i.e. two and a half years after the deadline for final 

notifications of January 2009, is summarized in the following tables 4-2 and 4-3 and in the 

figures 4-1 to 4-3. 

− Stationary refrigeration, air conditioning and heat pumps: 20 Member States were 

in compliance with the notification obligations. They provided final notification of their 

certification bodies for personnel and companies to the Commission. 

− Fire protection: 19 Member States were in compliance with the notification 

obligations. One of these Member States (DK) decided not to designate 

evaluation/certification bodies, as the use of F-gases for fire protection is prohibited in 

the country. 

 

136 Commission Regulations (EC) No 303-307/2008. 
Chapter 4 Application of the F-gas Regulation 83 

− High voltage switchgear: 19 Member States were in compliance with the notification 

obligations: 17 Member States had notified their training and certification schemes. 

Two Member States decided not to designate evaluation/certification bodies.137

− F-gas based solvents: 19 Member States were in compliance with the notification 

obligations: 11 Member States provided final notification of their certification bodies 

for personnel recovering F-gas based solvents. 8 Member States decided not to 

designate evaluation/certification bodies.138 17 Member States139 declared that F-gas 

based solvents were not in use at the time. Use of F-gas based solvents is prohibited 

in Denmark. 

− Air conditioning systems contained in motor vehicles: 20 Member States were in 

compliance with the notification obligations. They provided final notification of their 

attestations bodies for personnel recovering F-gases from AC systems in motor 

vehicles. 

− 18 Member States had notified interim certification schemes, amongst them 3 

which had not yet notified final certification (Luxembourg, Poland and Portugal). 

− 4 Member States did not notify interim certification schemes and had not yet notified

final certification (Greece, Italy, Latvia, and Malta). 

 

137 These Member States are Denmark and Estonia. 138 These Member States are Austria, Czech Republic, Denmark, Estonia, Ireland, Lithuania, the 

Netherlands, and Romania. 

139 These Member States are Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, 

Hungary, Ireland, Lithuania, Latvia, Malta, the Netherlands, Romania, Slovakia, Slovenia, and 

Sweden. 
Chapter 4 Application of the F-gas Regulation 84 

Table 4-2: Status of notification of certification bodies according to (EC) No 303/2008-307/2008 

as of July 2011 

Final notification of certification/attestation bodies 

under Regulation (EC) No 

303/2008 

(SRAC/HP)

304/2008

(FPS)

305/2008 

(HVS)

306/2008 

(solvents)

307/2008 

(MAC)

Interim 

certification 

notified 

Without 

notification of 

interim/final 

certification 

AT X X X N2 X X 

BE X X X X2 X X 

BG X X X X2 X - 

CY X X X X2 X X 

CZ X X X N2 X X 

DE X X X X X X 

DK X N1 N N1, 2 X X (only 303) 

EE X X N N2 X X 

EL - - - - - - X 

ES X X X X X X 

FI X X X X X X 

FR X - - - X X (only 303) 

HU X X X X2 X X 

IE X X X N2 X X 

IT - - - - - - X 

LT X X X N2 X - 

LU - - - - - X (only 303) 

LV - - - -

2 - - X 

MT - - - -2 - - X 

NL X X X N2 X X 

PL - - - - - X 

PT - - - - - X 

RO X X X N2 X - 

SE X X X X2 X X 

SK X X X X2 X - 

SI X X X X2 X - 

UK X X X X X X 

total 20 18 17 11 20 18 4 

X: Final notification submitted; N: Member States decided not to designate evaluation/certification 

bodies. 1

 In DK use of fluorinated greenhouse gases in the fire protection sector and as solvents is 

prohibited. 2

 No use of solvents (17 Member States). Source: EC and EU-27 authorities. 
Chapter 4 Application of the F-gas Regulation 85 

Two and a half years after the due date, 19 Member States were in full compliance with the 

notification obligations. Final notifications of certification bodies were completely or partly 

lacking in 8 Member States i.e. in 30% of the EU-27 Member States (table 4-3). 

Table 4-3: Status of notification of certification bodies according to (EC) No 303/2008-307/2008 

as of July 2011 (number of Member States) 

In compliance with notification obligations 

Final notification not 

submitted 

In total 

Certification/ 

attestation bodies 

identified 

Decision not to 

designate 

evaluation/ 

certification bodies 

Stationary refrigeration, air 

conditioning, heat pumps 

(EC) No 303/2008 

20 20 - 7 (EL, IT, LU, LV, MT, PL, 

and PT) 

Fire protection 

(EC) No 304/2008 

19 18 1 (DK) 8 (EL, FR, IT, LU, LV, MT, 

PL, and PT) 

High-voltage switchgear 

(EC) No 305/2008 

19 17 2 (DK, EE) 8 (EL, FR, IT, LU, LV, MT, 

PL, and PT) 

Solvents 

(EC) No 306/2008 

19 11 8 (AT, CZ, DK, EE, 

IE, LT, NL, and RO) 

8 (EL, FR, IT, LU, LV, MT, 

PL, and PT) 

Mobile air conditioning 

(EC) No 307/2008 

20 20 - 7 (EL, IT, LU, LV, MT, PL, 

and PT) 

Source: EC and EU-27 authorities 

Figure 4-1: Status of notification of certification bodies in the stationary refrigeration, air 

conditioning and heat pump sector (left; 303/2008) and of attestation bodies in the mobile air 

conditioning sector (right; 307/2008) in July 2011. Green: 20 Member States in compliance with 

notification obligations. Red: 7 Member States not yet in full compliance. 
Chapter 4 Application of the F-gas Regulation 86 

Figure 4-2: Status of notification of certification bodies in the fire protection sector (left; 

304/2008) and the high-voltage switchgear sector (right; 305/2008) in July 2011. Green: 19 

Member States in compliance with notification obligations. Red: 8 Member States not yet in full 

compliance. 

Figure 4-3: Status of notification of 

certification bodies in the solvents sector 

(306/2008) in July 2011. Green: 19 Member 

States in compliance with notification 

obligations. Red: 8 Member States not yet in 

full compliance. 

As of 4th July 2011, relevant national 

legislation was adopted in Portugal, Latvia 

and (with regard to Commission 

Regulations (EC) No 304/2008, 305/2008 

and 306/2008) in France. 

However, these Member States had not yet notified the designation of the respective 

certification bodies to the Commission. In most of these Member States the certification 

bodies had been identified already. 
Chapter 4 Application of the F-gas Regulation 87 

4.1.3 Implementation of Article 5(2): reasons for delay

A significant delay can be identified when looking at the status of implementation of Article 

5(2) according to the notification obligations of the Member States as of July 2011, i.e. 30 

months after the deadline for notifications. 

The identification of the reasons for the delay in implementing the requirements of Article 

5(2) and for the problems associated with the delay has to consider the different conditions in 

each Member State. These include: 

− Structural and cultural differences in the political-administrative and legislative system 

of the Member States, which impact priority and speed of implementing the F-gas 

Regulation. 

− Different baseline conditions regarding the vocational training systems and the 

existence of certification systems in sectors before entry into force of the F-gas 

Regulation. 

− Differences in the number of staff involved and companies concerned in the various 

sectors and Member States, and differences in the availability of infrastructure 

(training institutions, examination bodies) in the Member States. 

In addition, it seems that political and administrative effort for coordination in the Member 

States in order to establish structures for the implementation of the F-gas Regulation have 

been largely underestimated especially concerning: 

− The need for extensive discussion on the implementation of the minimum 

requirements in training programs, and examination requirements. 

− The need for clarification of the recognition of existing qualifications, and of the 

harmonization with existing certification systems in the stationary refrigeration, air 

conditioning and heat pump sector as well as the mobile air conditioning sector. 

− The need for extensive and time-consuming coordination between political 

institutions, industrial associations and further stakeholders. 

− The lack of training facilities and providers and the time and effort to put them in 

place. This is particularly a problem of small Member States and particularly affects 

the F-gas applications with few specialized personnel and hence low demand for 

training/certification (Cat III in the stationary refrigeration, air conditioning and heat 

pump sector, fire protection, high voltage switchgear, solvents). For example, it is 

pointed out that the organisation and conduct of trainings for the fire protection sector 

is not profitable for the relevant institutions if the demand for such training is too low. 

4.1.4 Status of implementation of Article 13 (penalties) 

According to Article 13 of the F-gas Regulation, Member States should have laid down rules 

on penalties applicable to infringements of the provisions of this Regulation and shall take all 

measures necessary to ensure that such rules are implemented. Member States should have 

notified the rules on penalties to the Commission by 4 July 2008. 
Chapter 4 Application of the F-gas Regulation 88 

As of 4th July 2011, 23 Member States had notified that rules on penalties were set out at 

national level. Notifications were still lacking from the other 4 Member States140 (Fig. 4-4). 

The implementation of the provisions on penalties according to Article 13 is also delayed 

even though, in fewer Member States, compared to training and certification according to 

Article 5. 9 out of the 23 Member States which have notified already did so in 2009, 2010 or 

2011 i.e. after the deadline laid down in Article 13. 

Figure 4-4: Status of notification of 

penalties according to Art 13, as of July 

2011. Green: 23 Member States in 

compliance. Red: 4 Member States not 

yet in full compliance. 

 

140 These Member States are Greece, Italy, Luxembourg, and Poland. 
Chapter 4 Application of the F-gas Regulation 89 

4.2 Application of the provisions of the F-gas Regulation 

The progress of application of the F-gas Regulation in the Member States is analyzed with 

regard to major provisions: 

− Training and certification requirements (Article 5) 

− Containment provisions (Article 3) 

− Requirements for proper recovery of F-gases (Article 4) 

− Reporting obligations (Article 6) 

− Labelling requirements (Article 7). 

− Bans (Article 8 and 9) 

Where appropriate, the assessment considers each sector separately: Stationary 

refrigeration, air conditioning and heat pumps, fire protection, high voltage switchgear, F-gas 

based solvents, mobile air conditioning. 

4.2.1 Certification requirements and availability of training centres in 

Member States 

Training requirements, programmes and bodies are not specified by the F-gas Regulation. 

But they are critical for the application of the provisions of Article 5 on certification and need 

to be in place in the Member States. Usually the organisations designated as certification 

bodies are not the same institutions which provide the necessary training.141 The availability 

of training centers for different sectors in the Member States has been assessed in early 

2010. 

According to (EC) No 303-306/2008, certification bodies shall issue a certificate to personnel in 

each sector who have passed a theoretical and practical examination organized by an 

evaluation body covering the minimum skills and knowledge set out by the relevant regulation. 

Evaluation bodies need to be recognized or certified at national level. 

However, neither the F-gas Regulation nor Regulations (EC) No 303-306/2008 contain 

provisions on how to gain minimum skills and knowledge. It is thus possible to pass the 

examinations without previous participation in trainings. 

Where an existing examination-based certification system covers the minimum skills and 

knowledge set out by the Regulations and meets their requirements with regard to certification 

and evaluation bodies, a certificate may be issued to the holder of previous qualification 

without repeated examination. 

Nevertheless, in practice, final certification according to Regulations (EC) No 303-307/2008 

requires the establishment of infrastructure for training in all Member States because most 

 

141 Two examples illustrate this aspect: Bulgaria notified for the stationary refrigeration, air conditioning 

and heat pump sector a personnel and a company certification body (Bulgarian Branch Chamber of 

the Machine Building). This certification body does not provide training. This is done by five 

professional training centres within the country. Germany notified only for personnel certification in the 

stationary refrigeration, air conditioning and heat pump-sector more than 200 certification bodies which 

are with two exceptions not identical to the more than 20 professional training centres. 
Chapter 4 Application of the F-gas Regulation 90 

personnel subject to certification requirements need training. This aspect is highly important in 

terms of costs. 

In the stationary refrigeration, air conditioning and heat pump sector, larger groups of qualified 

personnel (i.e. not beginners) can be certified without additional training only in few Member 

States, where training and certification schemes already existed prior to the F-gas Regulation. 

These Member States include Austria (ca. 50% of personnel subject to certification 

requirements), Germany (ca. 50% of personnel subject to certification requirements), Denmark 

(about 80%)142 and the Netherlands (100% due to the STEK system). 

In all other Member States, certification based on Article 5(3) of Regulation EC (No) 303/2008 

is only possible to very limited extent or not at all. Therefore, training programmes are 

necessary to teach the minimum skills. In most Member States with high numbers of personnel 

to be certified, the share of personnel participating in training measures is estimated to range 

between 90% (France, Spain, Sweden143, UK) and 100% (e.g. Italy). 

In the fire protection sector, the high-voltage switchgear sector and the F-gas-based solvent 

sector, all personnel need to take relevant trainings before the exams, which lead to 

certification. 

For training attestation according to (EC) No 307/2008, an exam is not required. In case 

personnel hold training attestations issued under existing qualification schemes, attestation 

bodies may issue training attestations to the holders of such qualification without repeating the 

training course. However, it is estimated that nearly all personnel subject to attestation 

provisions will need to follow trainings for attestation. 

Table 4-4 presents data on the availability of training centres per Member State, which are 

ready to run courses on the relevant skills and knowledge for F-gas certification as soon as 

national legislation on certification/attestation is in place. This includes training centres in 

Member States without final notification and/or without adoption of their national legal 

implementing provisions. The objective is to give an overview on the availability and 

development of training infrastructure in the Member States regardless of legal status.144

The availability of the necessary infrastructure for application of the certification requirements 

of the F-gas Regulation in the main sectors (stationary refrigeration, air conditioning and heat 

pumps; mobile air conditioning) is sufficient in almost all Member States. 

According to expert information from industry (AREA, EPEE members) from 15 Member 

States the number of training centres and/or training courses for the stationary refrigeration, 

air conditioning and heat pump-sector rose in Member States where implementation of these 

provisions was completed145. 

 

142 In DK, Cat. I acc (EC) 303/2008 is identical with the "kølemontør" category under the existing 

certification system. 

143 In Sweden the existing certification scheme covers minimum requirements according to (EC) No 

303/2008. Nevertheless almost all personnel participate in trainings prior to final certification. 

144 In house training is not covered by the table. 145 These include 10 out of the 15 Member States on which information was available: BE, DE, DK, 

FR, FI, HU, IE, SE, SK, and UK. 
Chapter 4 Application of the F-gas Regulation 91 

Table 4-4: Availability of training centres ready to run F-gas certification after implementation 

of Art 5(2) of the F-gas Regulation as of January 2010. 

Stationary 

refrigeration, air 

conditioning 

and heat pumps 

Stationary fire 

protection 

systems and 

fire 

extinguishers 

High-voltage 

switchgear 

Equipment 

containing Fgas based 

solvents 

Air conditioning 

in motor 

vehicles 

AT X X - - X 

BE 

W.R.: X 

F.R.: X 

B.R.: - 

W.R.: - 

F.R.: X 

B.R.: - 

W.R.: - 

F.R.: X 

B.R.: - 

W.R.: - 

F.R.: - 

B.R.: - 

W.R.: - 

F.R.: X 

B.R.:- 

BG X - - - X 

CY X - X - X 

CZ X X X - X 

DE X X X X X 

DK X n.a. - n.a. - 

EE X X - - X 

EL No data No data No data No data No data

ES - - X - - 

FI X - - - - 

FR X X X - X 

HU X X X - X 

IE X - - - X 

IT X X X - X 

LT X - - - - 

LU No data No data No data No data No data

LV X - - - X 

MT X - - - X 

NL X X X - X 

PL X X X - - 

PT - - - - - 

RO X X X - X 

SE X - X - X 

SK X X - - X 

SI X X - X X 

UK X X X X X 

X: available; -: not available; n.a.: not applicable, F-gas use prohibited. B.R.: Brussels Region; F.R.: 

Flemish Region; W.R.: Walloon Region. Source: EU-27 authorities, industry. 

The Netherlands represent an exception as the STEK Regulation existed prior to the F-gas 

Regulation and hence only some changes of the existing training centres and curricula were 

required. In some Member States where notification or national legal implementing 

provisions were pending, industry assured that training courses meeting the requirements of 

the F-gas Regulation may be performed already (without the possibility to issue the 

respective certificate) e.g. Poland (stationary refrigeration, air conditioning and heat pumpsector sector) and France (switchgear sector). 
Chapter 4 Application of the F-gas Regulation 92 

4.2.2 Application of certification requirements by sectors 

The status of certification according to the requirements of the F-gas Regulation (table 4-5) is 

analysed by sectors as of July 2011. 

Table 4-2 and 4-3 on the status of notifications and table 4-4 on availability of training centres 

in the Member States provide important background information. 

This practice of training and certification varies between individual sectors and Member 

States. A number of Member States did not have qualification or certification systems in 

place when the F-gas Regulation entered into force. In those Member States the creation of 

certification systems according to the requirements of the F-gas Regulation could not rely on 

existing occupational qualification or certification. In Member States with already existing 

qualification schemes, the certification system required by the F-gas Regulation could be 

built on existing schemes provided that these schemes and the skills and knowledge covered 

by them include the minimum standards envisaged by the F-gas Regulation. 

The information on personnel and companies in EU-27 subject to certification requirements 

and the number of personnel and companied who have been certified to date are based on 

information from industry and competent authorities in some Member States. Data were 

extrapolated for EU-27 by means of population data. 

Certification of personnel is required in all sectors (in the MAC sector: attestation). In the 

stationary refrigeration, air conditioning and heat pump sector as well as the fire protection 

sector, company certification is also required. 

Stationary refrigeration, air conditioning and heat pumps 

Status of definitive certification of personnel: As of 4 July 2011, 20 Member States had 

notified their certification bodies (see table 4-2 and 4-3), and 7 not yet (Greece, Italy, Latvia, 

Luxembourg, Malta, Poland, and Portugal). The period during which interim certificates could 

be used expired, at the latest, on the same date. The total number of personnel that need to 

be certified in EU-27 (table 4-5) is estimated at about 228,000.146 

99,500 persons were certified in the 19 Member States who had submitted detailed 

information. This refers to ca. 59% of personnel subject to certification requirements in this 

sector and in these Member States (total: ca. 169,500). It is assumed that about 15% of 

personnel subject to certification requirements in the other Member States where no detailed 

information was available from were fully certified (8,700 persons, mostly in Spain). 

On this basis it is estimated that the share of certified personnel in this sector amounted to 

about 47.5% in EU-27 as of July 2011. 

 

146 This estimate is based on data from industry and competent authorities from 19 Member States 

(AT, BE, BG, CY, CZ, DE, DK, EE, FI, FR, HU, IE, IT, NL, RO, SE, SK, Sl, and UK). Data were 

extrapolated for the remaining Member States. Population in the 19 Member States who submitted 

detailed information represent about 78% of the total population in EU-27. 
Chapter 4 Application of the F-gas Regulation 93 

Table 4-5: SRAC sector – Status of certification according to (EC) No 303/2008 (July 2011) 

Fully certified 

personnel 

Fully certified 

companies 

Population 

(million) 

Total 

personnel 

subject to 

certification 

requirements 

Absolute 

number 

% 

share 

Total 

companies 

subject to 

certification 

requirements 

Absolute 

number 

% 

share 

AT 8.3 2,500 1,500 60.0 1,000 600 60.0 

BE 10.6 4,000 3,400 85.0 900 720 80.0 

BG 7.7 2,000 1,738 86.9 120 88 73.3 

CY 0.8 1,000 850 85.0 350 315 90.0 

CZ 10.3 2,700 2,200 81.5 275 230 83.6 

DE 82.3 28,000 23,800 85.0 5,750 4,025 70.0 

DK 5.4 4,000 2,200 55.0 1,000 1,000 100 

EE 1.3 450 45 10.0 250 15 6.0 

FI 5.3 4,900 1,960 40.0 2,050 1.025 50.0 

FR 63.4 45,000 25,917 57.6 18,000 12,688 70.5 

HU 10.1 4,500 900 20.0 1900 380 20.0 

IE 4.3 1,900 950 50.0 700 490 70.0 

IT 59.1 30,000 0 0 9,000 0 0 

NL 16.3 11,800 11,649 98.7 850 850 100 

PL 38.2 6,000 0 0 

PT 10.6 1,700 0 0 

RO 21.6 60 30 50.0 30 18 60.0 

SE 9.0 5,700 5,600 98.2 900 768 85.3 

SK 5.4 900 675 75.0 300 240 80.0 

SI 2.0 600 487 81.0 300 257 86.0 

UK 60.9 19,500 15,584 79.9 6,000 4,500 75.0 

subtotal 169,510 99,485 58.7 57,375 28,209 49.2 

other* 58,250 8,700 15.0 7,717 0 0 

total 495.2 227,760 108,185 47.5 65,092 28,209 43.3 

Source: EU-27 authorities, industry. * Other MS (extrapolated): Personnel certification: EL, ES, LT, LU, LV, MT, 

PL, PT (population = 111.1 million); company certification: EL, ES, LT, LU, LV, MT (population = 62.3 million). 

Large differences between Member States need to be noted: Only in 15 Member States147, 

the share of certified personnel was 50% in July 2011 (i.e. at the end of the interim period). 

The high share of certified personnel in the Netherlands has been inherited from the former 

STEK-system and related certification requirements. 

Status of definitive certification of companies: The total number of companies subject to 

certification requirements in this sector in EU-27 is estimated at ca. 65,000 (table 4-5). By the 

end of the interim period on 4 July 2011, all of these companies needed to be certified.148 

Detailed information on final company certification is available from 21 Member States and 

includes ca 28,200 companies (ca. 49% of all 57,300 companies subject to certification 

requirements in these Member States). Five out of the remaining 6 Member States (with the 

exception of Spain) had not yet notified certification bodies (see table 4-3); from Spain no 

data on definitive company certification were available. Therefore, it is assumed that the total 

 

147 These include AT, BE, BG, CY, CZ, DE, DK, FR, IE, NL, RO, SE, SK, SL, and UK. 148 The estimate is based on data from industry and competent authorities from 21 Member States 

(AT, BE, BG, CY, CZ, DE, DK, EE, FI, FR, HU, IE, IT, NL, PL, PT, RO, SE, SK, Sl, and UK). The data 

have been extrapolated for the remaining Member States. Population in the 21 Member States who 

submitted detailed information represents about 87.4% of the total population in EU-27. 
Chapter 4 Application of the F-gas Regulation 94 

number of fully certified companies in EU-27 as of 4th July 2011 is about 28.200 or 43.3% of 

all companies subject to certification requirements in this sector. 

The status of company certification differs largely between Member States. 18 Member 

States confirmed that at least some of the companies in this sector were fully certified. In 

16149 Member States the share of certified companies was 50% in July 2011 (i.e. at the end 

of the interim period). 

Fire protection 

Status of final certification (personnel and companies): Interim certification for the fire 

protection sector expired on 4 July 2010. 

On 4 July 2011, 18 Member States had submitted their final notification of certification 

bodies. In Denmark, the use of F-gases in fire protection systems has been prohibited since 

January 2006 (Statutory Order No 552/2002). Final notifications for this sector were still 

lacking from 8 Member States (tables 4-2 and 4-3).150 In some Member States, where final 

notification for this sector is pending, training facilities for personnel certification in this sector 

already exist (e.g. FR, IT, PL; cf. table 4-4). 

In cooperation with experts from EUROFEU and based on data reported by Member States, 

the total number of personnel and companies to be certified in the fire protection sector in 

EU-27 has been estimated at 4,500 persons and the number of companies to be certified at 

1,300 (Table 4-6).151 

In January 2011, less than one third of personnel (28%) and about 7% of companies had 

been fully certified. 

By July 2011, the relevant industry association EUROFEU had no further information on 

personnel and company certification. This indicates that the certification process within this 

sector is progressing slowly. It is thus assumed that the number of fully certified personnel 

and companies in January 2011 did not rise by more than 20% in the period from January to 

July 2011. As of July 2011, a share of one third of fully certified personnel and 9% of fully 

certified companies can be estimated (table 4-6). 

Table 4-6 shows that the number of personnel and companies to be certified varied largely 

between Member States depending on the extent of the use of HFC fire extinguishing 

agents, the size of companies and market structure as well as national regulations. 

Already about 950 personnel certificates had been issued in the UK, which is due to the rule 

that not only personnel of fire extinguishing companies but also personnel of fire alarm and 

detection (FA&D) companies are subject to certification requirements. This is a national 

particularity and does not apply in other Member States. Certification quotas of 50% and 

more for personnel and companies are reported from BG, CZ, FI, NL, and SK. In the UK only 

the share for personnel certification ranges at similar levels and in Germany the share for 

company certification. 

 

149 These are AT, BE, BG, CY, CZ, DE, DK, FI, FR, IE, NL, RO, SE, SK, Sl, and UK. 150 These Member States are EL, FR, IT, LU, LV, MT, PL, and PT. 151 This estimate is based on data from industry and competent authorities from 22 Member States. 

Data were extrapolated for the remaining Member States (HU, IE, LT, LU, MT, and RO). Population in 

the 22 Member States who submitted detailed information represent about 93% of the total population 

in EU-27. 
Chapter 4 Application of the F-gas Regulation 95 

Table 4-6: FPS sector – Status of certification according to (EC) No 304/2008 (January and July 

2011) 

Fully certified 

personnel 

Fully certified 

companies 

Population 

(million) 

Total 

personnel 

subject to 

certification 

requirements 

Absolute 

number 

% 

share 

Total 

companies 

subject to 

certification 

requirements 

Absolute 

number 

% 

share 

Data January 2011 

AT 8.3 36 0 0 9 0 0 

BE 10.6 20 9 45.0 6 1 17.7 

BG 7.7 40 23 57.5 15 10 66.7 

CY 0.8 2 0 0 2 0 0 

CZ 10.3 75 70 93.3 4 3 75.0 

DE 82.3 150 50 33.3 8 4 50.0 

DK 5.4 0 0 0 0 

EE 1.3 40 0 0 15 0 0 

EL 11.2 150 0 0 100 0 0 

ES 44.5 600 0 0 400 0 0 

FI 5.3 15 15 100 2 2 100 

FR 63.4 500 0 0 20 0 0 

IE 4.3 80 0 0 40 0 0 

IT 59.1 750 0 0 200 0 0 

LV 2.3 35 0 0 10 0 0 

NL 16.3 80 57 71.3 10 10 100 

PL 38.2 300 0 0 10 0 0 

PT 10.6 150 0 0 100 0 0 

SE 9.0 20 0 0 5 0 0 

SK 5.4 73 63 86.3 9 8 88.9 

SI 2.0 20 0 0 5 0 

UK 60.9 1000 950 95.0 175 50 28.6 

subtotal 459.2 4136 1245 30.0 1143 88 7.7 

other* 36.0 278 81 

Total 495.2 4414 1237 28.0 1223 88 7.2 

Estimate July 2011** 1485 33.6 110 9.0 

Source: EU-27 authorities, EUROFEU. * HU, LT, LU, MT, and RO (population = 36 million). ** Estimate: number 

of personnel/companies certified as of January 2011 plus 20%. 

High-voltage switchgear 

Personnel carrying out recovery of F-gases from high-voltage switchgear have to be certified 

according to (EC) No 305/2008.152 

By July 2011, 17 Member States had provided notification to the Commission of their 

certification systems for this sector (cf. tables 4-2 and 4-3).153 8 Member States had not 

 

152 The Regulation does not provide an explicit “interim certification system”. However, according to Art 

3(3) of this Regulation, Member States may decide that personnel undertaking the described activity 

before 4 July 2008 shall be deemed certified (transitional regulation) up to 4 July 2009 at the latest. 

153 These Member States are AT, BE, BG, CY, CZ, DE, ES, FI, HU, IE, LT, NL, RO, SE, SK, Sl, and UK 

(table 4-2). 
Chapter 4 Application of the F-gas Regulation 96 

notified yet154. Two Member States (Denmark and Estonia) explained their decision not to set 

up a national certification system and use the possibility of certification abroad.155 

Status of definitive certification of personnel: In cooperation with experts from T&D Europe 

and based on data reported from Member States the total number of personnel to be certified 

in the High Voltage Switchgear sector in EU-27 has been estimated at 3,000 persons (Table 

4-7).156 

Table 4-7: HVS sector – Status of certification according to (EC) No 305/2008 (July 2011) 

Population Fully certified personnel 

(million) 

Total personnel subject 

to certification 

requirements Absolute number % share 

AT 8.3 45 34 75.6 

BE 10.6 45 23 51.1 

BG 7.7 20 9 45.0 

CY 0.8 6 3 50.0 

CZ 10.3 60 60 100 

DE 82.3 1150 1148 99.8 

DK 5.4 60 40 66.7 

EE 1.3 10 2 20.0 

EL 11.2 10 1 10 

ES 44.5 80 9 11.3 

FI 5.3 50 42 84.0 

FR 63.4 210 0 0 

HU 10.1 10 0 0 

IE 4.3 35 35 100 

IT 59.1 250 21 84.4 

LT 3.4 10 2 20.0 

LU 0.5 10 7 70.0 

LV 2.3 10 0 0 

MT 0.4 2 0 0 

NL 16.3 126 126 100 

PL 38.2 50 7 14.0 

PT 10.6 15 4 26.7 

RO 21.6 10 0 0 

SE 9.0 100 42 42.0 

SK 5.4 100 91 91.0 

SI 2.0 40 30 75.0 

UK 60.9 450 404 89.8 

total 495.2 2964 2140 72.2 

Source: EU-27 authorities, T&D Europe. 

 

154 These Member States are EL, FR, IT, LU, LV, MT, PL, and PT. 155 In contrast, training centres have already been in place and operating in some of the Member 

States in which the certification system still had to be installed and thus participation in training 

courses was not yet compulsory. For example, in France, 170 persons out of 210 persons to be 

certified had passed a training course already in November 2010. However, as regulations for this 

sector had been lacking, it was not possible to issue personnel certificates. Information provided by 

T&D Europe. 

156 This estimate is based on information from industry and competent authorities from all EU-27 

Member States. 
Chapter 4 Application of the F-gas Regulation 97 

The share of certified personnel out of all personnel subject to certification provisions in this 

sector is estimated at 72%, which is much higher than in other sectors. Nevertheless, 

differences between Member States are also significant: In 14 Member States the rate is 

<50%, in 13 Member States 50%. 

The high level of certification results from some peculiarities of the high voltage switchgear 

sector: 

− A high degree of concentration of equipment manufacturers in EU-27, close cooperation 

between equipment manufacturers and utilities; close cooperation of the industry with 

regard to training and certification; training and certification schemes are often linked to 

equipment manufacturers and servicing companies. As major equipment manufacturers 

are based in Germany, almost 50% of all personnel certificates were issued in Germany 

(including >200 certificates for personnel from 18 other Member States). 

− The majority of personnel to be certified are active in Germany, France, Italy, the 

Netherlands and the UK. 82% of the certified personnel are from three countries (DE, 

NL, and UK). In these Member States, high certification quotas of 90-100% had been 

achieved. In contrast, final certification had not yet started in France and Italy. 

− Certification in other Member States is of high importance in this sector. From at least 

two thirds of the EU-27 such cross-border certification has been reported. It shows that 

also personnel from Member States without notification and/or without training and 

certification system in place can be certified. More than 200 technicians from 18 Member 

States have been certified in Germany in late 2010157. Out of the 970 personnel 

certificates issued in EU-27 for personnel not originating from Germany 22% were 

issued in Germany. 

− A delay in implementing the required certification system does not necessarily mean a 

lack of training. The standard of qualification and training within the high-voltage 

switchgear industry is high since voluntary agreements aiming at reductions of SF6

emissions from equipment had been in place in some Member States (DE, ES, and FR; 

see chapter 3.2) before the F-gas Regulation entered into force. These voluntary 

approaches also included training and qualification of personnel. T&D Europe underlines 

that manufacturers of high-voltage switchgear equipment and utilities already had their 

system to train people in charge of handling SF6. “SF6 training is only part of a larger 

training package given to personnel handling HV equipment.” (T&D Europe) 

F-gas based solvents 

As of 4 July 2011, 11 Member States had notified for this sector. 

F-gas based solvents are not in use in at least 17 Member States (cf. tables 4-2, 4-3)158. In 

one of them (DK) the use of F-gas based solvents is prohibited. This matches the information 

given by the manufacturer of the main HFC solvent, DuPont. The company communicated 

sales to 9 Member States in 2008 (see Annex III. 20). 

On the basis of Art 6(2) of Commission Regulation (EC) No 306/2008, if F-gas based 

solvents are not used in a Member State, the Member State may decide to not designate the 

 

157 Larger groups came from DK (40), CZ (28), IE (35), AT (18), FI (16), and IT (14). 158 These are AT, BE, BG, CY, CZ, EE, HU, IE, LT, LV, MT, NL, RO, SE, SK, and Sl. 
Chapter 4 Application of the F-gas Regulation 98 

requested certification or evaluation body until the need for such certification arises. In this 

case Member States shall provide for the necessary arrangements under their national 

legislation in order to ensure the timely issuance of such certificates in case such certification 

would be requested in the future. 8 Member States made use of this option.159

Final notifications or statements concerning the solvents sector (with regard to Article 6(2)) 

were lacking from 8 Member States. Only one active training centre according to (EC) 

306/2008 was identified and is located in the UK. 

Status of certification of personnel: F-gas based solvents are used at least in 3 Member 

States including France, Poland and UK. The number of personnel subject to certification 

requirements is estimated at 160 persons in these Member States out of which ca. 100 

persons are active in UK (table 4-8).160 In France, where also high quantities of HFC-based 

solvents are used, no training and certification body could be identified in 2011. Therefore, 

relevant personnel will likely be trained abroad in the future. In Poland one company using Fgas based solvents will organize in-house training. 

Out of the remaining 7 Member States Germany and Finland explained that F-gas based 

solvents played no important role. Thus it is assumed that at maximum 170 persons are 

subject to certification provisions. 

In total, over 50% out of the 170 persons subject to certification requirements have been 

certified already (all in UK). 

Table 4-8: Solvents sector – Status of certification according to (EC) No 306/2008 (July 2011) 

Population Fully certified personnel 

(million) 

Total personnel 

subject to certification 

requirements Absolute number % share 

FR 63.4 50 0 

PL 38.2 10 0 

UK 60.9 100 92 

Sub-total 162.5 160 92 57.5 

“no use”* 119.2 0 - - 

Other** 213.5 10 0 

total 495.2 170 92 54.1 

Source: EU-27 authorities. *17 Member States; **DE, EL, ES, IT, FI, LU, and PT. 

Recovery of F-gases from AC systems in motor vehicles 

Personnel carrying out recovery of F-gases from air conditioning systems in motor vehicles 

falling within the scope of Directive 2006/40/EC must hold a training attestation according to 

(EC) No 307/2008.161

 

159 These Member States are AT, CZ, DK, EE, IE, LT, NL, and RO (cf. table 4-2 and 4-3). 160 Defra/UK, 2 November 2010. 161 According to Art 2(3) of this Regulation, Member States had the possibility to decide that until 4 

July 2010 at the latest, personnel holding an attestation issued under existing qualification schemes 

for the activity within the scope of this regulation or personnel with professional experience in this 

activity acquired before 4 July 2008 should be considered appropriately qualified to carry out the 

mentioned activity (transitional arrangement). 
Chapter 4 Application of the F-gas Regulation 99 

Status of personnel attestation: As of July 2011, 20 Member States had been in compliance 

with notification obligations; final notifications and the possibilities for attestation of personnel 

were missing from 7 Member States (cf. tables 4-2 and 4-3).162

Table 4-9: MAC sector – Status of attestation according to (EC) No 307/2008 (July 2011) 

Population Fully certified personnel 

(million) 

Total personnel 

subject to 

certification 

requirements 

Absolute number % share 

AT 8.3 3,500 1,750 50.0 

BE 10.6 8,000 6,000 75.0 

CY 0.8 360 140 38.9 

DE 82.3 70,000 49,000 70.0 

DK 5.4 7,000 3,500 50.0 

EE 1.3 430 258 60.0 

FI 5.3 6,350 6,350 100.0 

FR 63.4 40,000 40,000 100.0 

HU 10.1 3,000 600 20.0 

IT 59.1 58,000 0 0 

NL 16.3 7,400 7,350 99.3 

SE 9.0 2,500 2,500 100 

SK 5.4 900 675 75.0 

SI 2.0 2,000 510 26.0 

UK 60.9 50,000 26,656 53.3 

subtotal 340.2 259,440 145,289 56.0 

other* 155.0 100,801 10,080 10.0 

total 495.2 360,241 155,369 43.1 

Source: EU-27 authorities. *: BG, CZ, EL, ES, IE, LT, LU, LV, MT, PL, PT, and RO (population = 155.0 million). 

The total number of personnel to be certified in the MAC sector in EU-27 (cf. table 4-9) has 

been estimated at about 360,000 persons.163 In the 15 Member States who had submitted 

detailed information, it is known that by July 2011 ca. 145,000 persons held their final 

attestation, which equals ca. 56% of the personnel subject to attestation requirements. In the 

other Member States, some of which have not notified yet, it is expected that about 10% of 

the total personnel subject to attestation requirements hold attestations. Therefore, the total 

share of personnel holding attestations in EU-27 is estimated at about 43%. 

In the mobile air conditioning sector, large differences between Member States are to be 

noted. While the level of attestation is high (50->90%) in 12 out of the 15 Member States with 

detailed data, it is comparably low (<50%) in 3 of them. In at least 7 Member States, 

attestation does not take place yet (attestation bodies not yet notified). 

 

162 These are EL, IT, LU, LV, MT, PL, and PT. (In Denmark, attestation bodies had been identified but 

not notified, and training and attestation were carried out in 2010 already.)

163 This estimate is based on data from industry and competent authorities from 15 Member States. 

Data were extrapolated for the remaining 12 Member States (BG, CZ, EL, ES, IE, LT, LU, LV, MT, PL, 

PT, and RO). Population in the 15 Member States who submitted detailed information represent about 

69% of the total population in EU-27. The estimate determines the number of service workshops and 

the stock of servicing equipment for mobile air conditioning systems contained in motor vehicles and 

was carried out in order to complement data from Member States. 
Chapter 4 Application of the F-gas Regulation 100 

4.2.3 Other issues related to Article 5

Training and certification abroad: Notification of certification bodies and the use of training 

facilities in other Member States are only important in the high voltage switchgear sector. As 

outlined above, this is the sector with the largest share of foreign certification relevant for two 

thirds of the Member States. Until 30 November 2010, more than 200 certificates for 

personnel from other 18 Member States were issued in Germany (10% from all certificates 

issued in EU-27). This is due to the small number of personnel to be certified in this sector in 

most Member States, the rather high costs for special equipment and related high costs for 

certification as well as the close cooperation of switchgear manufacturers and utilities. 

In other sectors training and certification in other Member States play a minor role. In few 

cases, small Member States notified certification bodies in other Member States or personnel 

from small Member States were trained and certified in other Member States. In the solvents 

sector, France is considering this possibility. In the stationary refrigeration, air conditioning 

and heat pump sector, certain companies operating in several Member States also took the 

opportunity to train and certify their personnel together with personnel from the parent 

company in one Member State. 

In all sectors, training and certification in other Member States is de-facto limited by language 

barriers. 

Recognition of certificates: There is no information on serious problems related to the 

recognition of certificates. In few cases minor problems were highlighted concerning the 

following issues: 

- Language problems related to certification abroad and certificates, which were issued 

abroad (requirement for translation of certificates into national language). 

- Insufficient transparency of compliance of certificates gained abroad with the EU 

minimum requirements. 

Validity of certificates: The Commission Regulations (EC) No 303-307/2008 which 

establish the minimum requirements for certification of personnel and companies do not 

specify a validity period for the certificates. The Member States may decide whether the 

validity of the certificates should be limited and what the validity period should be. 

Out of 20 Member States who had submitted final notifications, 10 had decided to limit the 

validity of personnel and company certificates (table 4-10). The validity period of personnel 

and company certificates vary widely: 

Personnel certification is valid for 5 years in 7 Member States and for 3 years in 1 Member 

State (Slovakia) but this does not always apply to all sectors. 

In France, the validity of personnel certificates according to Regulations (EC) No 303/2008, 

No 304/2008 and No 307/2008 (attestation) is not limited but checked every 5 years during 

regular audits which link company certification to certification of personnel. In Belgium and 

UK, only personnel certificates in the stationary refrigeration, air conditioning and heat pump 

sector are of limited validity. In the UK, personnel certificates with limited validity and 

certificates with unlimited validity coexist. 

Article 5(4), delivery of F-gases only to certified personnel: According to Article 5(4) and 

by 4 July 2009, Member States shall ensure that the companies involved in carrying out the 
Chapter 4 Application of the F-gas Regulation 101 

activities provided for in Articles 3 and 4 shall only take delivery of F-gases where their 

relevant personnel is certified. While the implementation of provisions according to Article 

5(2) (certification) and Article 13 (penalties) is a prerequisite for the application of this 

provision, no reliable indicators are available to assess its status of application. Member 

States164 refer to the respective provisions of national legislation, to national authorities, 

which are obliged to control compliance with the provisions of the F-gas regulation and to 

legislation on penalties according to Article 13 in case of non-compliance. Some Member 

States have set further national stipulations, which pledge the F-gas distributors to deliver 

appropriate refrigerants only to appropriately certified enterprises (FR; ES). In France, 

distributors of fluorinated gases are obliged to check whether the operator that takes delivery 

of F-gases is certified or not. To facilitate this check, the lists of certified companies are 

published on the internet. Penalties apply to F-gas distributors and the operator in case of Fgas delivery to a non-certified customer. 

Joint certification systems for F-gases and ODS: According to the ODS Regulation (EC) 

No 1005/2009 (recast which replaced Regulation (EC) No 2037/2000), Member States shall 

define minimum qualification requirements 

- for personnel carrying out leakage detection and repair activities in the refrigeration, 

air conditioning and heat pump sector and 

- for personnel carrying out leakage detection and repair activities in the fire protection 

sector and 

- for personnel involved in RRRD of ODS. 

Under the ODS Regulation, training courses without examination and certification are 

normally carried out in the Member States. However, in some Member States (e.g. Czech 

Republic, Hungary, Poland) certification of personnel is required for these activities and a 

joint certification system for both F-gases and ODS is (CZ, HU) or will be (PL) in force. In 

Member States which did not implement personnel certification requirements in the context 

of (EC) 1005/2009 the certification according to F-gas Regulation may be classified as 

further training covering the requirements of the ODS-Regulation (e.g. Germany). 

 

164 In the questionnaire under paragraph 4.7, Member States were asked for control mechanisms in 

order to monitor compliance with the provisions according to Articles 5(3) and 5(4). 
Chapter 4 Application of the F-gas Regulation 102 

Table 4-10: Limitation of the validity of certificates/attestations (January 2011) 

Personnel certificates/attestations Company certificates 

BE 5 years (only SRAC) 3 years (only SRAC, Flemish Region) 

BG 5 years always 5 years always 

EE 5 years always 5 years always 

FR 5 years (only HVS, solvents) 5 years (always incl. MAC) 

IE - 1 year always 

NL - 4 years always 

SE 5 years (only SRAC, HVS) 5 years (only SRAC) 

SK 3 years always 1 year always 

SI 5 years always - 

UK 5 years (only SRAC, one certification body) 3 years (SRAC); 

5 years (FPS) 

MS without notification 

LV 5 years (planned) 5 years (planned) 

PT planned Planned 

PL 5 years (planned, always, excl. MAC) 5 years (planned) 

Validity of company certification according to Regulations 303/2008 and 304/2008 is limited 

in 9 Member States, 3 other Member States plan to introduce such provisions. 

In France, certification requirements were extended to companies of the MAC sector 

(Regulation (EC) No 307/2008). In Belgium, only one region (Flemish Region) introduced 

company certificates of limited validity according to Regulation (EC) No 303/2008. 

4.2.4 Summary: Status of certification 

Based on the information presented above, table 4-11 gives an overview of the status of 

certification for each sector in July 2011. In EU-27, about 600,000 persons are subject to 

certification and attestation requirements according to Regulations (EC) No 303-307/2008. 

About 60% of the personnel subject to certification/ attestation requirements work in the 

mobile air conditioning sector (ca. 360,000 persons), 38% in the stationary refrigeration, air 

conditioning and heat pump sector (ca. 230,000 persons). The remaining 2% consists of 

personnel active in the fire protection sector (ca. 4,500 persons), the high voltage switchgear 

sector (ca. 3,000 persons) and the F-gas based solvents sector (up to 200 persons). 

In July 2011, the share of personnel holding final certification/attestation out of the personnel 

subject to certification/attestation requirements, as of 4 July 2011, is estimated at ca. 48% in 

the stationary refrigeration, air conditioning, heat pumps sector and at ca. 43% in the mobile 

air conditioning sector. The average values for both large sectors for EU-27 include large 

differences between Member States: While in some Member States the provisions for final 

certification of Article 5 of the F-gas Regulation are neither implemented nor applied yet, in 

some other Member States (more than 50% of the personnel with definitive certification/ 

attestation in 15 Member States), final certification/attestation is progressing well. 
Chapter 4 Application of the F-gas Regulation 103 

Table 4-11: Status of certification according to (EC) No 303-307/2008 (July 2011) 

Sectors Certification/attestation of Personnel Certification of 

Companies 

Total personnel subject to 

certification requirements 

Fully 

certified 

personnel 

Member 

States with 

>50% 

personnel 

fully certified 

Total 

companies 

subject to 

certification 

requirements 

Fully 

certified 

companies 

Absolute 

number 

% by sector % share Absolute 

number 

% share 

SRAC/HP 228,000 38.3 48 15 65,000 43 

FPS 4,500 0.8 34 6 1,300 9 

HVS 3,000 0.5 72 14 - - 

Solvents 170 <0.1 54 (1) - - 

MAC 360,000 60.4 43 15 - - 

total 595,670 100 66,300 

The share of personnel already certified in the fire protection sector is estimated at 34% in 

EU-27. The differences between Member States are larger than described for the stationary 

refrigeration, air conditioning, heat pumps and mobile air conditioning sectors. The share of 

certified personnel is much higher in the high voltage switchgear sector, which is linked to 

some particularities of this special industry (inter alia high level of previous qualification 

concerning the handling of SF6, high degree of concentration and cooperation between 

companies). However, the differences between Member States are also significant and low 

certification rates would be found in about half of the Member States. The F-gas based 

solvents sector takes a special role: These solvents are only used in few Member States and 

personnel had been certified only in UK so far. 

Company certification is only required for the stationary refrigeration, air conditioning and 

heat pump sector as well as the fire protection sector. The number of companies working in 

the stationary refrigeration, air conditioning and heat pump sector is estimated at 65,000 out 

of which ca. 43% hold final company certification in July 2011. In the fire protection sector, 

the number of relevant companies is estimated 1,300 of which less than 10% held final 

company certification in July 2011. 

In general, it has to be noted that the status of certification depends not only on the 

compliance of industry to the provisions of the Regulation but also on the activity of Member 

States in implementing the Regulation, its enforcement and control. 

In the stationary refrigeration, air conditioning and heat pump sector, the interim period for 

certification ended on 4 July 2011. Until then, most Member States had not reached full 

certification of personnel and companies as required. However, it should be noted that the 

qualification of personnel is in fact higher than indicated by the average certification quota. 

This relates to the delay of notification of certification bodies in some Member States while 

trainings of personnel according to the F-gas Regulation have been carried out already. 
Chapter 4 Application of the F-gas Regulation 104 

4.2.5 Application of containment provisions (Art 3)

Article 3 (containment) of the F-gas Regulation covers the following applications: 

− stationary refrigeration, air conditioning and heat pump equipment (including their 

circuits), and 

− stationary fire protection systems. 

The article establishes measures to prevent leakage of fluorinated gases and to repair any 

detected leakage as soon as possible. Operators of such equipment are required: 

− to ensure regular leakage checks, 

− to install leakage detection systems (in applications containing 300 kg fluorinated 

greenhouse gases) and 

− to maintain records (“logbooks”) on quantities and type of F-gases installed, added 

and recovered and on other relevant information. 

Article 3(2): Leakage checks 

Article 3(2) requires operators of the above mentioned applications referred to in paragraph 1 

of Article 3 to ensure that leakage checks are carried out by certified personnel complying 

with the requirements of Article 5 of the F-gas Regulation, and according to a specific 

schedule: 

− applications containing 3 kg of fluorinated greenhouse gases: at least once every 12 

months; 

− applications containing 30 kg of fluorinated greenhouse gases: at least once every 6 

months; 

− applications containing 300 kg of fluorinated greenhouse gases: at least once every 

3 months. 

Where a properly functioning appropriate leakage detection system is in place, the frequency 

of the checks required shall be halved (applications 30 kg and 300 kg, Art 3(4)). 

Equipment with hermetically sealed systems, which is labelled as such and contains less 

than 6 kg of fluorinated gases is exempt from these provisions. 

Regular leakage checks according to Article 3(2) became compulsory as of July 2007. 

Stationary refrigeration, air conditioning and heat pumps

In general, before the entry into force of the F-gas Regulation leakage checks at large 

systems with particularly high emission factors (commercial and industrial refrigeration) were 

carried out more or less regularly in the framework of service contracts in the stationary 

refrigeration, air conditioning and heat pump sectors. However, this was not a common 

practice in small systems and appliances (charges <30 kg). There is no quantitative data 

available on the extent of leakage controls prior to the entry into force of Regulation (EC) No 

842/2006. 
Chapter 4 Application of the F-gas Regulation 105 

In some Member States regular leak checking is enhanced by national legislation: 

− According to Austrian legislation165, regular checks have been obligatory “for many 

years” (at least annually). Following the Regulation's entry into application, intervals 

have to be shorter, depending on charge. 

− In Bulgaria regular leakage checks of F-gas refrigeration and air conditioning systems 

3 kg are compulsory at least annually since 2002166. 

− Germany reported a delay for the refrigeration and air conditioning sector because 

the national requirements for personnel carrying out leakage checks were not laid 

down before 1 August 2008. However, it was also stated that annual checks have 

always been compulsory for stationary fire extinguishers in order to maintain 

insurance coverage167. 

− Danish legislation168 requires that pressurized refrigeration and heat pump equipment 

containing charges >1 kg is subject to periodic examinations. 

− French national legislation169 prescribes periodical control of the installation for 

stationary refrigeration, air conditioning and heat pump equipment containing charges 

of ODS or F-gases >2 kg in order to prevent leakage (at the same frequencies as in 

Regulation (EC) No 842/2006). 

− The Netherlands underline that for stationary refrigeration and air conditioning 

systems “the same regime has been in place ... since 1997” and that the frequency of 

leakage checks performed is generally well in line with the requirements of the F-gas 

Regulation (>90% as reported in 2007 and 2008). With regard to the fire protection 

sector, due to insurance and safety policy in the Netherlands a safety check regime is 

required in line with the provisions of the F-gas Regulation. 

− According to the Swedish authorities, annual checks of stationary refrigeration, air 

conditioning and heat pump equipment have been required since 1989. 

These Member States are among the group of countries which notified (interim) certification 

schemes relatively early (except Bulgaria). They all had finally notified in 2009. 

Representatives of the stationary refrigeration, air conditioning and heat pump industry170

were asked in a more detailed way about their experiences with leakage checks. Information 

 

165 Austrian Kälteanlagenverordnung BGBL. Nr. 305/1969. 166 Amendment to the Bulgarian Ordinance on ODS, State Gazette No 96/2002. 167 A few years ago shorter intervals depending on the size of the system had been laid down by the 

licensing institution VDS Schadenverhütung GmbH. 

168 Danish Executive Order No. 100 issued by the Danish Working Environment Authority (in force 

since 15 February 2007). 

169 French arrêté of 7 May 2007. 170 Data from AREA, EPEE and ECSLA. The “Air conditioning and Refrigeration European 

Association” (AREA) is an organisation of air conditioning, refrigeration and heat pumps contractors in 

Europe. The association is active in 20 European countries and represents according to their own 

information more than 9,000 companies, mainly small to medium sized enterprises. EPEE – 

“European Partnership for Energy and the Environment” – is an industrial association composed of 

internationally operating companies who produce, design and install heating, cooling and refrigeration 

technologies. ECSLA: European cold storage and logistics Association. 
Chapter 4 Application of the F-gas Regulation 106 

has been provided by small and medium contractors in this sector from several Member 

States171. 

− Industry estimates that since 2009 leakage checks in equipment containing charges 

of 30 kg are carried out more or less regularly. The industry associations have no 

empirical data but rely on experience and the qualitative judgement of their members. 

− Prior to entry into force of the F-gas Regulation, in this sector fewer checks were 

carried out, unless there was a specific problem e.g. decrease of performance 

leading to investigative work and suspicion of refrigerant shortage. AREA estimates 

that with regard to equipment containing refrigerant charges 30 kg “the number of 

leak checks increased substantially” since 2009. 

The association AREA communicated the status of compliance in different sub sectors as 

follows. 

Table 4-12: Status of compliance with requirements for leakage checks according to Article 

3(2) by sectors and sub sectors 

Sectors Compliance with requirements 

of Article 3(2) of Regulation (EC) No 842/2006 

Mostly compliant 

Supermarkets 

„major supermarkets“/big chains 

Smaller supermarkets Less compliance 

Small commercial applications Mostly very little regular checking 

More likely to fully comply 

Large commercial applications 

Hospitals, public buildings 

Private sector Depends (on nature of the business, whether other regular 

checks are made compulsory or not, maintenance contract exist 

etc.) 

Industrial applications More likely to comply (often other mandatory inspections, 

tighter rules and regulations) 

Source: Questionnaire to contractors, AREA 2010 

Table 4-12 shows that compliance with obligations for leak checks can be expected to a 

higher degree for large companies and for large equipment (large supermarkets, major public 

and private enterprises such as hospitals, industrial facilities) rather than for small shops or 

small equipment. 

Further findings of the survey confirm that the reality and the trend of frequency of leak 

checks differ between small and large industries and between regions. 

− Small industries (small contractors, charges from 3 kg to 30 kg): In the past the 

frequency of leak detection did “depend on the leaks” or on the maintenance contract. 

In the past 10 years (before and after entry into force of the F-gas Regulation) the 

number of leak checks increased only slightly. 

− Larger industries (Internationally operating manufacturing and service companies, 

charges from 3 kg to 300 kg): Frequencies of leakage checks are reported to be 

more or less in compliance with the F-gas Regulation only in some Member States 

(e.g. Germany, the Netherlands, and Great Britain). From other Member States (e.g. 

 

171 These Member States include: AT, BE, CZ, DK, DE, EL, ES, FI, FR, HU, IE, IT, NL, PL, PT, SE, 

SK, and UK. 
Chapter 4 Application of the F-gas Regulation 107 

EL) low awareness and no enforcement is reported. For the first group of Member 

States a slight increase in leak checks is registered (e.g. DE, FR, UK; Baltic; in the 

Netherlands the number of leak checks remained stable, for Poland an significant 

increase is estimated.) 

− As for the cold storage and logistics sector, ECSLA reports that most companies in 

France, Germany, Netherlands and Spain carry out regular leakage checks twice a 

year, in France and Germany since approximately 2000. The number of leak checks 

remained stable in France, Germany, and the Netherlands over the past ten years 

and increased slightly in Spain (+10%). 

Based on the information available and with regard to early 2010 it can be concluded that 

leak checks in this sector must increase by at least 50-100% to meet the requirements of Art 

3(2). 

Fire protection sector 

In this sector, the above mentioned schedule for leakage checking is compulsory. Article 3(5) 

of the F-gas Regulation specifies that if an existing inspection regime is in place to meet ISO 

14520 standard, these inspections may also fulfil the requirements as long as the inspections 

are at least equally frequent. 

In contrast to the provisions of the F-gas Regulation, ISO 14520172 is a voluntary international 

standard which was introduced in 2000. This norm requires systems (including systems with 

F-gas charges < 3 kg) to be checked regularly. It was widely adopted as European norm EN 

15004173. According to ISO 14520 and EN 15004 all systems shall be thoroughly inspected 

at least annually. At least every 6 months, the contents of the containers shall be checked. If 

the halogenated extinguishing agents are filled into the containers and losses of more than 

5% or a loss in pressure (adjusted for temperature) of more than 10% occur, the container 

shall be refilled or replaced. 

Representatives of the fire protection174 industry were asked in a more detailed way about 

their experiences with regard to leakage checks. In the fire protection sector leakage control 

is widespread to ensure proper functioning of the systems. 

Data on the percentage of fire protection systems subject to regular leakage checks as of 

January 2010 have been provided by the fire protection industry175 for Germany and the UK 

(table 4-13). 

Table 4-13: Status of regular leakage checks according to Art 3 for fire protection systems 

Percentage of systems with regular leakage checks in compliance 

with Art 3 [%] 

 Systems 3 kg Systems 30 kg Systems 300 kg 

DE 50 70 90 

UK 100 100 100 

Source: Questionnaire to fire protection industry 

 

172 ISO 14520: Gaseous fire-extinguishing systems - Physical properties and system design. 173 EN 15004: Fixed fire fighting systems - Components for gas extinguishing systems. 174 Data is from EUROFEU (a section of Fire Extinguishing Installations) for Germany and UK and 

from two companies from Italy and Estonia. EUROFEU represents National Trade Associations of the 

European fire protection industry from a total of 10 EU Member States, amongst them 5 with a section 

„Fire Extinguishing Installations“(BE, DE, FR, NL, and UK). ASSURE. European Association for 

Responsible Use of HFCs in Fire Fighting did provide a general statement. 

175 Input from EUROFEU, section Fire Extinguishing Installations. 
Chapter 4 Application of the F-gas Regulation 108 

UK experts report that this high level of compliance was related to the routine of application 

of ISO 14520 and state that leakage checks were undertaken every 6 months. For Germany, 

industry indicates mostly annual or semiannual leakage checks for all types of equipment 

(charges from 3 kg to 30 kg). Industry claims that the frequency of leakage checks 

remained relatively stable since the entry into force of the F-gas Regulation (EUROFEU: DE, 

IT, UK; ASSURE). 

Available information indicates that leakage checks must increase by at least 25% in this 

sector to meet the requirements of Article 3(2). This information corresponds to statements 

made by experts from industry (EUROFEU). 

Article 3(3): Leakage detection systems 

Operators of the applications referred to in Article 3(1), containing F-gas charges 300 kg, 

shall, according to Article 3(3), install leakage detection systems. These leakage detection 

systems shall be checked at least once every 12 months to ensure that they are working 

properly. In the case of fire protection systems installed before 4 July 2007, leakage 

detection systems shall be fitted by 4 July 2010. 

According to Article 3(4) the frequency of the checks required for applications containing 30 

kg and 300 kg of fluorinated greenhouse gases – Article 3, paragraphs 2(b) and (c) – shall 

be halved where a properly functioning appropriate leakage detection system is in place. 

The installation of leakage detection systems required by the F-gas Regulation became 

compulsory as of July 2007 (exception: fire protection systems installed before 4 July 2007, 

as mentioned above). 

Stationary refrigeration, air conditioning and heat pumps

In this sector around 20 % of commercial centralized refrigeration systems, i.e. the small and 

large industrial refrigeration units and AC centrifugal chillers are concerned by Article 3(3) 

(according to the model AnaFgas). 

The mainly small to medium sized contractors in this sector have no detailed information on 

the extent of installed leakage detection systems and estimate that only few systems may 

have been introduced in this sector. Also, large internationally operating manufacturing and 

service companies report relatively small numbers of installed leakage detection systems. 

They characterize the use of such systems in Great Britain and France as mediocre, and in 

the Netherlands, and Germany even less.176 Data from other Member States were not 

available. However, most of the companies describe an increasing trend since the entry into 

force of the F-gas Regulation. 

Authorities from some Member States expressed the need for more guidance on technical 

specifications of leakage detection systems.177 The main issue seems not to be the 

availability of detection systems but their accuracy. Enquiries show that there is still 

uncertainty amongst operators about what types of leakage detection systems are accepted 

 

176 In contrast, the cold storage industry is according to the Branch association ECSLA well equipped 

with leakage detection systems, and in most cases these have been in place for a long time (data from 

Germany, France, Greece, the Netherlands, and Spain). 

177 These Member States include BE, DE, FR, and PT. 
Chapter 4 Application of the F-gas Regulation 109 

by the authorities. Due to this uncertainty, systems are not installed and so the frequency of 

checking procedures pursuant to Article 3(4) cannot be halved. 

According to the information available leakage detection systems are rarely installed in this 

sector. Therefore, the cost assessment is based on the assumption that installation of 

leakage detection systems at equipment containing charges 300 kg is generally required in 

this sector to meet the provisions of Article 3 (3) of the F-gas Regulation. 

Fire protection sector

More experience on the use of leakage detection systems for the fire protection sector 178 is 

available in some Member States. Large stationary fire protection systems were already 

subject to leakage checks stipulated by property insurances before entry into force of the Fgas Regulation179. 

The percentage of fire protection systems with leakage detection systems installed according 

to Article 3(3) of the F-gas Regulation (i.e. applications containing 300 kg of fluorinated 

greenhouse gases, erected after 4 July 2007) was indicated by industry at 99% in Germany 

and at 75% in UK. Hence, such detection systems are “widespread”. The UK-representatives 

stated the view that it is “sometimes difficult to install leakage detective systems 

retrospectively on older systems”. 

At the same time the survey with experts from industry (EUROFEU) showed that ISO 

standard 14520 is prevalent throughout Europe in this sector. This applies to standard EN 

12094, too (also see chapter 3).180

Thus, it is assumed for the cost assessment that the installation of leakage detection 

systems at fire protection systems is not necessary. 

 

178 “All containers used to store extinguishing agents in fixed fire protection systems are required to 

have a leakage detection system fitted as standard. (...) These leak detectors are of two kinds: the 

majority are pressure gauges but weight monitoring systems are also used, so that the detector 

indicates either a loss of pressure or weight if a leakage occurs, depending on the type used. 

New fire protection systems over 300 kg manufactured since 2003 have alarm systems fitted that 

automatically alert the operator if a leak occurs. (...) Some older systems also have retrospectively 

fitted alarms. However, under Article 3 of the Regulation, operators of fixed fire protection systems 

containing more than 300 kg of HFCs have until 4th July 2010 to fit an alarm system. These larger 

systems are in a minority and our impression is that retrospective fitting of alarm devices to older 

systems (some of which already have them) is proceeding to schedule.” 

ASSURE, Review of Regulation (EC) No 842/2006 on certain fluorinated greenhouse gases. 

Response to Öko-Recherche GmbH Questionnaire on Fire Protection Systems, May 2010. For 

technical aspects cf. BFPSA (British Fire Protection Systems Association), Guidance Note EC 

Regulation No 842/2006 on Certain Fluorinated Greenhouse Gases, 7-08-06, p. 6. 

179 Examples: Austria and Germany: checks by weighing the containers; monitoring the gas supply by 

pressure measurements has also been permitted for some time. 

180 EN 12094: Fixed fire fighting systems - Components for gas extinguishing systems. Of special 

relevance is Part 4: Requirements and test methods for container valve assemblies and their 

actuators.
Chapter 4 Application of the F-gas Regulation 110 

Article 3(6): Records 

Operators of the applications referred to in Article 3(1) containing F-gas charges 3 kg shall 

maintain records on the quantity of F-gases installed, added, and recovered. They shall also 

maintain records of other relevant information described in detail in Article 3(6) and in Article 

2 of (EC) No 1516/2007 (stationary refrigeration, air conditioning, heat pumps) and (EC) No 

1497/2007 (fire protection sector). These records shall be made available upon request to 

the competent authority and to the Commission. 

Status of record keeping and analysis of records by Member States 

The survey undertaken within this project investigated the status of record keeping by 

operators and whether the authorities request these records for control purposes. 

Records are kept either on paper and/or electronically181. 

The survey shows that authorities although they request records for control purposes usually 

do not analyse the records in a systematic and comprehensive manner. The authorities from 

16 Member States report that they requested in the past “representative samples of records 

... in order to review them” (table 4-14) at least “during inspection campaigns”, “in some 

cases” or “only when the compliance of the operator is being checked”. The checks are 

conducted by environmental inspectorates, local health authorities, occupational health 

authorities, fire brigades (in case of the fire protection sector) etc. 10 Member States 

answered that they have not requested records for inspections so far (2 Member States: no 

data). 

Table 4-14: Analysis of records according to Article 3(6) by EU-27 authorities 

Number of Member States 

 Yes No Not reported 

Records requested 16 10 1 

Records analysed 4 21 2 

National assessment report 2 24 1 

Source: Questionnaires to EU-27 authorities. 

Only 4 Member States explained that they had analysed the records to some extent.182 Finally, 

2 Member States have prepared national assessment reports on the results of their inspections 

in former times (the Netherlands, NOKS-report from 2000) or recently (Latvia), but these 

reports are not based on systematic evaluation of record keeping by the operators of the 

equipment. 2 Member States are planning such assessments (Germany and Luxembourg). 

Analyses of records show – as far as results are reported – that they do not always include 

all necessary data and often are not completed correctly. The quality of record keeping 

depends not only on the awareness of the operators and qualification/certification of 

personnel but also on enforcement and control by authorities. This correlation is also 

confirmed by industry.183 

 

181 Records: In 11 Member States only or “mostly” on paper; in 12 Member States records both on 

paper or in electronic format are possible, in 2 Member States only electronic records. 2 Member 

States have recently introduced electronic records. No data from 2 Member States. 

182 These Member States are BE (Flemish Region), BG, LV, and NL. 183 Statement from AREA: “In general, the lower the enforcement, the more customers are reluctant to 

spend any money on having logbooks prepared.” 
Chapter 4 Application of the F-gas Regulation 111 

Stationary refrigeration, air conditioning and heat pumps 

The survey among industry (1st quarter of 2010) revealed that frequency and quality of record 

keeping vary strongly by size and type of companies and shows high differences between 

regions. 

− Record keeping is more common or widespread amongst supermarket operators 

(chains, franchised stores), major public institutions like hospitals and in general in 

industry (food processing, chemical and pharmaceutical, cold stores and logistics etc.). 

− Records are rare among operators of small supermarkets (groceries, convenience 

shops), shops with light commercial equipment (e.g. bakeries, butchers, restaurants, 

flower shops), shopping malls, leisure institutions (sports, cinema etc.), and office 

buildings (banks, insurances), hotels or canteens. 

− An estimate of the percentage of operators maintaining records is shown in table 4-15. It 

summarises estimates from five Member States, based on the expertise from seven 

companies. The share is relatively high among operators of equipment in the sector of 

industry (40->80%), large supermarkets (40->80%), large commercial applications 

(hospitals, banks, insurances etc.: 40-70%) and rather low among operators of small 

shops and businesses relying on small commercial equipment. 

Table 4-15: Shares of operators maintaining records according to Article 3(6) 

“Do the operators who are customers of your company 

and who own systems above 3 kg charge have 

logbooks on their installation?” 

DE* UK** FR*** ES* EL* 

 

5 5 3-4 3 3 

Supermarkets 

Large (chains) 

Small (franchised stores; groceries, convenience 

stores etc.) 

n.a. 2 2 1 1 

Small commercial applications 3 1 1-2 1 1 

 

4-5 4 3-4 4 4 

Large commercial applications 

Hospitals, banks, insurances, hotels, shopping malls 

Canteens, Leisure (sports, cinema) 4 2-3 n.a. 1 1-2 

Industrial applications 4-5 5 4-5 3-5 4-5 

* Clients of one company; ** clients of three companies; *** one company plus AFCE. n.a.: no answer 

1: Few operators (<20%) have records; 5: All operators (80%) have records. 

Source: 7 installer and service companies and national associations (EPEE member) 

− According to large internationally operating manufacturing and service companies in this 

sector, ca 50% of their customers in France and UK maintain records. Belgian 

contractors from the small and medium sub sector (charges of 3 kg to 30 kg) likewise 

confirm that <50% of their clients maintain records. 

− One internationally operating manufacturing and service company provided an estimate 

of frequency of record keeping in percentage of operators for some Member States (own 

clients of the company excluded) as follows: The Netherlands = 100%, Germany = 70%, 

Great Britain = 60%, Spain = 10%, Greece = nearly 0%. 

− Records often are not kept in an accurate manner. Table 4-16 shows the judgement of 

industry experts on the quality of records kept by operators in 3 Member States (UK, FR, 

IT). The data represent the top level of accuracy, because these installers and service 
Chapter 4 Application of the F-gas Regulation 112 

companies and associations mostly work for medium and large operators which were 

generally found to be more compliant than small companies. 

Table 4-16: Quality of records (FR, UK and IT) – expertise from stationary refrigeration, air 

conditioning and heat pump industry 

“How precisely are the logbooks filled in with regard to”: FR UK IT 

- Dates and results of leakage inspections and servicing 4-5 4-5 3 

- Refrigerant type and quantity by refrigerant circuit 4-5 4-5 1 

- Quantities recovered/added during service, repair, disposal 4 4 3 

- Identification of company, technician, certifications 4-5 4 5* 

1: not precise (<20%); 5: very precise (80%); * no certification in place 

Source: Seven installer and service companies and national associations (EPEE member) 

Records from cold storage industry are assumed to be precise or very precise, according to 

the relevant association (ECSLA members, FR, DE, NL, and ES). 

Fire protection sector 

The fire protection industry from Great Britain and Germany (installers and service 

companies) estimate that about 50% of the operators of systems (charges 3 kg) maintain 

records according to Article 3(6) of the F-gas Regulation. Industry comments that the low but 

increasing figure represents the ongoing replacement of existing records according to ISO 

14520 by those containing the text required by Regulation (EC) No 842/2006.184

Awareness of operators of obligations according to Article 3 

The awareness of the operators is important for all measures of containment. 

It was generally communicated by industry stakeholders that operators’ compliance and 

awareness of the requirements of the F-gas Regulation is highly dependent on enforcement 

by authorities. 

Stationary refrigeration, air conditioning and heat pumps

Based on discussions with industry experts from small and medium-sized contractors as well 

as from large international service companies in this sector, about 50% of the operators do 

not know about their obligations. 

A clear difference in awareness between large companies and operators of large plants 

(industry, large supermarkets, and large commercial applications) on the one hand and small 

companies and operators of small equipment on the other hand has been stated. The 

awareness is low in the sector of small equipment with low refrigerant charges, but relatively 

high among operators with large equipment. 

Differences between segments/applications of F-gases are indicated in table 4-17: 

 

184 “ISO 14520 required records of service to be kept for HFC fire protection systems from 2000. There 

is very little difference between the log books previously required under ISO 14520, and those 

currently required by EC 842/2006. However, the industry is currently undertaking the transition from 

previous log books to those that contain the wording according to EC 842/2006. The majority of 

systems now have the current log book in place.” ASSURE, Review of Regulation (EC) No 842/2006 

on certain fluorinated greenhouse gases. Response to Öko-Recherche GmbH Questionnaire on Fire 

Protection Systems, May 2010. 
Chapter 4 Application of the F-gas Regulation 113 

Table 4-17: Awareness of operators of obligations according to Art 3 

“Are the operators aware of their obligations?” DE* UK** FR*** IT**** ES* 

 

5 5 4 4 3 

Supermarkets 

- Large (chains) 

- Small (franchised stores; groceries, convenience 

stores etc.) 

4 2 2 1 1 

Small commercial applications 4 1-2 1 1 1 

 

4-5 4-5 4 4 4 

Large commercial applications 

- Hospitals, banks, insurances, hotels shopping malls 

- Canteens, Leisure (sports, cinema) 4 3 3-4 2-3 1-2 

Industrial applications 5 5 5 4-5 4 

* HVAC/HP, clients of one company; **SRAC/HP, clients of three companies; *** SRAC/HP, one 

company plus one national association; **** one national association. 

1: Few operators (<20%) aware of their obligations; 5: All operators (80%) aware of their obligations. 

Source: 7 installation and service companies and national associations (EPEE member) 

Similar data are reported by service companies from the Baltic (Estonia) and by contractors 

from Belgium. Both underline that operators of major applications (such as supermarkets, 

retails, industrial applications) are more aware of their obligations than operators of small 

applications (small shops), and they maintain records and perform leak checks more 

regularly than operators of small applications. 

Table 4-17 indicates a north-south gradient in terms of awareness. 

Table 4-18, based on additional information, also shows significant differences between 

Member States. 

Table 4-18: Awareness of operators of their obligations according to Art 3 (6 Member States) 

Percentage of operators “aware” >60% (“4”) >40% (“3”) >20% (“2”) <20% (“1”) 

France, Great Britain, Germany X 

Italy X 

Spain X 

Greece X 

1: Few operators (<20%) aware of their obligations; 5: All operators (80%) aware of their obligations. 

Source: 7 installation and service companies and national associations (EPEE member). 

The same is reported about the cold storage and logistics industry: High awareness (>80%) 

in Germany and the Netherlands, less awareness (>60%) in France and low awareness 

(<20%) in Spain. The association presumes that awareness is much higher within large 

companies (>50 employees) than in small ones (data submitted by ECSLA). 

Awareness of the provisions of the F-gas regulation is generally considered to be better 

amongst contractors than among operators.185 Staff of specialized technical companies 

(contractors) have better knowledge and higher awareness than staff from companies that 

 

185 In 2008, in Ireland’s SRAC sector, awareness of the F-gas regulation was regarded fairly well 

amongst contractors (“well aware”: 50%) although it was generally felt that most customers had a very 

poor understanding of the requirements (“well aware”: 5%; “not aware”: 66%). Awareness was 

considered to be high amongst multi-national end user companies but not so high at smaller 

companies. DOEHLG F-gas report 2008: Department of the Environment, Heritage and Local 

Government: Study on Meeting the Requirements of European Regulation 842 on Certain Fluorinated 

Greenhouse Gases (F-Gases). A Report by Enviros Consulting Ltd., Dublin 2008, p. 40. 
Chapter 4 Application of the F-gas Regulation 114 

work only occasionally in this sector (mechanical and electrical contractors). Such companies 

often install AC systems during construction projects, but rarely work in service and 

maintenance. 

It has been reported that the awareness of requirements related to containment measures 

and record keeping was higher in industrial facilities, especially facilities licensed under 

Directive 2008/1/EC concerning integrated pollution prevention and control (IPPC Directive), 

than in small commercial applications (e.g. retail). 

Fire protection sector

For the fire protection sector, it is assumed that about two-thirds of the operators in the UK 

and Germany (from where data has been available) know their obligations (estimate from 

EUROFEU). 
Chapter 4 Application of the F-gas Regulation 115 

Status of application of containment measures 

All in all, the reported qualitative estimates show that the state of application of the provisions 

on containment widely differs within EU-27. Delay of the application of relevant requirements 

of the F-gas Regulation is found in most Member States. The extent to which containment 

measures according to Article 3 are applied in the individual Member States and in the 

individual stationary applications of F-gases after entry into force of Regulation (EC) No 

842/2006 depends on several factors: 

− Entry into force of national legislation for certification of personnel and companies; 

− Status of implementation of other F-gas related legislation, e.g. IPPC Directive which 

requires licensing of industrial facilities with high pollution potential; 

− Structural disparities between sectors of F-gas applications (SRAC/HP sector: 

industry, big supermarket chains, large commercial applications vs. small shops, light 

commercial applications, etc.; the fire protection sector: operators with maintenance 

contracts vs. service by demand etc.); 

− Knowledge/awareness of operators and service companies about the requirements of 

the F-gas Regulation; 

− Intensity of enforcement of the F-gas Regulation and the extent of control and 

sanctioning in case of infringements. 

Leak checks: Leak checks according to Article 3(2) at stationary refrigeration, air conditioning 

and heat pump equipment are not performed consistently in all Member States. Experts from 

industry note comparably high compliance of operators of large equipment and low 

compliance of operators of small equipment. 

In Member States, where regular leak checks have already been undertaken on the basis of 

technical standards, voluntary commitments, or legal obligations, the frequency of leak 

checks according to Article 3 is higher compared to other Member States. 

Industry stakeholders assume that since entry into force of the F-gas Regulation the 

frequency of leak checks has increased to some extent, however, with considerable 

differences between Member States. Quantitative information supporting this assumption is 

not available. 

For the fire protection sector a comparably high level of compliance is reported. Leakage 

checks have already been carried out for a long time on the basis of specific technical 

requirements (e.g. ISO 14520) and hence an increase of the frequency specifically caused 

by the F-gas Regulation is not observed. 

Leakage detection systems according to Article 3 (3) have been installed rarely so far in the 

SRAC/HP-sector, pursuant to information from industry experts. Apparently, upgrading of 

older equipment with leak detection systems takes place to a small extent only. In contrast 

internationally operating installers and service companies report a trend which indicates 

slight increase. Only the cold storage industry claims high numbers of equipment with 

leakage detection systems, which have already been in place over a long time period. 
Chapter 4 Application of the F-gas Regulation 116 

The fire protection sector reports a high rate of installed leakage detection systems. For two 

Member States a rate of 75% (UK) and 99% (DE) is reported for installations erected after 4 

July 2007. Upgrading is often considered difficult. The sector explains the high equipment 

rate with long term experience of the industry concerning relevant requirements. ISO 

standard 14520 is prevalent throughout Europe in this sector. 

Record keeping and quality of records: Industry communicates that in the stationary 

refrigeration, air conditioning and heat pump sector no more than half of the operators 

maintain records. The compliance level by sub-sectors and Member States is similar to that 

of leakage checks: high percentages are typical for industry, large supermarkets and large 

commercial applications, low percentages are typical for small enterprises and light 

commercial equipment. There is also a north-south gradient in the frequency of record 

keeping. The quality of records, where they exist, is often criticized because of insufficient 

accuracy. 

In the fire protection sector, records have been kept so far in accordance with ISO 14520. 

Industry communicates that about half of the companies have not yet changed to records 

according to F-gas Regulation. 

Awareness of the operators: According to the information from small and medium-sized 

contractors, as well as from large international service companies in the SRAC/HP-sector, as 

many as half of the operators do not know about their obligations. Firstly, there is a clear 

difference in awareness between large companies and operators of large plants (industry, 

large supermarkets, and large commercial applications) and small companies and operators 

of small equipment. Secondly, it is understandable that staff of specialized companies have 

better knowledge and higher awareness than staff from companies that work only 

occasionally in this sector (mechanical and electrical contractors). Thirdly, a clear north-south 

gradient in terms of awareness is reported. 

For the fire protection sector, it is estimated that about two-thirds of the operators in UK and 

Germany (from where data has been available) are aware of their obligations. 

Control and enforcement: It was generally communicated by industry experts that operators’ 

compliance with and awareness of the requirements of the F-gas Regulation and its 

containment provisions is highly dependent on enforcement by the authorities. According to 

information from authorities, records from operators (“logbooks”, usually in paper form, but 

often electronic) have been requested randomly for control in more than half (16) of the 

Member States in the past few years. There is de facto no comprehensive evaluation of 

these records in the Member States. 
Chapter 4 Application of the F-gas Regulation 117 

4.2.6 Application of recovery provisions (Article 4)

Article 4(1) requires recovery of F-gases from stationary applications by certified personnel. 

Paragraph 1 covers the following stationary applications: 

− Cooling circuits of refrigeration, air conditioning and heat pump equipment; 

− Equipment containing F-gas based solvents; 

− Fire protection systems and fire extinguishers; 

− High-voltage switchgear. 

The article applies to all equipment covered by its provisions irrespective of the quantity of Fgases they contain. Operators of these types of stationary equipment are required to 

establish arrangements for proper recovery of F-gases (i.e. collection and storage of F-gases 

from equipment or machinery) by personnel certified according to Article 5 to ensure their 

recycling, reclamation or destruction. 

Recovery for the purposes described in Article 4 shall take place before the final disposal of 

that equipment and, when appropriate, during its servicing and maintenance. 

The purpose of the provisions of Article 4 is the following: Firstly to avoid emissions at 

recovery by qualified personnel. And secondly, that the quantity of recovered F-gas and the 

quantity of F-gas returned for recycling/reclamation/destruction is increased and F-gas 

emissions are thereby reduced. The intention of Article 4 is to contribute to emission 

reduction during recovery and through extension of recovery. The main objective is the 

reduction of disposal emissions. 

Recovery, recycling, reclamation and destruction – practice and infrastructure 

The term “recovery”, as used in the F-gas Regulation,186 does not exclusively refer to the 

removal of F-gas from the equipment with the objective to supply it to an external 

recycling/reclamation/destruction facility. The term also stands for temporary removal of the 

F-gas during service or maintenance before reuse in the same equipment (“on site 

recycling”). To give an example: SF6 is removed from high-voltage switchgear equipment 

during mid-term maintenance, cleaned and afterwards refilled in the same equipment. This 

operation falls under “recovery” for onsite recycling and has to be performed according to 

Article 4 by certified personnel.187 

The quantities recovered and subsequently recycled on site are normally not included in 

statistics on recovery and recycling. Quantities referred to as “recovered” in statistics are only 

quantities which have been definitely transferred to facilities for 

recycling/reclamation/destruction. 

Quantities recovered and recycled on site should be included in the equipment records 

required by Art 3. 

Little is known about the mass flows of recovered quantities before disposal of equipment. 

 

186 (EC) No 842/2006, Art 2, Definitions: “14. ‘Recovery’ means the collection and storage of 

fluorinated greenhouse gases from, for example, machinery, equipment and containers”. 

187 Certificates issued under (EC) No 305/2008 concern personnel recovering F-gases from highvoltage switchgear, not personnel involved in installation, maintenance or servicing of the equipment. 
Chapter 4 Application of the F-gas Regulation 118 

The emission factors assumed in the model AnaFgas (annex III) for end of life (WOM 

scenario) show that the recovery efficiency before disposal is presently 50% in many 

sectors. Recovery rates are relatively high, up to 70% in larger installations and for 

equipment which is maintained systematically. Barrault and Clodic (2008) estimate that 2% 

or less of refrigerant is recovered from small equipment at end of life. For larger equipment 

they estimate a recovery rate of 70-80%.188 

Likewise, nothing is known about F-gas quantities which have been recovered prior to 

disposal of equipment, and are reused for recharging other equipment instead of being 

properly recycled, reclaimed or destructed. In Austria, for example, that amount is estimated 

by industry experts at about 2 % of the total market for HFCs in the stationary refrigeration, 

air conditioning and heat pump sector. 

Legal Framework 

The legal framework for proper recovery of F-gases includes European and national 

legislation on waste/hazardous waste including national legislation on WEEE (see section 

3.3.2 on policy interactions). 

Used HFCs and SF6 are classified as hazardous waste189. According to the F-gas 

Regulation, the operator of equipment is responsible for the recovery of the F-gas and its 

proper transfer to a company for recycling/reclamation/destruction. 

In some Member States specific arrangements for the recovery of F-gases have been 

established based through additional national requirements including the responsibility of 

manufacturers and distributors of F-gases to take those back after use (e.g. France, 

Germany, Sweden). In practice many of the distributors take back recovered F-gases and 

provide their customers with special recovery cylinders. 

Common practice of recovery

Companies and contractors describe the common practice of recovery in general as the 

following: The personnel handling/servicing/maintaining the systems containing F-gas 

(machinery, equipment, containers) collect F-gas quantities from the system undergoing 

service or disposal and store it in a container. The recovered and stored F-gas is – usually 

after a basic cleaning process (filtering) – used for refilling of the system (i.e. recycling) or – 

not treated at all and sent to a facility for reclamation or destruction. 

Differences between Member States regarding recovery result from legal circumstances 

(status of implementation/application of the F-gas Regulation including particularities of 

national legislation and voluntary agreements) and from the availability of technical 

requirements and logistics for the reclamation and destruction of F-gases within the Member 

States. 

Availability of infrastructure for reclamation and destruction

Table 4-19 and figure 4-5 present data on the availability of operating190 F-gas reclamation 

and destruction facilities in the EU-27 based on information from authorities and industry and 

 

188 S. Barrault/D. Clodic, Quantités récuperées et projection futures, Colloque AFCE, 9 Oct 2008. 189 HFC: Waste category 140601*; SF6: Waste category 160504*. 190 In some cases companies had the licence to destruct F-gases but did not operate for cost reasons 

(amount of F-gas offered for destruction too low compared to operating costs). Companies with 

several facilities normally concentrate OCF/F-gas for destruction at one site. 
Chapter 4 Application of the F-gas Regulation 119 

on data from ICF 2008/2010. In EU-27, 41 facilities for reclamation of F-gases and 24 

facilities for destruction of F-gases exist as of beginning of 2010. 

The figures in table 4-19 are lower than the data from ICF191 which seem to contain a number 

of collecting points for F-gases. These collecting points are facilities which accept F-gases 

for reclamation/destruction without being equipped for the technical process of 

reclamation/destruction themselves. They collect and store the material and supply (mostly 

export) it to other facilities for reclamation/destruction. Likewise, decommissioning sites for 

refrigerators are able to recover but not to destroy F-gases. The overview shows that 12 of 

the 27 Member States do not have reclamation facilities and 15 Member States do not have 

destruction facilities within their territory.192 

There is no information about which F-gases by type are accepted for reclamation by these 

facilities. 

Figure 4-5: Availability of reclamation and destruction facilities for F-gas refrigerants (April 

2010). Blue/green striped: Reclamation + destruction. Green: only Reclamation. Blue: only 

Destruction. Red: No facilities available. 

 

191 ICF International: Analysis on the Recovery of Fluorinated Greenhouse Gases in EU-27 in the 

Period 2004-2007 and Determination of Options for Further Progress, October 2008, p. 18; Identifying 

and Assessing Policy Options for Promoting the Recovery and Destruction of Ozone Depleting 

Substances (ODS) and Certain Fluorinated Greenhouse Gases (F-Gases) Banked In Products and 

Equipment, Prepared by: ICF International, March 2010 – Final Report. 

192 ICF assumes for 2008 and for 2010 that 10 Member States are without a reclamation facility. With 

regard to F-gas destruction, ICF assumes, in 2008 11 Member States without a facility and in 2010 15 

Member States. The number of F-gas destruction facilities indicated in the ICF studies halved from 

2008 to 2010. 
Chapter 4 Application of the F-gas Regulation 120 

Table 4-19: F-gas reclamation and destruction facilities 2010 

 Number of reclamation 

facilities 

Number of destruction 

facilities 

AT 0 0 

BE 3 1 

BG 2 0 

CY 0 0 

CZ 5 1 

DE 3 52

DK 0 2 

EE 0 0 

EL 11 0 

ES 4 0 

FI 0 1 

FR 5 3 

HU 3 2 

IE 0 0 

IT 3 3 

LT 11 0 

LU 0 0 

LV 0 0 

MT 0 0 

NL 3 0 

PL 1 1 

PT 0 0 

RO 1 1 

SE 1 2 

SI 0 0 

SK 0 0 

UK 5 2 

Total 41 24 1 License since March 2010 (Greece) and June 2010 (Lithuania) 

2

 One company with 4 facilities referred to as 1 facility (only 1 out of the 4 facilities is operating). 
Chapter 4 Application of the F-gas Regulation 121 

Status of RRRD by sectors 

Stationary refrigeration, air conditioning and heat pumps

Recovery of F-gases from cooling circuits of refrigeration, air conditioning and heat pump 

equipment is normally done by contractors carrying out installation, service and maintenance 

of the equipment. Larger operators may have their own service. 

Recycling – reclamation – destruction 

Recycling normally takes place on site and is carried out by the same contractors, i.e. service 

and maintenance companies. It is done to clean the refrigerant by removing oil and other 

pollution and by drying the refrigerant. Special equipment and standards for recovery and 

recycling exist.193 F-gas quantities recovered and recycled onsite are not part of reported 

data on recovery. In addition to onsite recycling, a simple recycling process different from 

reclamation can also be done by specialised companies. From the total amount of HCFC and 

HFC refrigerants, which were reported by manufacturers and distributors as recycled, 

reclaimed or destructed in France in 2008, only 0.1% was classified as recycled.

194 

The number of specialised companies involved in recovery and onsite recycling of F-gases is 

large. AREA reported a number of around 45,000 small and medium-size contractors in the 

stationary refrigeration, air conditioning and heat pump sector from 16 Member States. For 

France alone, AFCE adds to this number another 10,000.195 We expect that the total number 

of specialised companies carrying out activities related to refrigerant circuits in this sector in 

the EU-27 can be estimated at >100,000. A high proportion of them are small businesses. 

The average number of employees within these small businesses is about 10 in Germany 

and 3 in Italy, for example. According to our survey at least two thirds of the contractors are 

involved in onsite recovery and recycling. 

In contrast to recycling, reclamation involves chemical reprocessing of the recovered used Fgas to essentially its virgin specifications in order to meet a specified standard or 

performance. This is a technically much more elaborate and costly, analytically controlled 

process (filtration, distillation, adsorption and other separation technologies), which cannot 

take place onsite, but only in special reclamation facilities (manufacturers, wholesalers). In 

general, only pure recovered refrigerants can be reclaimed since separation of refrigerant 

blends is technically difficult and very costly. According to ICF 2008, facilities were unable to 

reclaim about one third of gases collected (main reasons: mixtures; high oil content)196. Field 

instruments to analyze refrigerants are available, however are not very widespread for cost 

reasons in some of the Member States. 

Since reclamation can be carried out in appropriate facilities only, it is possible to record and 

report reclaimed amounts in statistics. The percentage of reclaimed CFC/HCFC/HFC 

 

193 ISO 11650 „Performance of refrigerant recovery and/or recycling equipment”. Cf. UNEP, 2010 

Report of the Refrigeration, Air Conditioning and Heat Pumps Technical Options Committee, Draft, 

chapter 11. 

194 ADEME, Rapport annuel sur la mise en oeuvre de l’Observatoire des flux de fluids frigorigènes. 

Données 2008, Janvier 2010, p.32. 

195 AREA Reply to Öko-Recherche Questionnaire on F Gas Review, 16 April 2010 ; AFCE (Alliance 

Froid Climatisation Environnement), François Heyndrickxs, written communication, 14 April 2010. 

196 ICF International: Analysis on the Recovery of Fluorinated Greenhouse Gases in EU-27 in the 

Period 2004-2007 and Determination of Options for Further Progress, October 2008, p. 21. 
Chapter 4 Application of the F-gas Regulation 122 

refrigerants was just under 82% of the total amount of recycled, reclaimed or destroyed 

refrigerant in France in 2008.197

Destruction of F-gases by incineration takes place mostly in specialized waste incineration 

plants equipped with high temperature incinerators. In addition, other technologies can be 

applied (reactor cracking; plasma arc technology).

198

Since non-combustible F-gases, delivered in cylinders, have to be dosed for hightemperature decomposition and fed in the combustion process without emission loss, 

devices for connecting the gas cylinders are required. Only a few plants which are principally 

able to destruct F-gases by high-temperature incineration have the necessary appliances for 

feeding-in gases. This is usually dependent on the volume of the quantity of waste gases 

supplied. 

Recovery – quantitative data 

Quantitative data on recovered F-gas refrigerants hardly exist. Some data is available from 

France and UK. Data from service companies recovering F-gases for 

reclamation/destruction, and from companies executing the reclamation and destruction, are 

not included into centralized databases in the Member States. 

The French Association of companies active in the refrigerant sector, SNEFCCA199, reports 

annually on refrigerant purchasing and recovery in SRAC sector. The data for the years 

2001-2009 are included in table 4-20 and relate to the recovery of CFCs, HCFCs and HFCs. 

The amount is based on the annual use of HCFCs and HFCs. The percentage of recovery is 

4-6% in the annual purchase of refrigerants. Since 2006, a slight increase of the percentage 

of F-gas recovery can be observed. 

Table 4-20: Annual purchase and recovery of HCFC- and HFC-refrigerants in the French 

stationary refrigeration, air conditioning and heat pump sector 2001-2009 (t and %)

2001 2002 2003 2004 2005 2006 2007 2008 2009 

Purchase 

(HCFC + HFC) 11,293 11,829 11,572 12,580 13,120 12,131 12,810 12,570 11,965 

Recovery CFC + 

HCFC + HFC 478 486 690 570 545 565 585 610 720 

Recovery (%) 4.2 4.1 6.0 4.5 4.2 4.7 4.6 4.9 6.0 

Destruction in % 

of recovery 65.5 47.7 56.6 53.8 44.3 45.8 

Source: SNEFCCA 2010 

The statistics published by ADEME for the first time for 2008 on refrigerant sales in France, 

include information from 83% of French refrigerant manufacturers and distributors (table 4-

21). They indicate sales of about 9,800 t of HCFCs and HFCs on the French market in 2008. 

The quantities of CFCs, HCFCs and HFCs returned is 361 t or 3.7% of the refrigerant 

purchase.200 The proportion of the "treated" (= destruction + reclamation + recycling) 

 

197 ADEME 2010, p. 32 (quantities reported by distributors and manufacturers). The total amount of 

these refrigerants recycled, reclaimed or destroyed was 451 t (cf. table 4-21). 

198 ADEME 2010, p. 32. 199 SNEFCCA: Syndicat National des Entreprises du Froid, d'Equipements de Cuisines 

Professionnelles et du Conditionnement de l’Air. The number of companies of the industry is indicated 

with 3,100. Cf. www.snefcca.com. 

200 The greatest proportion is R22 and R11. The share of HFCs out of the returned quantity is 41%. 
Chapter 4 Application of the F-gas Regulation 123 

refrigerant is 4.6%. Out of this quantity, ~18% were destroyed, ~82% were reclaimed. The 

percentage of recycling of ca. 0.1% was almost negligible.201 

Table 4-21: Recovery, reuse and treatment of refrigerants in the French stationary refrigeration, 

air conditioning and heat pump sector 2008 (t and %) 

Sales charge recovered reused 

on-site „treated“ 

Producer / distributor 

metric tonnes 9,787 - 361 - 451 

% 100 - 3.7 - 4.6 

43 operators 

metric tonnes - 80 3.9 7.1 21 

% 100 4.9 9 26 

ADEME 2010 

For the same year, reports have been delivered by 43 operators (<1% of the total number of 

operators with attestation).202 They communicated a recovery of 4.9% compared to the 

quantity of refrigerant charged into equipment. 80% of the recovered fluid was returned to 

dealers. 21 t were treated by the operators. 

Comparatively high is the amount of refrigerants that have been recovered and recycled onsite (reused on-site) which ranges at 7.1 t or ca. 9% of the 80 t reported as filled-in. 

The recovery data from ADEME are in the same order as the SNEFCCA data. They don’t 

show a trend of quantities recovered and are therefore not yet suitable to draw conclusions 

on the effectiveness of the F-gas Regulation. 

In UK, the percentage of used HCFC- and HFC-refrigerants returned for reclamation or 

destruction compared to the annual purchase increased from 2007 to 2009 from about 10% 

to about 12% (table 4-22). The increase is due to increasing quantities of R-22 returned for 

reclamation, and does not refer to increasing quantities of returned F-gases. 

Table 4-22: Annual purchase and recovery of HCFC and HFC refrigerants in UK (t and %) 

2007 2008 2009 

Purchase (HCFC + HFC) (t) 9,655 9,320 9,792 

Recovery HCFC + HFC (t) 979 971 1207 

Recovery HCFC + HFC (% of 

purchase) 

10.1 10.4 12.3 

Refrigerants destroyed 587 507 436 

Refrigerants reclaimed 392 460 764 

R-22 reclaimed 205 210 522 

HCFC + HFC recovered without 

R-22 reclaimed 

774 721 685 

The data on recovery of HCFC- and HFC-refrigerants available today show a low level of 

recovery and only a slight increase of recovered quantities which is primarily due to increase 

of HCFC-22 quantities returned for reclamation203. This indicates little effectiveness of 

recovery measures according to Article 4. 

 

201 The difference between 361 t “recovered” and 451 t “treated” in 2008 is due to treatment of 90 t of 

refrigerants recovered before 2008 (ADEME 2010, p. 31). 202 These 43 operators had purchased 111 t of refrigerant and filled 80 t in SRAC systems. 203 This is confirmed also for the Netherlands where HFCs today account for <10% of the substances 

taken back by producers within a take back scheme, while the majority is HCFC-22. (Personal 

communication, Linde Gas Netherlands, 16 June 2011). 
Chapter 4 Application of the F-gas Regulation 124 

Fire Protection Systems

The fire protection sector is characterized by the following particularities: 

The extinguishing agent is stored in a container and will be released in case of fire. Unlike in 

the stationary and mobile refrigeration and air conditioning sector and the high voltage 

switchgear sector, on site refilling and on site recycling do not take place. After intended 

release in the event of fire or in case the equipment is malfunctioning (leakage, pressure 

drop), the containers are returned to the manufacturers. Re-charging, repair work and 

recovery is always done off site by specialist personnel. 

As long as the extinguishing agent is contained, it does not get polluted by impurities, and 

reclamation is not relevant. The industry points out that recovery and recycling of F-gas fire 

extinguishing agents has been only carried out to a small extent, since HFCs in fire 

protection have only been in use since the mid 1990s. As the lifetime is 15 years or longer, 

most systems are still in use. 

According to the industry, no data (apart from internal company records) on recovered F-gas 

quantities and F-gas quantities transferred to the manufacturer for recycling/destruction are 

available. 

Recovery, recycling and destruction of F-gas fire extinguishing agents already took place 

before the F-gas Regulation came into force. There is no evidence of an increase in 

recovery, recycling and destruction in response to the implementation of the F-gas 

Regulation. 

High-Voltage Switchgear

SF6 is used as an insulating gas in electrical equipment for the transmission of electricity with 

a rated voltage of >1 kV (high-voltage (HV) switchgear) such as switchgear, instrument 

transformers, gas insulated transmission lines, high-voltage bushings, capacitors and power 

transformers. According to the industry (T&D Europe), since 1995 the HVS industry has 

developed measures to systematically reduce SF6 emissions. National voluntary agreements 

to reduce SF6 emissions exist at least in France (2005), Germany (1996; 2005), and Spain 

(2008). 

In general, the use and handling of SF6 in electrical equipment >1 kV includes the following 

characteristics: 

With regard to recovery and direct reuse on site (recycling), it is known that during 

maintenance of HV switchgear equipment, recovery of SF6 occurs from closed pressure 

systems >52 kV including immediate reinjection of the recycled SF6 into the system after 

maintenance operations. 

For repair and maintenance of HVS >52 kV in Germany it is estimated that more than 90 % 

of the SF6 quantity recovered will be recycled on site and reinserted into the HVS (SF6 quality 

according to IEC 60480). Sealed pressure systems (<52 kV) do not need recovery during 

normal operations life, only before disposal. According to industry (T&D Europe), no 

database on quantities recycled on site exists. 

Recovery for external recycling and for reclamation/destruction: SF6 is removed either on site 

and returned e.g. to a gas manufacturer or the SF6 charged equipment is completely 

transported to gas or equipment manufacturers for recovery of F-gas quantities. After a gas 

analysis according to IEC 62271-303, the gas may be reused if the quality is in accordance 
Chapter 4 Application of the F-gas Regulation 125 

with IEC 60480 (recycling) or it is reclaimed or destroyed. On the European level, according 

to T&D Europe, statistics on quantities are only available to companies involved (gas 

manufacturers, distributors or reclamation/destruction companies). 

Facilities for reprocessing (reclamation) of SF6 are available in Germany and France. 

Facilities for the destruction of SF6 are available in Germany, France and the UK. Other 

facilities are not known; therefore recovered SF6 is often subject to cross border shipment. 

Since 1990, Solvay (SF6 producer) has established a “ReUse” concept (reclamation and 

destruction) for SF6.

204 This concept offers appropriate packaging and transport, analysis of 

used SF6, re-introduction of the used F-gas into the SF6 production process (annual quantity 

of approximately 40 t) or destruction by incineration. Several companies in France, 

Netherlands, Belgium, Austria, Finland, Spain, Great Britain, Italy and Greece participate. 

Some quantitative information on SF6 recovery, reclamation and destruction is available from 

Germany. The German voluntary commitment205 on SF6 in HVS includes detailed reporting 

on RRRD to the German EPA. 

The vast majority of operators and manufacturers in Germany take part in the SF6 “ReUse” 

system of Solvay. Since the investment costs for mobile equipment to reclaim SF6 on site are 

very high, reclamation of used SF6 by SF6 producers is the common practice. 

The quantity of SF6 which was supplied for reclamation and destruction by HVS 

manufacturers and operators from Germany in the “ReUse” system did slightly increase 

between 2005 and 2009 (table 4-23). This applies primarily to the amount of SF6 to be 

destroyed. About one-third of the total quantity was delivered by German operators and twothirds by German manufacturers (2008/2009). 

Table 4-23: High-voltage switchgear – SF6 reclamation and destruction 2005-2009 (Solvay 

ReUse system, Germany)

Reclamation Destruction Total 

2005 7.80 1.90 9.70 

2006 10.20 0.11 10.31 

2008 9.40 0 9.40 

2009 9.23 2.52 11.75 

Source: Solvay Fluor GmbH 

The trend for SF6 is as follows. Since the voluntary agreements from 2005 and 2008 included 

already detail commitments to RRRD, the F-gas Regulation will probably not lead to 

significant changes. The SF6 quantities for disposal in Germany will increase from 2015 

onwards for HVS >52 kV, and for HVS <36 kV from 2020 onwards because of the long 

lifetime of the equipment (ca. 40 years, see annex III). 

The national associations of the HVS industry and at least one HVS equipment manufacturer 

claim that national and European waste legislation hampered the cross border transport of 

used SF6 within EU-27, because its shipment would be allowed only when declared as 

 

204 Cf. http://www.solvay-fluor.com/docroot/fluor/static_files/attachments/sf6_e.pdf, p 42f. 205 Voluntary Commitment of SF6 Producers, Manufacturers and Users of Electrical Equipment >1kV 

for Transmission and Distribution of Electric Power in the Federal Republic of Germany on SF6 as an 

insulating and arc extinguishing medium, 1st edition: 1996, current version: 2005. Federal Ministry for 

the Environment: http://www.bmu.de/klimaschutz/downloads/doc/35655.php. 
Chapter 4 Application of the F-gas Regulation 126 

waste, and would hence hinder reclamation and promote domestic incineration of SF6. This 

is, however, difficult to understand, since SF6 has to be declared as waste in both cases 

(reclamation/destruction), and in many countries no possibility for incineration exists. 

Therefore, a preference to destruction for this reason alone is not very likely. 

F-gas based Solvents

F-gas based solvents206 are mainly used for degreasing of metal prior to precision coating 

and in the optics and electronics sector. Equipment can have charges of 50 to 1,200 litres. 

Used solvent is heated to remove impurities (distillation) and the recovered solvent is reused. 

The residue is sent for incineration. Normally it consists of 75% oil/impurities and 25% of 

solvent. 

As of July 2011, 17 Member States communicated that F-gas solvents are not used in their 

country (table 4-2). The quantity used before in 9 Member States was <300 t (model 

description in annex III). The main countries using F-gas based solvents in EU are France 

and the UK. A UK DEFRA report estimates that the bulk of the annual sales are used to 

replace the contaminated residue solvent. Further information on the 

recovery/recycling/reclamation/destruction (RRRD) of F-gas based solvents is not available. 

Recovery for recycling or reclamation of F-gas based solvents is unlikely. 

Control and enforcement by authorities 

Competent authorities from EU-27 Member States were asked about control mechanisms in 

order to monitor compliance with the provisions of Article 4. Most of them referred to 

provisions on control and sanction in the national legislation on F-gases and in the waste 

legislation. Inspection campaigns are reported from less than half of the Member States.207

Other desktop control instruments mentioned are checking of system dossiers, reporting 

obligations etc. But in general it seems that no systematic monitoring of the compliance to 

the recovery provisions is carried out, as expressed explicitly by one Member State (DE). 

 

206 These are blends from which HFC is only a component. Cf. for the following: DuPont, Vertrel – 

Specialty Fluids, 2007; DEFRA, Impact Assessment of the Fluorinated Greenhouse Gases Regulation 

2009, November 2008; DuPont, Pascal Faidy, pers. comm. by Email, 28 April 2010. 

207 These Member States include Belgium, Cyprus, Czech Republic, Denmark, Estonia, Germany, 

Hungary, Ireland, Latvia, the Netherlands, and Slovenia. 
Chapter 4 Application of the F-gas Regulation 127 

4.2.7 Application of reporting provisions (Article 6)

Article 6(1) of the F-gas Regulation requires entities in the European Union (EU) which 

produce and/or import and/or export more than one metric tonne per year of F-gases or 

preparations (blends) containing F-gases, to submit a report by 31 March each year for the 

previous calendar year, starting in 2008. The companies must submit their report to the 

Commission, sending the same information to the competent authority of the Member State 

concerned. 

Reporting includes bulk shipments, including F-gases shipped with the equipment for the 

purpose of charging that equipment. It excludes quantities contained in imported or exported 

equipment (i.e. pre-charged equipment).208 Producers, importers and exporters shall 

communicate any quantities reclaimed or destroyed within the Community or exported for 

recycling, reclamation and/or destruction (cf. Regulation (EC) No 1493/2007). 

Results of the first four reporting years 

The F-gas reporting system builds upon the reporting system for substances that deplete the 

ozone layer (ODS) according to Article 19 of the Regulation (EC) No 2037/2000209. The 

majority of companies obliged to reporting according to the F-gas Regulation have several 

years of experience in collection and submission of relevant ODS data. 

Reporting according to Article 6(1) takes place since 2008 for calendar year 2007. Table 4-

24 shows the F-gas quantities reported by producers, importers and exporters for the years 

2007-2010. The 2010 data are preliminary data. 

Table 4-24: Reported quantities of F-gases according to Art 6(1) for the period 2007-2010 

(metric tonnes) 

2007 2008 2009 2010** 

 t %* t %* t %* t %* 

EU Production 58,037 100 41,647 71.8 35,123 60.5 46,459 80.1 

EU Imports 59,647 100 68,721 115.2 58,904 98.8 70,052 117.4 

EU Exports 23,654 100 19,373 81.9 17,162 72.6 22,074 93.3 

EU Sales 93,126 100 94,043 101.0 85,230 91.5 97,697 104.9 

RRRD in EU*** 426 100 343 80.5 173 40.6 n.a. 

Export for RRRD*** 12 100 48 400 - - n.a. 

n.a. = not yet available. 2007 = 100%; ** 2010: preliminary data; *** RRRD includes only quantities 

from companies obliged to report acc. to Art 6(1), not accounting for specialised RRRD facilities, which 

process by far the largest part of returned F-gas quantities. 

Quality of reported data 

Analyses of the reports from companies for calendar year 2007, 2008 and 2009 have been 

undertaken on behalf of the European Commission210. Some aspects relevant for the 

assessment of the quality of the reporting system are outlined here. 

 

208 (EC) No 1493/2007, Annex part 1, Introduction, 2nd paragraph. 209 In 2009, this Regulation was recast by Regulation (EC) No 1005/2009. 210 Touchdown Consulting sprl 2008: Analysis of Data Reported by Companies in the European 

Community on the Production, Import and Export of Fluorinated Greenhouse Gases in 2007. 
Chapter 4 Application of the F-gas Regulation 128 

− Completeness. The total number of reporting companies for each reported calendar 

year was: 76 for 2007, 80 for 2008 and 88 for 2009. 19 companies that had reported 

for 2007 did not submit a report for 2008. Conversely, 18 companies reported for 

2008 for the first time. Some of these companies stated that they had not been aware 

of their reporting obligation for 2007. Companies from 9 different Member States have 

not submitted reports in one or more years during the period 2007-2009 (2007 and 

2008: 6 MS, 2009: 5 MS). Companies from 3 Member States (AT, LU, and SK) have 

not submitted reports in any year in the entire period 2007-2009. 

In case some companies had not fulfilled their reporting obligations, reported data on 

import/export would be somewhat lower as in reality. As imports exceed exports 

significantly (table 4-24), the sales volumes to the EU market would be slightly 

underestimated. In our view, this hypothetical case is not considered to have a 

serious impact on the total F-gas sales data in the EU. 

− Compliance with reporting obligation. In 2007, seven of 76 companies, and in 

2008, 25 of 80 companies represented more than 95% of the total HFC sales to the 

EU market. The remaining companies accounted for less than 5% of sales and 

exports.211 

It is likely that large companies comply with the reporting obligations more 

consistently than small enterprises. However, relatively lower participation of small 

companies would not significantly distort the picture. Even if 54 additional small 

companies (i.e. two more small companies from each Member State) had not 

reported, the total outcome would increase by only a few percent. 

− Accuracy of sales estimates. A small difference exists between the reported data 

on production, import and exports on the one hand and estimated sales to intended 

applications on the other hand. The sales were estimated higher by 3.4% in 2008 and 

by 11% in 2009. 

The error may be caused by overly high expectations for sales held before the 

economic crisis. It might also be possible that the recording is not accurate at each of 

the companies. The difference, however, is well within acceptable order. 

The overall finding is confirmed that the reported figures are dominated by the accuracy and 

completeness of the companies with the greatest quantities of F-gas sales and exports on 

the European market. 

Control and enforcement by authorities 

The producers, importers and exporters shall send the same reports to the competent 

authorities of the Member State. Responses from questionnaires by competent authorities 

from EU-27 show that authorities from 13 Member States (ca. 50%) have checked the details 

 

Touchdown Consulting sprl 2009: Analysis of Data Reported by Companies in the European 

Community on the Production, Import and Export of Fluorinated Greenhouse Gases in 2008. 

Austrian EPA 2010: Fluorinated greenhouse gases 2009 – Data reported by companies on the 

production, import and export of fluorinated greenhouse gases in 2009. 

211 TouchDown Consulting sprl, 2008, p. 18; 2009, p. 23. 
Chapter 4 Application of the F-gas Regulation 129 

of the reports; 10 authorities have not yet looked into them. (4 did not answer the relevant 

question.) 

The authorities of the Member States were also asked whether all companies in their country 

subject to reporting requirements do actually report. When F-gas producers operate in the 

country, the question was consistently answered "yes". Regarding importers and exporters 

the answer was "yes" in two thirds of the cases. Enforcement measures were not mentioned. 

 

Reporting of recycling, reclamation and destruction 

Reporting according to Art 6(1) includes the F-gas quantities for recycling, reclamation, and 

destruction, to be communicated by producers, importers, and exporters. 

The provisions continue identical provisions set out in the former ODS Regulation (EC) No 

2037/2000 (recast: Regulation (EC) No 1005/2009) relating to “controlled substances”. The 

companies subject to reporting of recycled, reclaimed and destroyed quantities under the Fgas Regulation are usually the same companies that have already been subject to reporting 

under the ODS Regulation. Therefore, the system is well established.212 

It must be pointed out that the information on recovery, reclamation and destruction of Fgases gained through the F-gas reporting system is of very limited use for an overview of the 

total quantities recycled, reclaimed or destroyed within the EU or exported from the EU. 

Reported RRRD includes only quantities from the companies obliged to report according to 

Art 6(1), and does not account for specialised RRRD facilities, which reclaim or destroy by 

far the largest part of returned F-gas quantities. For the year 2008, only four companies 

reported reclamation and destruction of HFC-134a, and three companies reported 

destruction of SF6. As shown in table 4-19 the number of specialised reclamation facilities in 

the EU is at least 41, and the number of destruction facilities is at least 24. Unlike the data of 

production and sales, the data on RRRD are not representative of the EU total. However, 

they can be used as supplementary to data from the specialised facilities, if the European 

Commission wants to obtain a complete picture of the overall RRRD quantities within the EU. 

Therefore, chapter 8 suggests the possibility of introducing reporting obligations for 

destruction facilities similar to the provisions under the ODS Regulation (EC) No 1005/2009. 

Conclusion on the application of the F-gas reporting provisions

The reporting system according to Article 6(1) of the F-gas Regulation is well-established. It 

benefits from the preceding reporting system on ODS, which had been established in the 

1990s for the majority of the present participants. Assuming that all large 

producers/importers/exporters fulfil their reporting obligation, the reported sales and 

 

212 The recast ODS Regulation (1005/2009) requires higher reporting demands of producers, 

importers, and exporters (Art 26 and 27). The ODS data to be reported vary depending on the type of 

undertaking. For example, producers must report quantities produced, placed on the market, as well 

as quantities recycled, reclaimed and destroyed, and stocks. Undertakings in the ODS database that 

did not produce, import, export or destroy ODS in the previous year are required to return a “nil” form. 

The recast regulation also introduced new requirements for destruction plants to report quantities 

destroyed, including quantities contained in products and equipment, directly to the European 

Commission. 
Chapter 4 Application of the F-gas Regulation 130 

production quantities of F-gases are well within acceptable statistical error range. Control 

and enforcement mechanisms seem to be not fully active at this point in time. Reporting of 

recycled, reclaimed, or destroyed quantities as it currently stands is of limited value. 

One-tonne threshold 

Article 10(2)f of the F-gas Regulation requires a review of the “one tonne quantitative limit” 

for the reporting obligation. Chapter 8 discusses this aspect in the context of improved 

reporting systems. 

The reporting obligation under Art 6(1) covers only entities which produce and/or import 

and/or export more than one metric tonne per year of F-gases or preparations containing Fgases. This one tonne limit hardly distorts the total data outcome as it is shown by the 

following calculation: If ten companies213 in each of the 27 Member States would import or 

export a non-reportable quantity of F-gases <1 t, the missing amount would total 270 t at the 

maximum. This amount equals 0.3% of the effectively reported sales quantities (85,180 t) or 

0.5% of the reported import quantities (58,848 t) in 2009. 

The low impact of the one-tonne-limit and the validity of the assumption of ten companies per 

Member State may be illustrated by data from two EU Member States, which serve as 

example: 

• The Estonian customs authorities collect data on all quantities of HFCs imported from 

and exported to countries which are not member of the EU, without any threshold. 

Evaluation of the customs records reached the same conclusion as the calculation 

above. Individual quantities below 1 tonne add up to a total share of ~ 0.3% in the annual 

volume of foreign trade. Estonia is an importer of large HFC quantities, especially of 

HFC-152a, because manufacturing of OCF foams plays an important role. 

• In Germany 35 companies import annually about 10,000 t F-gases from in- and outside 

the EU. In 2007 and 2008 10-11 out of the 35 companies reported according to Art 6. If 

each of the remaining 25 companies imports 1 t at maximum from outside the EU this 

would result in 25 tons or 0.25% of the total import. (But in fact only some of them are 

expected to do so.) 11 out of 35 companies represent about 30% of all importing 

companies. The total figure of European companies reporting according to Art 6 is about 

80. If these represent 30% of the total number of companies, the remaining 70% would 

be about 270 companies. 

Import and export of F-gases contained in pre-charged equipment 

Under Article 6(1), importers and exporters are not obliged to report on F-gas quantities 

contained in equipment. The lack of information on these quantities might have more serious 

consequences for the data quality than missing information on quantities below one-tonnelimit. 

 

213 On average only 4 companies per Member State do report. 10-30% of them represent more than 

95% of the HFC sales of the European market. The number of 10 additional companies per Member 

States is rather high compared to the real number of F-gas importing/exporting companies. 
Chapter 4 Application of the F-gas Regulation 131 

Pre-charged equipment in large numbers imported to or exported from outside EU-27 is 

found in the following sectors: 

− Mobile air conditioning (import and export of motor vehicles) 

− Stationary air conditioning (import of factory-made devices) 

− One component foam (export of cans) 

− High-voltage switchgear (export of SF6-filled systems) 

− Metered Dose Inhalers (export of aerosol cans). 

A survey-based estimate of the amount of F-gases in pre-charged equipment is shown in 

table 4-25214. 

Table 4-25: Import and export of F-gases contained in pre-charged equipment, which is 

currently not covered under reporting obligations in 2008. GWP values according to 3rd IPCC 

Assessment Report 

Import Export 

Sector F-gas metric t CO2 eq (Mt) metric t CO2 eq (Mt) 

Automotive HFC-134a 1,694 2.20 2,389 3.11 

Stat Air Con R-410A 7,002 13.83 negl. negl. 

OCF HFC-134a 0 0 2,100 1.99 

MDI 134a, 227ea 0 0 3,135 4.15 

Switchgear* SF6 negl. negl. 460 10.21 

Total 8,697 16.03 8,084 19.46 

Source: AnaFgas and specific research by Öko-Recherche. * Exports from Germany and Spain. 

negl.: negligible. 

• The largest quantities of F-gases imported are contained in pre-charged stationary air 

conditioners. Almost 90% of split systems of different types are imported from East Asia 

(Japan, China). Export of stationary air conditioning equipment is of negligible size. 

• As for mobile air conditioning, quantities of F-gases exported are higher than quantities 

imported. 

• The EU is the world largest producer of one-component foam. About one third of the 

production is exported, to large extent to Russia. 

• The EU is the world largest filler of metered dose inhalers. Almost two-thirds of the 

production is exported worldwide. 

• The EU is the world largest exporter of switchgear equipment. To ship, medium voltage 

systems are completely factory-filled with SF6 while the large high-voltage equipment is 

filled to atmospheric pressure only and is filled up to operating pressure at the place of 

 

214 The data are based on Öko-Recherche interviews in the course of this study with Daikin Europe 

(stationary air conditioning), ACEA (foreign trade with motor vehicles), Mexichem (MDI), T&D Europe 

(electrical switchgear) and an Öko-Recherche study on OCF for the German EPA (2009). 
Chapter 4 Application of the F-gas Regulation 132 

destination215. In terms of CO2 eq, SF6 in pre-charged electrical equipment represents by 

far the largest single F-gas quantity in the foreign trade of the EU. 

In 2008, exports of F-gas contained in pre-charged equipment amounted to ca. 8,000 tonnes 

and imports of F-gas contained in pre-charged equipment ranges at about 8,700 tonnes. 

Imported quantities of F-gases contained in pre-charged equipment represent almost 13% of 

the total import of bulk F-gases covered under reporting obligations. Export of F-gases 

contained in pre-charged equipment represents ca. 42% of the exported quantities reported 

under Art 6(1). 

In 2008, the most important F-gases in imported equipment were HFC-32 and HFC-125 

which are the two components of the refrigerant blend R-410A. Each of them accounted for 

40% of the F-gas quantities (in metric tonnes) in imported pre-charged equipment. HFC-134a 

in mobile air conditioning represented the remaining 20%. 

As for exports, HFC-134a accounts for more than 92% of the total quantity of F-gas 

contained in pre-charged equipment, HFC-227ea and SF6 represent the remaining 

percentage. 

Although in metric tonnes, imports and exports in charged equipment numerically balance 

each other almost, and thus do not significantly change the reported overall emission 

potential of the EU-27 in metric tonnes, the consideration of pre-charged F-gases 

significantly shifts the composition of the emission potential by individual F-gas types. 

The distortion of the reported emission potential is even more evident when looking at the 

global warming potentials. A clear difference between import and export in 2008 was found 

which amounts to 3.4 million t CO2 eq (import: 16 million t CO2 eq; export: 19.4 million t CO2

eq). This is primarily a result of the high GWP of SF6. Certain quantities of SF6 are exported 

in pre-charged switchgear equipment. 

The composition and the amount of F-gases in imported and exported equipment vary from 

year to year, depending on the economic activities inside and outside EU-27. The relevance 

of data reported under Article 6(1) for the calculation of potential F-gas emissions, would be 

higher if F-gases contained in pre-charged equipment were included in these reporting 

requirements. 

A review option on including F-gases contained in pre-charged equipment in the reporting 

obligations according to Article 6 is included in chapter 8. 

Reporting systems of Member States for emission data 

According to Art 6(4) of the F-gas Regulation, Member States shall “establish reporting 

systems for the relevant sectors referred to in this Regulation, with the objective of acquiring, 

to the extent possible, emission data”. 

In our interpretation, which conforms to the position of the most Member States asked in the 

survey undertaken, this provision does not necessarily require the establishment of new 

monitoring and reporting systems in addition to existing national systems for CRF reporting 

 

215 Separate gas containers, which are often shipped with the equipment for charging on-site, are 

covered by reporting. 
Chapter 4 Application of the F-gas Regulation 133 

to the UNFCCC. In general, Article 6(4) remains rather unclear to Member State authorities. 

Additional efforts of Member States are considered useful only if they would lead to 

monitoring systems for emissions which allow verification of emission trends and emission 

factors over time. 

In chapter 2.3 on the measurability of emission reductions caused by containment measures 

of the F-gas Regulation, appropriate approaches for this purpose which already exist or are 

planned in EU-27 have been discussed. So far, attempts to build up appropriate 

electronically based monitoring systems have been made only in a few Member States.216 In 

most cases these systems are not yet fully in place. Only one Member State, Hungary, uses 

records maintained under Art 3(6) to estimate emissions (Stationary refrigeration, AC and 

heat pump sector and mobile AC sector). This system is still under development and cannot 

yet be used for CRF reporting. 

 

216 These Member States are Bulgaria, Estonia, Hungary, Lithuania, and Poland. 
Chapter 4 Application of the F-gas Regulation 134 

4.2.8 Application of labelling provisions (Article 7)

Labelling provisions according to Article 7 apply since 1 April 2008. Article 7 states that 

products and equipment containing F-gases shall not be placed on the market unless the Fgas type according to chemical nomenclature and quantity can be identified on a label which 

is placed near the charging or recovery points for F-gases on the equipment. These labelling 

provisions apply to the following types of equipment and include equipment containing F-gas 

charges <3 kg: 

- Refrigeration and air conditioning products and equipment (other than those 

contained in motor vehicles), heat pumps, fire protection systems and fire 

extinguishers containing PFCs, HFCs or preparations containing PFCs or HFCs. 

- Switchgear which contains SF6 or preparations containing SF6. 

- All F-gas containers. 

Hermetically sealed systems shall be labelled as such. Furthermore, it is required that 

instruction manuals of the equipments contain information on F-gases and their global 

warming potentials. 

With regard to the mobile refrigeration and air conditioning sector, it should be noted that 

Article 7 covers also products and equipment installed in rail vehicles, ships and agricultural 

machinery. As for F-gas containers not placed on the market, e.g. large ISO tanks used by 

chemical producers or importers for distribution of F-gases but eventually returned to them, 

labelling requirements according to Article 7 might not apply. However, a case-by-case 

analysis will be needed in order to assess specific circumstances. Guidance by the EU 

Commission on the interpretation of Article 7 also includes the encouragement of voluntary 

labelling schemes at national level, in particular for recovery cylinders. 

According to Art 7(1) information on the fluorinated greenhouse gases, including their GWP 

shall be given in the instruction manuals provided for such products and equipment. 

Altogether labelling requirements affect around 50.000 companies in the SRAC sector (OEM 

and contractors assembling in site components), about 100 F-gas suppliers including 

suppliers of cylinders for FPS and about 25 manufacturers of HVS equipment. 

Article 7(3) requires the Commission to establish the form of the label and additional labelling 

requirements. Commission Regulation 1494/2007 defines the information to be contained on 

the label, the form of the label and the placing of the label. 

It should be noted that refrigeration, air conditioning and heat pump equipment insulated with 

foam blown with fluorinated greenhouse gases need in addition to be marked with a label 

saying “foam blown with fluorinated greenhouse gases” before being placed on the market. 

Concerning the language of the label, Article 2(4) allows Member States to require that label 

information is available in their official language when products and equipment are first 

placed on their territory in the Community market. The choice of the targeted markets within 

EU-27 is expected to lead manufacturers and importers to adapt to language needs. 

The Commission provided guidance with regard to text and placing of the label on the 

equipment. As an example, a possible label for is given below (figure 4-6). Nevertheless, 

several industries and Member States highlighted the need for further guidance. 
Chapter 4 Application of the F-gas Regulation 135 

Figure 4-6: Example for a possible label for F-gas based solvent containers217. 

Industry efforts focus on harmonization of labels, in particular in sectors where products and 

equipment are marketed across Europe, and integration of the additional labelling 

requirements into other labels. For example, a label for switchgear containing SF6 fulfilling 

the requirements of Article 7 and a relevant industry standard218 has been developed by T&D 

Europe (figures 4-7, 4-8, 4-9). 

Figure 4-7: Label for high voltage switchgear >52 kV fulfilling requirements of Article 7 of the Fgas Regulation and a relevant industry standard. 

 

Figures 4-8 and 4-9: Additional multilingual labels are placed near the servicing access of 

switchgear <52 kV (left) and >52 kV (right). 

 

217European Commission 2009: Information for operators and technical personnel working with 

equipment containing fluorinated greenhouse gases – equipment containing fluorinated F-gas based 

solvents. 

218 IEC 62271-200 (2003). 
Chapter 4 Application of the F-gas Regulation 136 

For household appliances, in particular hermetically sealed heat pump tumble dryers 

containing HFCs, the idea of a harmonized label was discussed by industry but found to be 

rather complicated. Since most manufacturers are active in all Member States, a label 

containing the required text in all 24 official languages was considered confusing. Instead, 

the industry association CECED considered a harmonized pictogram which is voluntary to 

use by manufacturers and indicates that the system contains F-gases219. 

Manufacturers of other hermetically sealed household appliances such as domestic 

refrigerators and freezers as well as room air conditioners have not yet considered a 

harmonized label. 

While products and equipment placed on the market prior to April 2008 is not subject to 

labelling provisions, it can be recommended to operators to label all equipment. Labelling 

plays an important role during installation, servicing and maintenance of equipment and 

helps to find out whether the equipment is covered by the F-gas Regulation. In addition, 

labelling will also provide significant support for future environmentally sound management of 

F-gas banks i.e. safe handling at disposal. 

Other labelling requirements set out by European or national legislation might apply for 

certain types of equipment and include e.g. pictograms according to the WEEE Directive or 

the CE conformance mark according to Council Decision 94/465/EEC. 

The application of labelling provisions in the different sectors has been delayed to some 

extent. At the due date of 1 April 2008, small manufacturers only active in one Member State 

were hence not in all cases compliant with the requirements of the F-gas Regulation. Large 

manufacturers of electrical switchgear equipment were to large extent compliant with 

labelling requirements at the end of 2008 at the latest. 

Lack of compliance with labelling provisions was also indicated for imported equipment from 

outside of EU-27, in particular Asia. Importers might often not be aware of their obligations 

under the F-gas Regulation, are rarely members of European associations and hence do not 

refer to guidance documents distributed by industry associations. The lack of control and 

enforcement stated previously has also been confirmed with regard to labelling. 

An option to further enhance labelling requirements is suggested in chapter 8. 

 

219 CECED: Instructions for identifying tumble dryers containing fluorinated refrigerants (Draft of 10 

March 2011). 
Chapter 4 Application of the F-gas Regulation 137 

4.2.9 Application of bans (Articles 8 and 9)

Article 8 prohibits the use of SF6 for two types of open applications: Large magnesium die 

casting facilities with SF6 use >850 kg/year from 1 January 2008 and the use of SF6 for 

vehicle tyres from 4 July 2007. The use of SF6 for both applications has decreased 

significantly since the start of the bans. 

As for magnesium die casting, the companies concerned substituted their use of SF6 as 

cover gas of 24 t in 2007 by HFC-134a and SO2 according to a recent study on behalf of the 

EU Commission220. Two companies located in Germany substituted SF6 only in the first half 

of 2008 by HFC-134a; therefore the remaining SF6 quantity in this year amounted to 3.1 t.221

SF6 use for the filling of vehicle tyres amounted to ca. 5 t in 2006 (model AnaFgas). Two 

thirds of this quantity was used in Germany, since introduction of this technology in 1984. For 

Germany, SF6 data for 2007-2009 are available from the Board of Statistics’ database which 

refers to sales of gas distributors to car workshops. Table 4-26 indicates some residual use 

of SF6 in 2008-2009 despite the ban as of 4 July 2007. In 2010 the quantity was nearly 0. 

This data can serve as indicators for EU-27. 

Table 4-26: SF6 use (metric tons) of Mg die casting facilities (>850 kg/y) and for the filling of 

vehicle tyres in 2007-2010 

2006 2007 2008 2009 2010 

Mg die casting >850 kg (EU-27) 31 23 3.1 0 0 

Vehicle tyres (Germany – 2/3 of EU-27) 3.0 0.8 0.5 0.5 ~0 

Article 9 prohibits the placing on the market of F-gases in a number of applications, which 

are listed in Annex II to the F-gas Regulation and include open applications and such closed 

applications, for which F-gas recovery at end of life is technically not possible. 

OCF (ban as of 4 July 2008 except when required to meet national safety standards), novelty 

aerosols (ban as of 4 July 2009) and sound proof windows (full ban as of 4 July 2008) are 

the most important F-gas applications in terms of sales quantities (table 4-27). 

Table 4-27: F-gas sales (metric tons) to applications subject to bans pursuant to Article 9 of the 

F-gas Regulation in 2006-2009 

2006 2007 2008 2009 

OCF (HFC-134a) 1,200 1,100 950 400* 

Novelty aerosols (HFC-134a) 500 380 260 91* 

Soundproof glazing (SF6 **) 12 9 7 3.3 

* In preparations with GWP <150. ** Data for Germany (50% of EU-27 sales) 

With regard to PU canned one-component-foam (OCF) it can be stated that ca 10% of OCF 

cans sold in 2006 contained HFC-134a (of 11.3 million cans sold each contained ca. 110 g of 

 

220 Öko-Recherche 2009: Service contract to assess the feasibility of options to reduce emissions of 

SF6 from the EU non-ferrous metal industry and analyse their potential impacts. Final Report, on 

behalf of the European Commission. 

221 Öko-Recherche 2010: Inventory compilation of F-gases 2009. Data on HFCs, PFCs, and SF6 for 

the national emissions reporting under the Framework Convention on Climate Change for the 

reporting year 2009. On behalf of the German EPA. 
Chapter 4 Application of the F-gas Regulation 138 

HFC-134a), in total ca. 1,200 t (AnaFgas). HFC-152a is used to negligible extent in this 

sector. 

A study on behalf of the German EPA222 found that since 2008 all European PU canned foam 

producers are able to manufacture propellant gas mixtures without HFCs or with reduced 

quantities of HFCs in preparations of GWP <150. 

Under the F-gas Regulation, the use of HFC-134a in preparations with GWP <150 is allowed. 

Hence the maximum quantity of HFC-134a used in mixtures amounts to ca. 10%. 

A time series for the HFC use in PU canned foam is available from Germany, which accounts 

for about 25% of European OCF applications. The quantity of HFC-134a contained in the 

cans used annually decreased from 450 t in 2006 to 130 t in 2009.223

Compared to the total quantity of propellant gases of 2,500 t, only 5.2% of HFC-134a was 

used in preparations (130 t / 2,500 t). This indicates high compliance by industry with Article 

9 of the F-gas Regulation. 

In the medium term, it is estimated that HFC-134a quantities in PU canned foam 

preparations will continue decreasing. The use of HFC-134a as propellant will be limited to 

applications where safety concerns apply (e.g. underground coal mining).224

With regard to novelty aerosols, the use of HFC-134a for the EU market has decreased 

significantly since 2005225 (table 4-28). HFC-152a is of negligible importance in this sector. 

Based on the definition of “preparations” set out by the F-gas Regulation which includes 

mixtures with GWP <150, the use of HFCs in propellant mixtures is allowed as long as the 

GWP threshold is respected. According to FEA, European aerosol fillers succeeded in recent 

years to reformulate the propellant gas mixtures. Therefore, since mid-2009 only aerosols 

containing at maximum 10% of HFC-134a in the propellant gas mixture have been placed on 

the market in EU-27. 

It is estimated that annual HFC use for novelty aerosols will remain at a stable level of 50 t of 

HFC-134a in the medium term. 

With regard to the use of SF6 in windows for domestic and other use, it is estimated that ca. 

29 t were filled into soundproof windows (pane interspace) in 2006 (AnaFgas). About 12 t 

were used in Germany, which had always been the country with the largest market in EU-27. 

In 2007, the total quantity in EU-27 decreased slightly to 22 t. 

For subsequent years, data from Germany are available from the database of the Board of 

Statistics. In 2008, SF6 sales of surveyed gas distributors to manufacturers of soundproof 

windows amounted to 7 t. In the first full year of the ban in 2009, this quantity decreased to 

3.3 t (one German SF6 supplier). This indicates that full compliance with Article 9 was still 

 

222 Öko-Recherche 2009: HFC-containing Propellants in Canned PU Foam (OCF). Final report on 

behalf of the German EPA. 

223 Öko-Recherche. F-gases 2009. Data on HFCs, PFCs, and SF6 for the national emissions reporting 

under the Framework Convention on Climate Change for the reporting year 2009. For the German 

Umweltbundesamt, December 2010. 

224 Öko-Recherche 2009: HFC-containing Propellants in Canned PU Foam (OCF). Final report on 

behalf of the German EPA. 

225 Estimate by FEA (Fédération Européenne des Aerosols), Alain D’Haese, communicated to ÖkoRecherche on 12 August 2010. 
Chapter 4 Application of the F-gas Regulation 139 

lacking in 2009 although sales had been reduced by 75% as compared to 2006. Further 

enforcement of the ban in this subsector seems necessary. 

The other sectors subject to Article 9 are of minor importance and are not analyzed in detail. 

With regard to the use of SF6 and PFCs in sport shoe soles, production stopped in 2006. Fire 

protection systems containing PFCs were not sold any more even prior to the F-gas 

Regulation. 

In total, Article 8 and 9 applied successfully and resulted in significant and measureable 

reductions of F-gas use and hence emissions. SF6 has been substituted in large magnesium 

die casting facilities (>850 kg/year). Full compliance with Articles 8 and 9 can be stated for 

the novelty aerosols and OCF subsectors as HFCs are today only used as components of 

preparations with GWP <150. Further investigation of the application and potentially 

enforcement of the bans in soundproof windows and vehicle tyres seems necessary. 

It should be noted that Articles 8 and 9 have been applied to a large extent with minor 

administrative costs since conversion of production in these sectors largely took place, so 

far, without significant needs for enforcement and control by authorities. 

Options for additional bans of the use of F-gases and of the placing on the market of Fgases/ products containing F-gases are discussed in chapter 8. 
Chapter 4 Application of the F-gas Regulation 140 

4.3 Costs of implementation and application of the F-gas Regulation 

4.3.1 Costs of the F-gas Regulation

The assessment of the costs of implementation and application of the F-gas Regulation 

covers additional costs which were caused by provisions of the F-gas Regulation. 

Prior to the F-gas Regulation certain measures were in place in some sectors, e.g. leak 

checks, recovery of F-gases and certification measures in some Member States and sectors. 

This analysis intends to clarify to what extent additional costs were caused by provisions of 

the F-gas Regulation. 

In the Member States the costs for implementation of the F-gas Regulation differ largely for 

various reasons not only related to the levels of labour costs and public fees and charges. In 

some Member States, the infrastructure for application of the provisions including relevant 

bodies, training programmes, certification requirements etc. has been available prior to the Fgas Regulation, in other Member States this is not the case. Moreover, national regulations 

can be implemented in addition to the requirements of the F-gas Regulation e.g. with regard 

to the validity of certificates which might lead to extra costs at national level. 

Costs which result from national rules exceeding the minimum requirements of the F-gas 

Regulation and related Commission Regulations (EC) No 303-307/2008 are not taken into 

account in this assessment. Examples include costs for company certification in the mobile 

AC sector as required in Hungary, France and Finland. 

The costs of implementation and application of the F-gas Regulation are not separated in this 

analysis. 

The following data are based on surveys among the Member States and relevant industries 

and industry associations. The different types of cost show a large range within and between 

Member States and cost data from Member States which have not yet implemented the Fgas Regulation are almost entirely missing. Therefore, it is necessary to make assumptions 

based on average values. 

The types of costs are classified by sectors of application of the F-gas Regulation and are 

calculated for the entire EU-27. 

4.3.2 Most important types of costs 

When looking at the costs of implementation of the F-gas Regulation, one-off costs and 

recurring costs need to be distinguished. 

One-off costs result mainly from certification and labelling. They apply to all sectors with 

regard to certification/attestation (stationary refrigeration, air conditioning and heat pumps; 

fire protection, high voltage switchgear; solvents; mobile air conditioning sector) and most 

sectors with regard to labelling (stationary refrigeration, air conditioning and heat pumps; fire 

protection, high voltage switchgear). Their level differs between sectors as both personnel 

and companies need to become certified in only two sectors (stationary refrigeration, air 

conditioning and heat pumps; fire protection). 
Chapter 4 Application of the F-gas Regulation 141 

In the future and after implementation of the F-gas Regulation certification costs for new 

personnel and companies will occur, too (recurring costs). In addition, it should be noted that 

in ca. 50% of the Member States national rules limit the validity of certificates and require 

repeated certification after several years (mostly 5 years) which result in additional costs (cf. 

table 4-10). 

With regard to labelling, one-off costs apply for the development of new labels and change of 

instruction manuals for all equipment produced and/or placed on the market in EU-27 

(equipment, containers). 

Recurring costs occur mainly for leak checking/ record keeping and repair in the stationary 

refrigeration, air conditioning and heat pump sector as well as the fire protection sector 

(Article 3 costs). Furthermore, recurring costs result from recovery requirements according to 

Article 4 and from reporting requirements according to Article 6. 

In some Member States further national rules exist (e.g. recording requirements in Germany 

for mobile equipment and disposal companies). Costs resulting from such additional national 

provisions are excluded from the cost assessment as they are not caused by the F-gas 

Regulation. On the other hand, administrative costs which occur in public institutions and are 

not covered by the fees for certification (costs for personnel in authorities, set-up costs, 

measures to raise awareness, enforcement measures such as inspections etc.) are 

considered. Such recurring costs for enforcement and control are part of “public set-up costs” 

(cf. section 4.3.8). 

As stated earlier, costs differ largely within and between Member States. Therefore, cost 

data are averaged. For the sectors with large numbers of personnel to be certified (stationary 

refrigeration, air conditioning and heat pump sector; mobile air conditioning sector) high 

differences with regard to training costs and hence total costs for certification between 

Western Europe (higher price levels) and Eastern/South-Eastern Europe (lower price levels) 

need to be noted. Average costs for these regions are calculated separately. 

As different costs for personnel certification apply in various sectors, the sectors are 

analyzed individually. Costs for company certification range at rather similar levels and 

therefore can be considered together. 

4.3.3 Costs for certification of personnel and companies

The calculation of certification/ attestation costs according to the requirements set out in (EC) 

No 303-307/2008 is based on the number of personnel and companies subject to these 

requirements. Costs occur only once in most cases (one-off costs). 

Certification costs generally include the fees which need to be paid for company and 

personnel certification. 

The costs for full certification of personnel include 

- Fees for theoretical and practical exams (do not occur for mobile AC sector) 

- Fees for training (which is generally necessary) 

- Fees for the issuance of the certification documents. 
Chapter 4 Application of the F-gas Regulation 142 

In case personnel certificates can be issued based on existing qualifications (cf. section 

4.2.1), costs for trainings and exams do not apply. 

As for personnel certification/attestation, costs for the non-productive time, travel costs and 

other expenses which need to be covered by companies are to be accounted. 

The costs for full company certification include 

- Costs for the verification of company information by authorities and 

- Fees for the issuance of the company certificate. 

Stationary refrigeration, air conditioning and heat pumps (personnel 

certification) 

Definitive personnel certification according to (EC) No 303/2008: The total number of 

personnel subject to certification requirements in this sector amounts to 230,000 (table 4-5). 

Out of these, about 30,000 personnel can be certified without theoretical and practical exam 

and do not need training due to their pre-existing qualification.226 

It is assumed that all other personnel (200,000) need to follow trainings. 85% are required to 

take certification according to Category (Cat) 1 and about 15% according to Categories 2-

4.227 

Table 4-28: One-off costs of personnel certification according to (EC) No 303/2008 (stationary 

refrigeration, air conditioning and heat pumps) Cat: Category; Exp.: Expenses 

Costs Western Europe Costs Eastern/SouthEastern Europe Total 

costs 

Certification Number 

of 

personnel 

in total 

€/ 

pers. 

Number of 

personnel 

M€ €/ 

pers. 

Number of 

personnel 

M€ M€ 

pers. already 

qualified 

30,000 40 30,000 1.2 40 - - 1.2 

Cat 1 170,000 850 134,300 114.155 300 35,700 10.710 124.865 

Cat 2-4 30,000 550 23,700 13.035 200 6,300 1.260 14.295 

Exp. Cat 1 171.233 16.065 187.298 

Exp. Cat 2-4 13.035 1.260 14.295 

Total 230,000 188,000 311.458 42,000 29.295 340.753 

Certification costs vary due to the different duration of training programs according to Cat 1 

(on average 4 days) and Cat 2-4 (on average 2-3 days). Differences also relate to different 

price levels in regions and Member States. In Western Europe costs for certification 

according to Cat 1 amount to about €850 and in Eastern/South-Eastern Europe to about 

€300. Costs for certification according to Cat 2-4 amount to €550 in Western Europe and to 

€200 in Southern/Eastern Europe.228 As outlined earlier, companies also need to account costs 

for non-productive time, travel and other expenses. For Cat 1 certification in this sector based on 

 

226 Personnel certification acc. (EC) No 303/2008, Art 5(3): AT (50%), DE (50%), DK (80%), NL 

(100%). 

227 Estimation based on data from DE, FR, IT, SE, and UK with together 56% of total personnel 

subject to certification requirements in SRAC. 

228 Certification costs including training differ within and between Member States by a factor of about 10. 

Western Europe (higher price level): 15 Member States; Eastern/South-Eastern Europe (lower price 

level): 12 Member States (BG, CY, CZ, EE, EL, HU, LT, LV, PL, RO, SK, and Sl). The cost assessment 

is based on data from 12 Member States (BE, CZ, DE, EE, FR, HU, IT, NL, PL, SE, SK, and UK). 
Chapter 4 Application of the F-gas Regulation 143 

industry information the total costs including expenses are assumed to be 2.5 times the pure 

personnel certification costs (including training). In this case the factor is 2.5. For Cat 2-4 a factor 

of 2 is assumed. This leads to total costs including expenses per person of €2,125 (Cat 1) and 

€1,100 (Cat 2-4) in Western Europe and €750 (Cat 1) or €400 (Cat 2-4) in Eastern/SouthEastern Europe (table 4-28). 

The fees for issuance of a certificate are assumed to amount to €40. 

Total one-off costs of personnel certification in this sector according to (EC) No 303/2008 

amount to approx. €341 million in EU-27. About €140 million (41%) relate to pure certification 

and training costs while ca. €201 million (59%) are caused by additional costs to be covered 

by companies. 

Recurring costs: Annual costs for new first certification of personnel (beginners) are assumed 

to range at 5% of the costs calculated above (17 million €/year) based on information from 

certification bodies. 

Fire protection (personnel certification) 

Definitive personnel certification according to (EC) No 304/2008: The total number of 

personnel subject to certification requirements in the Fire protection sector amounts to 

approx. 4,500 (table 4-6). All personnel need to take training before theoretical and practical 

tests for certification. 

Certification costs for personnel including training (1-2 days) average at approx. €300 in EU27 (table 4-29). Unlike in the stationary refrigeration, air conditioning and heat pump sector, 

no clear differences appear between Western and Eastern/South-Eastern Europe. 

Total costs including expenses are estimated at €1,000. The share of expenses from the 

total certification costs is higher in this sector than in the stationary refrigeration, air 

conditioning and heat pump sector. This is due to the lower training costs compared to the 

costs for non-productive working time, travel expenses etc. 

Table 4-29: One-off costs of personnel certification according to (EC) No 304/2008 (fire 

protection) 

Certification Number of personnel Costs/personnel (€) Total costs (M€) 

Incl. training 4,500 300 1.350 

Expenses 4,500 700 3.150 

Total 4,500 1,000 4.500 

The one-off costs of personnel certification in this sector amount to ca. €4.5 million in EU-27. 

About 30% relate to pure certification and training costs while ca. 70% are caused by 

additional costs to be covered by companies. 

Recurring costs: Annual costs for new first certification of personnel (beginners) are assumed 

to range at 5% of the costs calculated above (ca. 225,000 €/year) based on information of 

certification bodies. 
Chapter 4 Application of the F-gas Regulation 144 

High-voltage switchgear (personnel certification) 

Personnel certification according to (EC) No 305/2008: The total number of personnel 

subject to certification requirements in the HVS sector amounts to approx. 3,000 (table 4-7). 

All personnel need to take training before theoretical and practical tests for certification. 

Certification costs for personnel including training (2 days) average at ca. €850 in EU-27229. 

Unlike in the stationary refrigeration, air conditioning and heat pump sector, no significant 

differences appear between Western and Eastern/South-Eastern Europe. 

Total costs (table 4-30) including expenses are estimated at €2,000. (The factor of total 

certification costs including expenses is 2.4 and thus lower than in the fire protection sector. 

This is due to the higher costs for training in this sector.) 

Table 4-30: One-off costs of personnel certification according to (EC) No 305/2008 (highvoltage switchgear) 

Certification Number of personnel Costs/personnel (€) Total costs (M€) 

Incl. training 3,000 850 2.550 

Expenses 3,000 1,150 3.450 

Total 3,000 2,000 6.000 

The one-off costs of personnel certification in this sector amount to ca. €6 million in EU-27. 

About 43% relate to pure certification and training costs while approx. 57% are caused by 

additional expenses to be covered by companies. 

Recurring costs: Annual costs for new first certification of personnel (beginners) are assumed 

to range at 5% of the costs calculated above (ca. 300,000 €/year). 

F-gas based solvents (personnel certification) 

Personnel certification according (EC) No 306/2008: The total number of personnel subject 

to certification requirements in the solvents sector amounts to approx. 170 (table 4-8). All 

personnel need to take training before theoretical and practical tests for certification. 

The costs for certification of personnel including training (0.5-1 day) amount to ca. €230230. 

Total costs including expenses are estimated at €600. 

Table 4-31: One-off costs of personnel certification according to (EC) 306/2008 (F-gas based 

solvents) 

Certification Number of personnel Costs/personnel (€) Total costs (M€) 

Incl. training 170 230 0.039 

Expenses 170 370 0.063 

Total 170 600 0.102 

The one-off costs of personnel certification in this sector amount to ca. €0.1 million in EU-27. 

About 38% relate to pure certification and training costs. 

Recurring costs: Annual costs for new first certification of personnel (beginners) in this sector 

are assumed to range at 5% of the costs calculated above (ca. 5,100 €/year). 

 

229 Basis: Data from 4 Member States (CZ, DE, NL, UK). The lowest and highest data differ by a factor 

of about 2 (UK: €600; DE: €1150; pure costs of certification). 

230 Basis: Data from UK (sole active certification body). 
Chapter 4 Application of the F-gas Regulation 145 

Recovery of F-gases from AC systems in motor vehicles (personnel 

attestation) 

Personnel attestation according (EC) No 306/2008: The total number of personnel subject to 

certification requirements in the MAC sector amounts to about 360,000 (table 4-10). All 

personnel need to take training. 

The costs for attestation of personnel, including a 1 day-training course, range between ca. 

€180 (Western Europe) and €120 (Eastern/South-Eastern Europe).231 

Table 4-32: One-off costs of personnel attestation according to (EC) No 307/2008 (Recovery of 

F-gases from AC systems in motor vehicles) 

Costs Western Europe Costs Eastern/SouthEastern Europe Total 

costs 

Number 

of 

personnel € Number of 

personnel 

M€ € Number of 

personnel 

M€ M€ 

Attestation 360,000 180 292,000 52.560 120 68,000 8.160 60.720 

Expenses 360,000 320 292,000 93.440 180 68,000 12.240 105.680 

Total 360,000 500 292,000 146.000 300 68,000 20.400 166.400 

Total attestation costs including expenses are estimated at €500 in Western Europe and 

€300 in Eastern/South-Eastern Europe (table 4-32). 

The one-off costs of personnel attestation in this sector amount to ca. €166 million in EU-27. 

About €61 million (36%) relate to pure certification and training costs. €105 million (62%) are 

caused by additional expenses to be covered by companies. 

Recurring costs: Annual costs for new first certification of personnel (beginners) in this sector 

are assumed to range at 5% of the costs calculated above (ca. 8.32 M€/year). 

Company certification: Stationary refrigeration, air conditioning and heat 

pumps/ Fire protection 

Company certification is required in the stationary refrigeration, air conditioning and heat 

pump sector and the fire protection sector according to Regulation (EC) No 842/2006, Art 

5(1). 

The total number for companies subject to certification requirements is estimated at 65,000 

(stationary refrigeration, air conditioning and heat pump sector) and 1,300 (fire protection 

sector) (table 4-11). The stationary refrigeration, air conditioning and heat pump sector 

accounts for 98% of all companies. 

Additional national requirements in some Member States (company certification also in the 

mobile AC sector) are not considered in this assessment since additional costs induced by 

such national further reaching legislation do not relate to the F-gas Regulation. 

Information on company certification is available from 15 Member States.232 Costs for 

company certification vary largely within and between Member States. According to 

information of the competent authorities in Slovenia, costs for company certification amount 

 

231 Basis: Data from 4 Member States (CZ, DE, EE, and UK). 232 These Member States include BE, CZ, DE, EE, FR, HU, IE, IT, LT, NL, PL, SE. SK, SI, and UK. 
Chapter 4 Application of the F-gas Regulation 146 

to only €20 if the personnel is already certified. In France, company certification includes an 

audit and costs can amount to up to €2,700. Similar differences of the level of costs for 

company certification can occur between different regions in Belgium. The range in Germany 

spans between €75 and €1,500, the average costs amount to €300. The major influencing 

factor is the size of companies, in different regions and Member States the intensity of the 

company check and fees of authorities’ impact costs. 

Large cost differences occur between Western Europe and Eastern/South-Eastern Europe. 

As for small companies in Western Europe company certification costs range between €100 

and €1,200 while costs in Eastern/Southern Europe vary between €20 and €225. As for large 

companies differences amount to €500-1,300 (Western Europe) and €20-800 

(Eastern/Southern Europe). 

For Western Europe an average of €400 per company is assumed and in Eastern/SouthEastern Europe an average of €200. 

Table 4-33: One-off costs of company certification according to (EC) No 303-304/2008 

(Stationary refrigeration, air conditioning and heat pumps/ Fire protection) 

Costs Western Europe Costs Eastern/SouthEastern Europe Total 

costs 

Number of 

companies 

€ Number of 

companies

M€ € Number of 

companies 

M€ M€ 

Total 66,300 400 53,900 21.560 200 12,400 2.480 24.040 

The costs for first certification of companies amount to ca. €24 million (table 4-33). 98% 

relate to the stationary refrigeration, air conditioning and heat pump sector (€23.6 million). 

Recurring costs of company certification result from new companies which enter the market 

and need to become certified. Many small enterprises are active in the stationary 

refrigeration, air conditioning and heat pump sector. Hence a continuous need for company 

certification is expected. Assuming that 5% new companies are certified every year, costs for 

company certification amount to ca. €1.2 million. 

Furthermore recurring costs relate to the limited validity of company certificates in about 50% 

of the Member States (cf. tab. 4-10). It differs between 1 and 5 years and hence requires 

repeated certification in the respective periods. 

These costs are not caused by the F-gas Regulation but by national rules. Costs levels 

cannot be assessed since the costs for recertification have not been set in most cases.233 

Costs of certification in total 

Total costs of personnel and company certification (one-off costs of first certification) amount 

to ca. €542 million in EU-27 (table 4-34). About 40% of these costs relate to costs for the 

required exams, fees and costs of trainings. Around 60% result from non-productive working 

time of personnel and other expenses. 

 

233 As first approach: At a five-year-term (running time) of the company certificates in half of the 

Member States and costs for re-certification as high as for first certification, there is an annual cost 

burden of around 20 % of first certification costs. For EU- 27 this amounts up to 10% off first 

certification costs annually, which is € 2.4 million.
Chapter 4 Application of the F-gas Regulation 147 

The total costs for personnel certification including training amount to ca. € 204 million. 

Compared to this amount, the costs for company certification (€ 24 million) are in the range 

of less than 12%. Costs for personnel certification (including expenses) account for >95% of 

total certification costs. 

67% of these total costs occur in the stationary refrigeration, air conditioning and heat pump 

sector (about €364 million including company certification) and 31% in the mobile AC sector 

(personnel attestation). 

Recurring costs: Assuming that 5% of personnel and companies need to become certified 

annually (entrants) results in on-going costs for certification of ca. 27.1 M€/year. 

Table 4-34: One-off and recurring costs of personnel and company certification/attestation 

according to the F-gas Regulation 

Certification/attestation 

according to 

Pure costs of 

certification and 

training (M€) 

Costs of certification including 

training and expenses (M€) 

One-off costs Recurring costs 

(per year) 

Personnel certification 

 (EC) No 303/2008 (SRAC) 139.160 340.753 17.038 

 (EC) No 304/2008 (FPS) 1.350 4.500 0.225 

 (EC) No 305/2008 (HVS) 2.550 6.000 0.300 

 (EC) No 306/2008 (Solvents) 0.039 0.102 0.005 

 (EC) No 307/2008 (MAC) 60.720 166.400 8.320 

Total personnel certification 203.819 517.755 25.888 

Company certification 24.040 24.040 1.202 

Total personnel and company 

certification 

227.859 541.795 27.090 

In table 4-34 additional costs resulting from time limitation of personnel certificates and 

necessary re-certification are not taken into account since they are due to Member State 

specific requirements. The range of these additional costs could be determined in the 

following way: 

As displayed in table 4-10, in 8 of those 20 Member States, which have notified, validation of 

personnel certificates is time limited to 5 years in almost all cases. 

However, this is not the case for all sectors; for example, in a few Member States this only 

applies to the SRAC sector, which is excluded from this regulation in France at present. To 

estimate the resulting upper limit of costs, it is assumed that 40% of all certificates have to be 

renewed every fifth year in EU-27, the annual re-certification rate is 8 %. 

There are no general conclusions on the costs for re-certification of the personnel. Training 

efforts for a re-certification are supposed to be significantly lower because of gained 

qualifications attested by the first certification. If one takes half of the cost and time efforts of 

first-certification as a basis for the calculation of recertification costs, annual costs range at 4 

% of the costs for first-certification in EU-27 (around 20.7 M€). 

The upper limit of annual costs for re-certification of companies is assumed at €2.4 million 

(see above in the section on company certification). 
Chapter 4 Application of the F-gas Regulation 148 

Recurring costs for re-certification of personnel and companies resulting from national 

regulations are in the range of € 23.1 million or less than 5% of the total EU-27 costs for first 

certification. However, in some of the Member States, costs are considerably higher. 

4.3.4 Costs of containment provisions (Article 3)

Since 4 July 2007 containment provisions according to Article 3 apply to stationary 

refrigeration, air conditioning and heat pump equipment, as well as to fire protection 

installations. Equipment with F-gas charges <3 kg is not subject to these provisions. 

Standard leakage check requirements are defined in (EC) No 1516/2007 and (EC) No 

1497/2007. 

Long before entry into force of the F-gas Regulation containment measures (including leak 

checks and leak detection systems) have been carried out in most F-gas sectors, however to 

a smaller extent and mostly more reactive than proactive. The application of containment 

provisions acc to Article 3 involves additional costs for upgrading of systems 300 kg with 

leak detection systems, as well as for leak checking by frequencies defined in Art 3(2) and 

for repair and record keeping. 

Stationary refrigeration, air conditioning and heat pumps (SRAC)

The following table 4-35 shows the approach for the assessment of the additional costs that 

arise to the operators from application of Art 3, such as costs for regular leak checking, quick 

repair, and record keeping. 

The basis of calculation is the cost of one working hour by certified personnel, which is 

assumed to amount to € 50 (including travelling) on average in EU-27. In the third column, 

the percentage of regular checks prior to the F-gas Regulation is displayed, ranging from 

10% (roof top air conditioning) to 70% (large industrial refrigeration). The fourth column 

shows the annual expenses for the measures according to Art 3, ranging from €157 

(condensing units) to €1,233 (large industrial refrigeration equipment). The sum is a result of 

three time units: working time for 1 leak check (5) which is multiplied by its frequency (6), 

annual hours for repair of detected leaks (7), and time for recording (8). The annual time for 

leak checking is reduced by the percentage of regular leak checks prior to the F-gas 

Regulation (3). Equipment charged >300 kg is equipped with a leak detection system, for 

which the annual cost are shown in column 9. Further explanation of the cost calculation 

approach is given in annex II. 
Chapter 4 Application of the F-gas Regulation 149 

Table 4-35: Calculation basis for the assessment of additional costs from Art 3 to operators in 

stationary refrigeration and air conditioning (SRAC sector) 

1 2 3 4 5 6 7 8 9 

Sectors of stationary 

refrigeration and air 

conditioning 

charge 

in kg 

regular 

leak check 

before Fgas Reg 

€/year 

[€50 

one 

hour] 

1 leak 

check 

/hours 

freque

ncy 

/year 

repair 

hours

/year 

record 

hours 

/year 

detection 

system 

€/year 

Commercial condensing 

unit 8 20% 157 3 1 1.6 0.33 

Commercial centralised 

system 230 50% 593 8 2 9.6 0.67 100* 

Industrial refrigeration 

small 650 60% 1,093 8 2 6.4 0.67 700 

Industrial refrigeration 

large 4,000 70% 1,233 12 2 6.4 0.67 800 

Stationary AC 

Multi split VRF 13.5 15% 181 3.5 1 1.28 0.33 

Stationary AC 

Rooftop 10.5 10% 162 3 1 0.8 0.33 

Stationary AC Chillers 

(displacement) 50 20% 201 2 2 0.64 0.67 

Stationary AC Centrifugal 

chillers 630 35% 805 4 2 1.44 0.67 500 

* €100 means 10% of systems are > 300 kg, and need a leak detection system of €1,000 per year. 

The recurring cost for additional leak checking, repair and recording caused by the F-gas 

Regulation is estimated under the assumption that the F-gas Regulation has been fully 

applied in the year 2010. 

As stated previously, quantitative data indicating the extent of additional leak checking are 

not available at industry or service companies. The values in the table are estimates by the 

sector experts in the project team. 

Record keeping (according Art 3(6)) is a new legal requirement and can clearly be attributed 

to the F-gas Regulation. This also applies to the relevant cost. Although service companies 

have always kept certain records, e.g. for financial accounting, in the past, it is a new 

provision that operators have to keep the records. 

Additional service costs arise to the operators also from increased labour costs for certified 

personnel. The increase is estimated +10 % compared to non-certified personnel previously 

used. 

As higher frequency in leak checking implies detection of more leaks, the requirement of Art 

3 that leaks shall be repaired “as soon as possible” increases the annual working time for 

repair compared to the time before full application of the F-gas Regulation. The costs from 

extra repair of small leaks by certified persons are included in the cost of leak checking. With 

regard to bigger leaks which lead to system failure it is assumed that such leaks had been 

repaired also before the F-gas Regulation. 

Table 4-36 shows an estimation of the annual costs by the eight sectors of stationary air 

conditioning and refrigeration and focuses on equipment containing refrigerant charges >3 kg 

under the assumption of full application of Art 3. Evidently, at a lower level of application, the 

total costs are lower and achievable emission reduction decrease accordingly. 
Chapter 4 Application of the F-gas Regulation 150 

Table 4-36: Recurring costs for leak checking according to Art 3 (SRAC sector) 

Number of SRAC-systems 

(1,000) 

Annual recurring costs of 

leak checking (M€) Sub sectors 

with equipment 3 kg 

Annual 

costs/ 

system 

(€/year) 2010 2015 2010 2015 

Commercial condensing unit 157 1,200 1,600 195.8 254.0 

Commercial centralised system 593 160 170 92.7 102.7 

Industrial refrigeration small 1,093 10.2 14.7 11.2 16.1 

Industrial refrigeration large 1,233 5 7.2 6.2 8.8 

Stationary AC multisplit-VRF 181 540 980 97.8 178.1 

Stationary AC Rooftop 162 470 520 49.9 76.1 

Stationary AC Chillers (displ.) 201 760 780 100.0 152.6 

Stationary AC Centrif. chillers 805 8.7 10.5 5.3 7.0 

Total 2,722 4,011 559.0 795.7 

Cost calculation according to table 4-35. Number of units from model AnaFgas. 

In 2010, a total of ca. 2.7 million SRAC systems were subject to Article 3 of the F-gas 

Regulation. This number will increase to 4.0 million until 2015. Annual costs that arise to the 

operators from the measures of Art 3 of the F-gas Regulation are estimated at 559 M€ 

(2010), and 796 M€ (2015). Full application of Art 3 is assumed. The costs vary by sectors, 

and are particularly high for condensing units (with charges >3kg) because their number is 

very large, accounting for 44% of the total number of systems. Annual service cost per 

condensing unit is estimated at €157, which is approx. three working hours by a certified 

person. 

Fire protection systems (FPS) 

Leak checking, record keeping

It is assumed that fire protection systems have already been equipped with appropriate leak 

detection systems and/or that an existing inspection regime has already been in place to 

comply with ISO 14520 (Art 3(5)), so that no additional costs for upgrading arise from the Fgas Regulation. 

Table 4-37: Recurring costs of additional leak checking and of record keeping according to 

Art 3 (FPS sector) 

Number of FPS systems (2010) Annual recurring costs of leak 

checking and record keeping 

(M€) 

working 

hours per 

year 

2010 2015 2010 2015 

Leak checking 1.00 22,800 24,000 1.1 1.2 

Record keeping 0.67 91,000 96,000 3.0 3.2 

Total 4.2 4.4 

Number of units from model AnaFgas. 

Additional cost, however, arise from extra leak checking. Prior to the F-gas Regulation, we 

estimate that 25% of the fixed fire protection installations have not been controlled at the 

same interval as prescribed by Art 3 of the F-gas Regulation. In these cases, additional 
Chapter 4 Application of the F-gas Regulation 151 

working time expenditure is estimated at 2x30 minutes per year, related to 25% of the 

equipment stock. Additional recurring costs arise to all operators for record keeping 

according to Art 3(6) (0.67 h per year). 

Total additional costs for leak checking and record keeping are approx. €4.2 to €4.4 million in 

2010/2015 (table 4-37). 

4.3.5 Costs of recovery (Article 4)

One of the objectives of the F-gas Regulation is to increase the recovery efficiency through 

the use of certified personnel. This mainly targets to recovery at end-of-life of stationary 

equipment. Additional costs to the operators of SRAC systems, resulting from extra recovery 

activities and from the use of certified personnel, can be attributed to the F-gas Regulation. 

No significant additional recovery activities are expected for FPS and HVS installations. In 

these sectors, only the increase in labour cost (+10%) must be accounted for, which is due to 

the fact that certified person must be paid more than non-certified personnel. The solvents 

sector is of negligible size and not considered further, here. 

We estimate that the recovery activities in the SRAC sector need to increase significantly for 

equipment with F-gas charges >3 kg compared to the situation prior the F-gas Regulation 

(percentage increase similar to leak checking). In the sub sectors of equipment <3 kg the 

increase in recovery activities must be even very much higher to meet the requirements of 

Art 4 of the F-gas Regulation, because in many SRAC sub sectors end-of-life was hardly 

common prior to the F-gas Regulation. 

The calculations in table 4-38 refer to SRAC equipment which is decommissioned in 

2010/2015 (for further explanation and details of calculation see Annex II.) The basic 

calculation unit is again €50 for one working hour of a certified person. 

The additional recovery cost for Domestic Refrigeration, which shows the highest number of 

decommissioned units by far, is only €1.50. As recovery at end-of-life is already subject to 

the WEEE Directive, additional cost arise only from the requirement that recovery must be 

carried out be certified personnel. The labour costs are estimated €5.00 higher per hour. As 

there is 0.3 hours time assumed for end-of-life treatment, additional cost from application of 

Art 4 is €1.50. 

The costs for recovery activities which are carried out by certified personnel (calculated to 

10% of total annual personnel costs of recovery) amount in the SRAC sector to €100 million 

(in 2010 and about €222 million in 2015. The additional costs in the fire protection and the 

high voltage switchgear sector are in the range of €132,000 – €545,000 in 2010/2015. 
Chapter 4 Application of the F-gas Regulation 152 

Table 4-38: Annual costs for recovery according to Art 4 by sectors 

Number of systems at 

decommissioning 

Annual recurring costs of 

recovery (M€) 

Sub sector Recovery 

costs/system 

(€) 

charge 

(kg) 

2010 2015 2010 2015 

Stationary refrigeration, air conditioning and heat pump equipment (SRAC) 

Domestic Refrigeration 1,5 0.12 16,600,000 11,200,000 24.950 16.770 

Commercial stand-alone 25 0.4 375,000 400,000 9,370 9,990 

Stationary AC moveable 25 0.75 316,400 774,600 7.900 19.400 

Stationary AC 

single split 50 1.5 1,133,700 3,250,500 56.700 162.500 

Heat pumps 50 2.4 0 27,500 0 1.300 

Commercial 

condensing unit 50 8 1,200 166,200 0.060 8.310 

Commercial 

centralised system 100 230 8,400 8,700 0.839 0.870 

Industrial refrigeration 

small 150 650 0 638 0 0.100 

Industrial refrigeration 

large 300 4,000 0 318 0 0.100 

Stationary AC 

multi split-VRF 50 13.5 0 0 0 0 

Stationary AC Rooftop 50 10.5 0 49,000 0 2.500 

Stationary AC 

Chillers (displ.) 50 50 0 0 0 0 

Stationary AC 

Centrif. chillers 75 680 0 0 0 0 

SRAC Total 18,470,000 15,860,000 99.800 221.800 

Fire protection systems (FPS) 

Fire protection systems 100 130 0 3,900 0 0.390 

Switchgear (HVS) 

HV switchgear 75 100 1,800 2,000 0.132 0.155 

Explanation of cost calculation in annex II. Number of units from model AnaFgas. 

4.3.6 Costs of Reporting (Article 6)

The reporting provisions of Article 6(1) of the F-gas Regulation apply to about 80 companies 

in EU-27 (importer, exporter and/or producer of >1 tonne of F-gases per annum; see chapter 

4.2.7). According to the European Fluorocarbon Technical Committee234 (EFCTC) the annual 

reporting costs per company are at maximum ca. €10.000 per year (including personnel 

costs). With regard to differences between Member States and between large and small 

companies, we budget €5.000 per year and company. 

 

234 Communication to Öko-Recherche, 28 March 2011. 
Chapter 4 Application of the F-gas Regulation 153 

Table 4-39: Recurring personnel costs of reporting according to Article 6(1) (importer, exporter 

and producer of F-gases) 

Annual reporting 

costs/company 

(€) 

Number of 

companies 

(2008/2009) 

Annual personnel costs 

of reporting according 

to Art 6(1) (M€) 

Importer, exporter, producer of >1 

tonne F-gases 5,000 80 0.40 

The reporting costs according to Article 6(1) total about € 0.4 million per year. 

4.3.7 Costs according to Article 7 (labelling, instruction manuals)

Article 7 and (EC) No 1494/2007 set out requirements for labelling of new equipment 

containing HFCs or PFCs placed on the market after 1 April 2008. The labelling requirements 

apply to all SRAC/HP systems, to mobile RAC products and equipment installed in rail 

vehicles, ships and agricultural machines, to FPS systems and fire extinguishers, to HVS 

equipment and to F-gas containers. Information on F-gases shall be included in the 

instruction manuals provided for products and equipment covered by Article 7 (chapter 

4.2.8). 

One-off costs emerge from (re)design of the label and additions in the instruction manuals 

from companies in the above mentioned sectors. These one-off costs apply to the original 

equipment manufacturers (OEM) and to the contractors which are assembling customized 

components on site, and to fillers of F-gas containers. 

Table 4-40 contains information on costs related to Article 7. 

The information is based on estimations of the number of affected companies in each sector 

and the average costs for redesign of labels and additional text in instruction manuals.235 

The number of affected companies in the stationary refrigeration, air conditioning and heat 

pump sector is the most important factor in this calculation since ca 50.000 OEM 

manufacturers and contractors assembling on site components are affected in EU-27 

(industry estimate). 

Table 4-40: One-off costs of labelling according to Article 7 

Sector Companies/model 

series concerned 

(number) 

Costs per 

company/model series 

(€) 

Total costs (M€) 

SRAC/HP 50,000* 1,000 50.00 

FPS 30 2,000 0.06 

HVS 115** 2,300 0.265 

F-gas supplier 70 1,000 0.07 

Total 50.39 

* OEM and contractors; ** model series, all manufacturers 

 

235 Calculation based on data input from EFCTC, EPEE, EUROFEU, and T&D Europe. 
Chapter 4 Application of the F-gas Regulation 154 

4.3.8 Public set-up costs

Public set-up costs include public expenses which are not covered by certification fees or 

other fee, for designation/set-up of certification systems, and related central data systems, 

for public awareness rising and other information activities as well as for enforcement, control 

and inspections. Public costs can be partly considered one-off costs but partly occur 

regularly and hence relate to recurring costs (e.g. control and inspections). 

On the basis of information from 6 Member States236 average public set-up costs are 

estimated at ca. €50,000 per 1 million inhabitants (table 4-41)237. These 6 Member States 

include countries which had to set-up completely the initial infrastructure (e.g. Hungary, 

Estonia, Malta) and others which could at least partially rely on existing information systems 

(e.g. Poland). 

This is well in line with the governmental set up costs for the Dutch STEK system. The costs 

for the Dutch STEK system were estimated at €750,000 by the Dutch Environment Ministry 

VROM, which corresponds to €46,000 per million inhabitants238. 

Recurring costs for registration systems, for public control and inspection measures and 

other administrative activities in the 6 Member States amount to ca. €23,000 per 1 million 

inhabitants. 

By extrapolation to EU-27, the sample estimate adds up to ca. €25.0 million of one-off costs 

and ca. €11.4 million of recurring costs (table 4-41). 

Table 4-41: Public set-up costs from implementation and application of (EC) 842/2006 

One-off costs Annual recurring costs 

€/million inhabitants 50,000 23,000 

Total EU-27 (M€) 25.0 11.4 

4.3.9 Summary: Total costs acc. to Articles 3-7 of the F-gas Regulation

The table 4-42 summarizes the total costs of the F-gas regulation for both one-off costs and 

recurring costs in 2010 and 2015. 

One-off costs, which are related to implementation and application of the F-gas Regulation, 

are in the range of €617 million. Almost 90% thereof result from costs for certification of the 

personnel and companies. Costs for Article 7 (labelling) and other public set-up costs are 

comparatively low. Two thirds (66%) of the certification costs arise in the sectors stationary 

refrigeration, air conditioning and heat pumps. 

Recurring annual costs of the F-gas Regulation are higher than the one-off costs. 

In 2010 recurring costs are estimated at about €890 million for EU-27, in 2015 at €1,250 

million. They account for the major costs of the F-gas Regulation. The highest costs by far 

 

236 The Member States include Estonia, Finland, Hungary, Malta, the Netherlands, and Poland. In 

case of the Netherlands the government set up costs for the STEK system have to be taken into 

account. 

237 Enviros 2002: Assessment of the Costs & Impact on Emissions of Potential Regulatory 

Frameworks for Reducing Emissions of HFCs, PFCs & SF6. 238 Cited in: Enviros 2002: Assessment of the Costs & Impact on Emissions of Potential Regulatory 

Frameworks for Reducing Emissions of HFCs, PFCs & SF6. 
Chapter 4 Application of the F-gas Regulation 155 

arise to the operators in the SRAC sectors for regular leak checking, repair and record 

keeping. These expenses account for approx. 85% of the recurring costs of the F-gas 

Regulation. 

Table 4-42: Total costs of implementation and application of the F-gas Regulation by Articles 3 

to 7 

Type of costs Sectors One-off Recurring costs (M€) 

costs (M€) 2010 2015 2030 

Art 5 Certification SRAC, FPS, HVS, Solvents, 

MAC 541.8 27.1 27.1 27.1 

Art 3 Containment SRAC, FPS 563.2 800.0 967.6 

Art 4 Recovery* SRAC, FPS, HVS 99.9 222.4 544.4 

Art 6 Reporting Fluid suppliers 0.4 0.4 0.4 

Art 7 Labelling SRAC, FPS, HVS, Fluid 

suppliers 50.4 

Other 

(public set-up costs) 25.0 11.4 11.4 11.4 

Total 617.2 702.0 1,061.3 1,550.9 

* Recovery costs mostly from small air conditioners. 

Recurring costs in 2030 are estimated at €1,550 million. Both containment and recovery 

costs are increasing from 2015 to 2030. The doubling of recovery costs is caused by the 

growing number of systems in use and from which F-gas has to be recovered eventually. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 156 

5. Impact and cost-effectiveness of the current EU F-gas policy 

framework 

5.1 Concept of the current EU F-gas policy framework 

The approach in the current F-gas Regulation distinguishes between F-gas emissions 

released from 

- closed applications such as stationary refrigeration, air conditioning and heat pump 

equipment, stationary fire protection systems, switchgear equipment 

and 

- open applications of F-gases such as the use of HFCs in one-component foam and 

novelty aerosols, or of SF6 in car tyres, SF6 in magnesium casting, etc. 

For closed applications, the Regulation establishes containment and recovery measures, 

while restrictions for use or placing on the market were established for specific open 

applications where alternatives were already technically feasible and cost-effective. 

Emissions from mobile air conditioning equipment contained in passenger cars are 

addressed by the MAC Directive, which requires gradual phase-out of F-gases with GWP 

>150 in new systems in the period 2011-2017 in EU-27. 

Certain sources of F-gas emissions in EU-27 are today addressed by neither the F-gas 

Regulation nor the MAC Directive. Chapter 5.3 lists and describes these emissions and their 

sources. 

The impact of the F-gas Regulation relies primarily on the extent to which HFC refrigerant 

emissions from stationary equipment for refrigeration, air conditioning and heat pumps can 

be reduced, since equipment from these sectors accounts for most emissions, after those 

from mobile air conditioning, whereas open applications covered by restrictions account for a 

minor share of emissions. Containment and recovery measures aim at reduction of 

emissions from operation in the use phase and at decommissioning at end of life of 

equipment. Use-phase emissions are indicated by the use-phase emission factor, end-of-life 

emissions are indicated by the disposal emission factor. 

It has not been possible to substantiate empirically disposal emission factors in detail as no 

reliable measurement approach exists for this type of emissions. Existing monitoring 

systems, including the Dutch STEK system, refer to use-phase emissions only and disregard 

from disposal emissions. Statistics on recovered F-gas quantities for recycling, reclamation 

and destruction (RRRD) are only partially helpful, because they do not indicate quantities 

recycled onsite and quantities released to the atmosphere during recovery. End-of-life or 

disposal emission factors used in the model AnaFgas are based on expert assumptions as 

outlined in chapter 2 on methodology. 

Before adoption of the F-gas Regulation, many experts expected a significant decrease in 

use-phase emissions within a short time after entry into force. This expectation was based on 

experience from the Dutch STEK system regulating ODS and HFCs, which is the model for 

containment provisions of the F-gas Regulation. Reduction of the overall use-phase emission 

factor in stationary refrigeration and air conditioning by 50% was considered to be likely 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 157 

within five years, because the STEK system was reported to have cut of the annual leakage 

rate in the Netherlands from more than 11% to less than 5%239, within the same timeframe240. 

Empirically verified data on use-phase emission factors are available to very limited extent 

only. It is not possible to simply extrapolate available data to all sectors and EU-27. 

Therefore, assumptions on use-phase emission factors were made as described and listed in 

chapter 2 on methodology. Emission reductions caused by bans set out in the F-gas 

Regulation (Articles 8 and 9) are reflected in the model AnaFgas from 2008 onwards. 

5.2 Current and projected impact of the F-gas Regulation and its 

cost-effectiveness 

5.2.1 Model output: Emission scenarios in EU-27 

The impact of the F-gas Regulation is illustrated by a comparison of the counter-factual 

WOM scenario and the WM scenario calculated by the model AnaFgas. 

• Without measures (WOM): An emission scenario for the EU-27 and each MS 

reflecting the situation that would likely have occurred since 1995 (baseline year for 

F-gases under the Kyoto Protocol) without the 2006 EU policy intervention (F-gas 

Regulation, MAC Directive). The projected emissions until 2050 are based on sub 

sector specific growth assumptions, which in most cases do not include technology 

changes or introduction of alternative fluids (“frozen technology”). Often the F-gas 

bank of the last year, or the trend over the last years before enforcement of F-gas 

legislation is extrapolated to the future in order to estimate emissions. Details are 

given in the model description in annex III. 

• With measures (WM): A scenario of actual or baseline emission trends for the period 

1995-2050 taking into account the existing policies and measures to reduce F-gas 

emissions in EU-27 and each Member State. The WM scenario is based on the same 

underlying growth trends as the WOM scenario, but varies those parameters that are 

influenced by the European legislation (F-gas Regulation, MAC Directive) for the 

period when the respective policies and measures are expected to be effective. 

These parameters include leakage rates, recovery efficiency and the substitution of 

certain gases which would not have occurred without regulatory action. 

Both the WOM and the WM scenario include not only F-gas emissions but also the 

underlying demand for F-gases. In chapter 8, a further scenario with additional measures 

(WAM) is presented. It shall help determine the emission and demand reductions which 

could be achieved by additional policies and measures which are discussed in that chapter. 

F-gas emissions and the differences between the two scenarios are summarized in table 5-1 

for selected years. Figure 5-1 shows F-gas emissions in EU-27 in the period 1995-2050. All 

data in this chapter are calculated with GWP values from the 4th IPCC Assessment Report. 

 

239 The basis for these assumption was the 2003 report “Assessment of the costs and implication on 

emissions of potential regulatory frameworks for reducing emissions of HFCs, PFCs and SF6“ by the 

consultancy Enviros. In this study the timescale for emissions reduction is the Kyoto timeframe of 

2008 to 2012, consistent with the ECCP analysis. 

240 Dan de Bruyckere, current manager of STEK, pers. comm. 27 August 2010. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 158 

Table 5-1: F-gas emissions in EU-27 in the WOM and WM scenarios in 2000-2050 (kt CO2 eq) 

and differences between the scenarios (kt CO2 eq; %) 

 2000 2006 2008 2010 2015 2020 2030 2050 

WOM 84,929 92,162 104,013 116,114 144,580 164,561 183,928 204,162 

WM 84,929 92,162 103,104 113,253 113,666 118,489 103,657 110,824 

Diff in kt CO2 0 0 909 2,861 30,914 46,072 80,271 93,338 

Diff. In % 0 0 0.9% 2.5% 21.4% 28.0% 43.6% 45.7% 

Table 5-1 shows that without policy measures, the emissions of fluorinated greenhouse 

gases in EU-27 would increase from 92 Mt CO2 eq in 2006 to more than 204,000 kt CO2 eq 

until 2050. In case of full application of EU F-gas legislation, F-gas emissions can be reduced 

substantially as compared with the WOM scenario. Relative emission reductions can amount 

to 2,900 kt CO2 eq (2.5%) in 2010, 31,000 kt CO2 eq (21%) in 2015, ca. 80,000 kt CO2 eq 

(44%) in 2030 and 93,000 kt CO2 eq (46%) by 2050. 

EU-27 All sources

0

50,000

100,000

150,000

200,000

250,000

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050

[kt CO2eq]

Without measures With measures

Figure 5-1: F-gas emissions in 1995-2050 in a scenario without measures (WOM) and a 

scenario with measures (WM) of EU F-gas legislation. The shape of the emission curves 

indicates the emission reduction potential for F-gas emissions. From 2008/2010 onwards the 

two curves distinctly split up. In the WM scenario, emissions will remain at a stable level from 

2010 until 2050, while in the WOM scenario emissions continue to increase up to almost the 

double. It should be noted that even in the WM scenario absolute emissions in 2050 will be 

higher than in the WOM scenario in 2008 (by 6,800 kt CO2 eq). 

Scenario without measures (WOM) 

Without EU policies addressing F-gas emissions, total emissions would rise by 122% in the 

period 2006-2050. In 2006, the year of entry into force of the F-gas Regulation and the MAC 

Directive, F-gas emissions in EU-27 amounted to ca. 92 million t CO2 eq. They would 

increase to 204 million tons by 2050. A particular steep rise would take place until 2030 and 

F-gas emissions would reach 184 million t CO2 eq then (table 5-1). 

Table 5-2 reveals that under WOM, the refrigeration sectors (including commercial, industrial, 

and transport refrigeration) and mobile air conditioning would contribute 25%-30% each to 

total F-gas emissions in 2030 and 2050. Stationary air conditioning would become the largest 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 159 

sector, accounting for 29% in 2050. HFC refrigerants cause most of the F-gas emissions in 

EU-27. 

Table 5-2: Historical and projected F-gas emissions (kt CO2 eq) in EU-27 by sectors in the WOM 

and WM scenarios in 2000-2050, GWP values according to the 4th IPCC AR 

 2000 2006 2008 2010 2015 2020 2030 2050 

WOM 

Total by Sector 84,929 92,162 104,013 116,114 144,580 164,561 183,928 204,162 

Refrigeration 13,471 28,530 34,478 39,347 49,295 52,884 54,833 56,862 

Stationary A/C & HP 2,110 8,693 11,750 15,058 26,761 38,195 52,113 59,091 

Mobile A/C 10,679 25,172 30,625 34,525 40,026 43,254 49,391 58,652 

Foams 8,304 4,954 4,721 4,906 5,408 5,938 7,034 8,680 

Other HFCs 7,223 9,651 9,423 9,491 10,083 10,500 10,748 11,181 

SF6 users* 9,610 5,919 5,887 6,370 7,399 8,808 4,824 4,711 

PFC and Haloprod 33,532 9,242 7,129 6,417 5,607 4,982 4,986 4,985 

WM 

Total by Sector 84,929 92,162 103,104 113,253 113,666 118,489 103,657 110,824 

Refrigeration 13,471 28,530 34,478 39,347 32,093 34,363 35,556 37,277 

Stationary A/C & HP 2,110 8,693 11,750 15,058 20,641 28,206 36,992 40,971 

Mobile A/C 10,679 25,172 30,625 34,525 36,608 30,105 8,426 8,736 

Foams 8,304 4,954 4,480 3,299 3,631 3,974 4,634 5,746 

Other HFCs 7,223 9,651 9,423 9,155 9,503 9,893 10,143 10,576 

SF6 users* 9,610 5,919 5,220 5,452 5,583 6,966 2,921 2,533 

PFC and Haloprod 33,532 9,242 7,129 6,417 5,607 4,982 4,986 4,985 

*This sector includes the following sub sectors: electrical switchgear, magnesium and secondary 

aluminium industry, soundproof glazing, car tires, and footwear. 

The other sectors including aerosols, solvents and fire extinguishers („other HFCs”) and 

foam blowing agents, which caused almost two-thirds of global warming emissions of 

fluorinated gases (CFCs, HCFCs) 20 years ago, currently play a minor role compared to 

HFC refrigerants. Even in the WOM scenario, emissions of “other HFCs” would rise only 

slowly in the future. 

This also applies to emissions of SF6, and to PFCs released during semiconductor and 

aluminium manufacture as well as to emissions from the production of halocarbons. 

Halocarbon production causes amongst others by-product emissions of HFC-23 which 

accounted for 25% of the total F-gas emissions still in 2000 (50% in 1995). Due to abatement 

technologies and as a result of the HCFC phase out, HFC-23 emissions have decreased in 

recent years. Further information on HFC-23 by-product emissions are laid down in chapter 

5.3. As mentioned earlier, PFC emissions and emissions from halocarbon production are not 

affected by any provisions of the F-gas Regulation241. 

 

241 Annex II of the F-gas Regulation prohibits placing on the market of PFCs in fire protection systems 

and fire extinguishers, in addition to F-gases in footwear. The last year in which PFC (C3F8) containing 

sport shoe soles were sold to the EU market was 2006, and PFCs (C4F10) have not been used for new 

fire protection equipment since 2005. A specific reduction of emissions from the F-gas Regulation 

cannot be identified. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 160 

With-measures (WM) scenario 

The WM scenario is used to calculate emission reductions until 2050 as compared to the 

WOM scenario, which result from EU F-gas legislation including the current F-gas Regulation 

and the current MAC Directive. 

Tables 5-1 and 5-2 show significantly lower emissions in the WM scenario than in the WOM 

scenario from 2010 onwards. The difference to the emissions in the WOM scenario amounts 

to 46% in 2050. 

Calibration of the model output: Comparison with CRF reports 

Sectoral data of the model AnaFgas are only partly based on emission data reported by the 

Member States to the UNFCCC in form of CRF tables although CRF data represent the best 

available empiric information source on F-gas activity data and emissions in Member States. 

Sectors largely relying on CRF data include fire protection, solvents, semiconductor 

manufacture, primary aluminium production, production of halocarbons, and XPS foam (see 

description of model AnaFgas in annex III). 

As CRF data are often too general, incomplete, and not sufficiently transparent and of 

varying quality, most sectoral data were compiled in a different manner, as described in 

annex III. 

A comparison of the F-gas emissions reported by CRF and F-gas emissions calculated by 

the model AnaFgas has been undertaken for validation. This comparison refers to historic 

data until 2009 and does not look at projected emission data. 

Table 5-3 summarizes the total EU F-gas emissions for the years 2000-2009. In the first line 

emissions from the recent CRF submission (EU CRF table 10s4.2) in 2011 are listed. The 

second line contains total F-gas emissions from the model AnaFgas. The GWP values are in 

both time series from the 2nd IPCC AR, because they are used in CRF reporting. 

Table 5-3: Comparison of CRF reported EU F-gas emissions with the model output, for the time 

series 2000-2008, in kt CO2 eq. GWP values according to 2nd IPCC AR242

kt CO2 eq 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

CRF 66,205 63,833 66,949 69,303 70,113 73,485 74,657 78,551 80,950 81,352 

Model 74,023 69,197 70,722 71,701 74,285 77,694 79,887 83,077 89,210 92,707 

Diff in % 12% 8% 6% 3% 6% 6% 7% 6% 10% 14% 

 

242 Note that reporting to the UNFCCC, which includes CRF data, needs to be based on GWP values 

according to the 2nd IPCC AR. For comparison, the model data given in this table are also calculated 

by using these GWP metrics while most other data in this report are based on GWP values from the 

4th IPCC Assessment Report. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 161 

Figure 5-2 illustrates the comparison of the model output and CRF data. 

EU F-gas emissions by CRF and AnaFgas model

 2000-2009, in kt CO2eq. 

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

CRF

Model 

Figure 5-2: Comparison of CRF reported F-gas emissions for the EU (left bars) with the model 

output of the EU F-gas emissions (right bars). The deviation between the annual data ranges in 

the order of magnitude, which is considered acceptable. 

From the comparison it can be seen: 

1. CRF reports and model output feature the same upward trend from 2001 to 2009. 

2. The deviation between the annual emission data ranges between 2% and 14%. 

3. The model emissions are always higher than the national reports. 

The third point is not surprising because the model sets the same completeness standards to 

all Member State reports and frequently adds data where MS do not provide any 

information243. The result of the comparison is considered an indication of the quality of the 

model output. 

 

243 For instance, one country has never reported HFC-23 by-product emissions although there is an 

HCFC-22 plant with estimated emissions of at least 0.4 million t CO2 eq. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 162 

5.2.2 Emission Reduction Potential of current EU F-gas legislation

Emission reduction potential by types of measures 

While empirical data and time series on emission reductions caused by measures of the Fgas Regulation are currently lacking, it can be expected that once the F-gas Regulation is 

fully implemented and applied in EU-27, F-gas emissions can be substantially reduced 

already within the next few years (2011 - 2015). 

Data on results of containment measures

Reliable data on a broad basis to assess the quantitative effects of containment measures of 

the F-gas Regulation is not yet available. As outlined in chapter 2 on the measurability of 

emission reductions, evidence for quantitative effects requires evaluation of appropriate 

records and compilation of data in appropriate databases. 

Significant evaluation and compilation of data in databases have not been undertaken so far, 

because implementation of certain key provisions of the F-gas Regulation in the Member 

States either occurred just recently or is still ongoing. New monitoring systems which are 

intended or currently being established in some Member States are promising. Time series 

sufficiently long for determination of leakage rate trends are not expected before the next 

couple of years. 

Stakeholders from industry are aware of this problem. Whilst some experts state that a 

substantial reduction of leakage rates has been already achieved by the F-gas Regulation244

no comprehensive information to verify this assumption by reliable large scale empirical data 

is currently available. As outlined, few data available from the commercial refrigeration sector 

(table 2-5) already indicate an effect of containment measures: For the time period 2004-

2009 a reduction of the emission rate from 18 – 15% for a large population of supermarkets 

can be seen. In other cases (industrial refrigeration) a trend could not yet be verified. 

The association of F-gas manufacturers, EFCTC, underlines that no databases exist with 

quantitative indicators on the development and occurrence of leakage rates. “Furthermore, 

even if emissions were estimated, the length of the EFCTC database, at two years since the 

implementation of the regulation, is too short to give a statistically significant trend”. EFCTC 

refers to the analysis of reported data245 on consumption and emissions from EU Member 

States submitted to UNFCCC, which show “continuing trends in improvement in containment 

that predates the implementation of the F-gas Regulation”. Apart from methodological 

problems, these studies are not of relevance for the analysis because they do not relate to 

the period after introduction of F-gas Regulation and cannot be used as indicator of the 

effectiveness of the containment measures of this Regulation. 

 

244 Statement by AREA: “Experience from countries that either implemented the Regulation in time or 

had leakage check requirements in place beforehand, however, shows a substantial decrease in 

leakage rates, which is now well under 10%.” 

245 A. McCulloch, Evidence for improvements in containment of fluorinated hydrocarbons during use: 

an analysis of reported European emissions. Environmental Science & Policy 12, 2009, 149-156. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 163 

The fire protection industry could not provide data on current trends of leakage rates in the 

context of the application of the F-gas Regulation either.246 

Emission reduction potentials in 2015-2050

Due to the described lack of empirical time series, model data had to be based on 

assumptions concerning emission factors (see chapter 2 on methodology). 

Emission reduction potentials refer to the potential effect of current measures on emission 

reductions and can be calculated by comparing projected emissions of the WOM scenario 

and the WM scenario. 

Particular large emission reduction potential emerges through containment and recovery 

measures as set out by Articles 3 and 4 of the F-gas Regulation, which address emissions 

from the sector of stationary refrigeration and the sector of stationary air conditioning 

including heat pumps. In the WOM scenario the emissions from these sectors are projected 

to rise from 2010 to 2015 by 10 million t CO2 eq (table 5-2), each. In the WM scenario the 

aggregated emissions from the two sectors decrease by 1.7 million t CO2 eq in the same 

time periods. Emissions from refrigeration247 even decrease within the 5 years, by 7 million t 

CO2 eq compared to the WOM scenario. By 2050, emission reductions in those sectors will 

have increased to 38 million t CO2 eq compared to WOM due to measures of containment 

and end-of-life recovery set out by the F-gas Regulation. 

As for the fire protection sector and the high voltage switchgear sector, potential emission 

reductions resulting from containment and recovery measures will amount to 1 million t CO2

eq by 2015 (table 5-7). This emission reduction potential will remain stable until 2050. 

Bans according to Articles 8 and 9 of the F-gas Regulation will lead to emissions reductions 

(relative to WOM scenario) in the foam sectors, other HFC sectors and all applications of SF6

in the range of 3 million t CO2 eq by 2015 (table 5-8). Emission reduction potentials of these 

sectors are expected to increase to 4.6 million t CO2 eq by 2050. 

As for mobile air conditioning, emission reductions resulting from measures of the MAC 

Directive will begin in 2011 (assumed start of the phase-out of HFC-134a) and take several 

years to reach their full potential. In the model, HFC emissions from AC systems contained in 

passenger cars will be almost completely cut by 2029 (figure 5-3), which leads to emission 

reductions of 50 million t CO2 eq by 2050, compared to the WOM scenario. Remaining F-gas 

emissions will be released from mobile air conditioning systems contained in other subsectors such as trucks, buses, ships, and railcars, which are not effectively addressed by 

current measures248. 

 

246 In its response to the Öko-Recherche questionnaire on Fire Protection Systems (May 2010), the 

association ASSURE refers to a recent report from the US-HFC Emissions Estimating Program 

(HEEP) which indicates a 2008/2009 decline in USA. ASSURE concludes: “The reduction in 

emissions in 2008 and 2009 is likely the result of an overall decline in economic activity rather than a 

large decrease in emission rates.” Specific data on Europe are not provided by this association. 

247 Refrigeration includes also mobile systems in trucks or fishing vessels. The indicated emission 

reductions from the F-gas Regulation (WM scenario) occur only in the stationary subsectors. 

248 In the model, the general provision of Art 4(3) for recovery by “appropriately qualified personnel” is 

not considered to impact quantitatively the disposal emission factor in mobile air conditioning of cars, 

trucks, buses and other vehicles. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 164 

EU-27 Mobile A/C

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050

[kt CO2eq]

Without measures With measures

Figure 5-3: EU-27 emissions from mobile air conditioning in the WOM and WM scenarios. The 

effect of the MAC Directive for passenger cars can clearly be seen in the curve split from 2011 

onwards. From 2030 HFC emissions are released from MAC systems in trucks, buses, ships 

and railcars only. 

Table 5-4 and figure 5-4 show emission reduction potentials of containment measures 

according to Article 3, recovery measures according to Article 4, prohibition measures of 

Articles 8 and Art 9 set out by the F-gas Regulation, and the emission reduction potential of 

the prohibition of HFC-134a (substances with GWP >150) according to the MAC Directive. 

Table 5-4: Emission reduction potentials (kt CO2 eq) of measures set out by EU legislation on 

F-gases (including F-gas Regulation and the MAC Directive) in 2008-2050 (WOM-WM) 

 2008 2009 2010 2015 2020 2030 2050 

MAC 

Directive 0 0 0 3,419 13,150 40,965 49,916 

Art 3 and 

Art 4 0 0 0 24,357 29,478 35,609 38,815 F-Gas 

Regulation Art 8 and 

Art 9 909 2,687 2,861 3,012 3,223 3,750 4,616 

Total 909 2,687 2,861 30,787 45,850 80,325 93,347 

Emission reduction from prohibition measures is visible with measurable effect already in 

2008 and 2009. The sectors concerned are one-component-foam (OCF), novelty aerosols, 

SF6 for magnesium die casting, and SF6 for car tyres. 

From 2015, the year for which full application of the F-gas Regulation is assumed and 

Articles 3 and 4 take effect, emission reduction in stationary refrigeration and air conditioning 

equipment determines the overall picture, with the tenfold emission reduction potential of 

Articles 8 and 9. 

From 2030 onwards, the MAC Directive contributes the largest emission reductions of all 

measures of almost 50 million t CO2 eq by 2050. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 165 

Emission reduction by 2006 EU F-gas legislation 

2006-2050

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

2008 2009 2010 2015 2020 2030 2050

kt t CO 2 eq

MAC Directive

Art 3 and Art 4

Art 8 and Art 9

Figure 5-4: Emission reduction potential of the EU F-gas legislation by containment/recovery 

measures according to Art 3 and 4 of the F-gas Regulation, prohibition measures of Art 8 and 

9, and by the MAC Directive in EU-27 in selected years. In 2015 and 2020 containment and 

recovery measures show strongest effect. The MAC Directive contributes large emission 

reductions in 2015. Prohibition measures show measurable effects in 2008 already. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 166 

Emission reduction potentials by sectors 

Detailed information on emission reduction potentials of each sector subject to current EU Fgas legislation helps to determine the effectiveness of different types of policy measures. 

• Stationary refrigeration, air conditioning and heat pumps & mobile refrigeration 

The emission reduction potential widely differs by sub sectors of the refrigeration and air 

conditioning sector (table 5-5). 

Table 5-5: F-gas emission reduction potential (kt CO2 eq) in refrigeration and air conditioning 

by sub sectors until 2050 (WOM-WM) 

Sub sector 2010 2015 2020 2030 2050 

Domestic Refrigeration 0 190 130 3 3 

Commercial Refrigeration 0 11,800 13,000 13,600 13,900 

Industrial Refrigeration 0 5,200 5,445 5,670 5,670 

Transport Refrigeration (road) 0 0 0 0 0 

Transport Refrigeration (fishing) 0 0 0 0 0 

Subtotal Refrigeration 0 17,190 18,575 19,273 19,573

Moveable & Single split 0 3,800 6,500 10,600 12,500 

Multi split & Rooftop 0 930 1,400 1,900 2,000 

Chillers incl. centrifugal 0 1,300 1,800 1,900 1,900 

Heat Pumps 0 50 180 900 1,800 

Subtotal Stat. AC & heat pumps 0 6,080 9,880 15,300 18,200

Total 0 23,270 28,455 34,573 37,773

Table 5-5 highlights the following aspects: 

- Not surprisingly, commercial refrigeration, where large centralised systems with 

comparably high use-phase-emission factors prevail, shows the highest reduction 

potential in all years, ranging from 11.8 (2015) to 13.9 million t CO2 eq (2050). 

- The sub sector of small room air conditioners (moveables and single split) with 

refrigerant charges <3 kg is not subject to containment measures of Art 3 but only to 

recovery measures of Art 4. Nevertheless, the emission reduction potential is almost 

as high as that of commercial refrigeration, by 2050 (12,500 kt CO2 eq). The high 

reduction potential is a result of the high market growth of room air conditioning 

systems of the single-split type, which is forecast until 2030. The emission reduction 

potential results only from an increase in recovery efficiency at end-of-life, with a 

reduction of the disposal emission factor from 70% to 35%. 

- In 2030, emission reduction potential of 5,670 kt CO2 eq in the industrial refrigeration 

sub sector is reached. This potential is mostly based on containment measures. 

- Emissions from chillers, multi-split & rooftop air conditioners, and heat pumps show 

reduction potentials by 2030 of 2,000 kt CO2 eq each. While chillers and multi-split air 

conditioners are subject to both Art 3 and Art 4, most domestic heat pumps have 

charges <3kg and are only subject to recovery by certified personnel. 

- Emission reduction potential in domestic refrigeration from application of Article 4 

(recovery at end-of-life) is low not only because the absolute amount of emissions is 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 167 

small but also because the end-of-life treatment is already covered by the WEEE 

Directive and is reflected in the WOM scenario. 

• Mobile air conditioning 

Currently only mobile air conditioning systems contained in passenger cars are subject to EU 

legislation addressing F-gas emissions, i.e. the MAC Directive. The general provision of Art 

4(3) for recovery by “appropriately qualified personnel” is not considered to impact 

quantitatively the disposal emissions in mobile air conditioning. The high emission reduction 

potential in the sub sector of passenger car air conditioning in 2050 is caused by two 

aspects: Firstly, the refrigerant bank is by far the largest F-gas emission source in Europe. 

Secondly, emissions will be cut to a very low level as the MAC Directive establishes a full 

phase-out of refrigerants with GWP >150 in this sector. 

Table 5-6: F-gas emission reduction potential (kt CO2 eq) in the sub sector of passenger car air 

conditioning until 2050 

2010 2015 2020 2030 2050 

MAC in passenger cars - 3,419 13,150 40,965 49,916 

• Fire protection and electrical switchgear 

The emission reduction potential in this sector amounts to 250-300 kt CO2 eq during the 

period 2015-2050. It is comparably low although both containment and recovery measures 

must be applied in the sector (Articles 3 and 4 of the F-gas Regulation). The reason is that 

independent from the F-gas Regulation in this sector regular inspection is quasi standard in 

order to meet the particularly high reliability requirements of fire suppression equipment. This 

is an important difference to the sectors and sub sectors of stationary refrigeration and air 

conditioning where the application of Art 3 of the F-gas Regulation will significantly increase 

the current level of leak control activities, with differences between individual sub sectors. 

We estimate that in the fire protection sector only in a minority of cases the containment 

provisions of the Regulation cause higher frequency of control measures by qualified 

personnel, compared to the current situation. Therefore the emission factor of 2.5% is 

considered to experience only a small further reduction to 2.3%, from application of Art 3. As 

disposal emissions on-site are negligible because most end-of-life emissions arise in off-site 

reclamation facilities which are not subject to the F-gas Regulation, further significant 

disposal emission reduction is not assumed (disposal emission factor decreases from 10% to 

9%). 

The emission reduction potential of the switchgear sector is based on recovery measures 

only (Article 4) which lead to some decrease in disposal emissions of SF6. 

Table 5-7: F-gas emission reduction potentials (kt CO2 eq) in the fire protection and switch gear 

sectors until 2050 

2010 2015 2020 2030 2050 

Fire protection 0 245 272 270 270 

Electrical switchgear 0 830 805 763 760 

Total 0 1,075 1,077 1,033 1,030 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 168 

• Other sectors 

Article 8 of the F-gas Regulation includes prohibitions of the use of SF6 in large magnesium 

die casting plants and for filling of vehicle tyres. Article 9 includes prohibition of placing Fgases on the market, in particular for soundproof windows (SF6), one-component foam 

(HFCs), and novelty aerosols (HFCs). Emission reduction potentials for these subsectors are 

listed in table 5-8. 

The last full years before these prohibition measures are mostly 2006 or 2007, for novelty 

aerosols it is the year 2008. Emission reduction effects can hence already empirically be 

identified in 2008 for some SF6 sub sectors and OCF foam. In the model AnaFgas the 2008 

emission reduction (WM vs. WOM) is in the case of the affected SF6 applications 0.68 

million t CO2 eq and 0.24 million t CO2 eq in the foam sector (OCF). The highest emission 

reduction potential based on prohibition measures (Articles 8 and 9) is achievable in the OCF 

sub sector, increasing from 2009 to 1.8 million t CO2 eq by 2015, and to almost 3 million t 

CO2 eq by 2050. 

From 2009 onwards, car tyres, and novelty aerosols also cause significantly lower emissions 

and show certain emission reduction potentials. The use of SF6 for soundproof glazing and 

emissions during manufacture started decreasing in 2009. However, end-of-life emissions of 

SF6 from this application are expected to peak in 2020. 

Table 5-8: F-gas emission reduction potential (kt CO2 eq) of sub sectors covered by prohibition 

measures (Articles 8 and 9 of the F-gas Regulation) 

 2008 2009 2010 2015 2020 2030 2050 

OCF 242 1,607 1,607 1,777 1,965 2,400 2,934 

Novelty aerosols 0 264 335 335 335 335 335 

Mg die casting 668 647 653 600 609 672 739 

Soundproof windows 0 169 172 188 203 231 497 

Car tyres 0 0 93 112 112 112 112 

Total 909 2,687 2,861 3,012 3,223 3,750 4,616 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 169 

5.2.3 Impact of the EU F-gas policy framework

In 2003, the European Commission's proposal for a Regulation to reduce emissions of 

fluorinated greenhouse gases249 was expected to reduce the F-gas emissions by ca. 23 

million t CO2 eq by 2010 (EU-15), which were projected to increase to 98 million t CO2 eq 

until 2010 in a business as usual projection250. 

This implied the target of not exceeding 75 million t CO2 eq by 2010 (GWP values of the 2nd

IPCC AR). The WM scenario of the model AnaFgas projects F-gas emissions in EU-15 (not 

including the 12 new Member States) to range at about 82.4 million t CO2 eq in 2010. This 

value is ca. 7 million t CO2 eq above the emission abatement target of 75 million t calculated 

in 2003, but it is to considerable extent below the amount of 98 million t CO2 eq in the 

mentioned business-as-usual projection. 

It must be pointed out that the comparably slow emission increase until 2010 is only to a 

small part caused by the F-gas Regulation. Empirically verified impacts of the F-gas 

Regulation today only refer to the sub sectors covered by prohibition measures (Articles 8 

and 9) and amount only to 2.4 million t CO2 eq (table 5-4, recalculated GWP values). As 

outlined in chapter 4, implementation and application of the provisions of the F-gas 

Regulation in EU-27 are progressing slowly and are hardly monitored on large scale. 

However, in anticipation of the F-gas Regulation, numerous actors have made important 

efforts to reduce use-phase emissions or replace F-gases by other substances and 

technologies. This increase of awareness has certainly contributed to prevent an increase of 

the F-gas emissions to the projected amount of 98 million t CO2 eq in 2010. 

From the model AnaFgas, which was developed in the course of this project, it can be 

concluded: Without policy mitigation measures, the emissions of fluorinated greenhouse 

gases in the EU-27 would increase from today (2009/2010) ca. 110,000 kt CO2 eq to more 

than 204,000 kt CO2 eq (GWP 4th AR) until 2050. The F-gas legislation which includes the Fgas Regulation and the MAC Directive opens up the opportunity to significantly slow down 

the increase of future emissions. The emission reduction potential relative to the “withoutmeasures-scenario” scenario totals 31,000 kt CO2 eq in the short-term (by 2015) and even 

93,000 kt CO2 eq in the long-term (by 2050). 

While the MAC Directive is considered to substantially cut HFC-134a emissions in the mobile 

air conditioning sector, the F-gas Regulation will leave large quantities of F-gas emissions 

continue rising. This is not only due to the fact that certain emission sources are not 

addressed by containment and/or recovery measures, such as mobile refrigeration 

equipment, the sectors of XPS or PU rigid foam, or the semiconductor industry. Even after 

full implementation and application of the F-gas Regulation large quantities of F-gas 

emissions will arise in the sectors which are already subject to containment measures. 

Figure 5-5 shows a comparison of F-gas emissions in the WOM and WM scenarios by those 

individual sectors which are already subject to the F-gas Regulation. The reference year is 

2030. 

 

249 This proposal was a key element of the first phase of the European Climate Change Programme 

(ECCP), which was established in June 2000 to identify cost-effective reduction measures. 

250 European Commission: Climate Change: Commission tackles fluorinated gases. Press Release 

from 12.08.2003, IP/03/1155. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 170 

Remaining emissions after application of F-gas Regulation, 

by sectors, 2030

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

Domestic Ref

Room AC

Heat Pumps

Industrial Ref

Commercial Ref

Multisplit&Rooftop

Chillers

Fire protection

Aerosols+MDI

OCF

Mg casting +Al

Car tyres

Soundproof glaz

Switchgear

WOM

WM

Figure 5-5: Comparison of F-gas emissions (kt CO2 eq) in 2030 as projected in the WOM and 

WM scenarios by sectors covered by measures of the F-gas Regulation. 

In 2030, from those sectors that are covered by the F-gas Regulation emissions of 120,000 

kt CO2 eq would arise in the WOM scenario. In the same year and the same sectors, the 

emissions will be reduced by 39,000 kt CO2 eq from application of containment and recovery 

provisions. However, emissions of 81,000 kt CO2 eq are still left unabated. 

Although already covered by containment and recovery provisions the following sectors will 

account most of the remaining F-gas emissions in 2030: 

- Room air conditioning (27,300 kt CO2 eq) 

- Commercial refrigeration (20,400 kt CO2 eq) 

- Industrial refrigeration (10,100 kt CO2 eq) 

Options for further EU action addressing F-gas emissions are assessed in chapter 8 of this 

report. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 171 

5.3 Cost-effectiveness of the EU F-gas Regulation 

Effectiveness is a key criterion for the quality assessment of any environmental law. 

Evidently, the effect of the F-gas Regulation refers to the reduction of emissions of 

fluorinated greenhouse gases in EU-27. We estimate that as a result of full implementation 

and application of the F-gas Regulation, the F-gas emissions can be reduced by ca. 27.5 Mt 

CO2 eq until 2015 compared to a projection without policy measures (WOM scenario without 

passenger cars minus WM scenario minus passenger cars). The emissions reduction as a 

result of the F-gas Regulation would increase to 39.3 Mt CO2 eq by 2030. 

The second key criterion for the F-gas Regulation is its cost effectiveness which can be 

expressed in quantitative terms by the relationship between annual cost and annual 

emissions reductions. 

In chapter 4.3, the total cost was estimated that arises to industry, operators, and authorities for 

and from implementation and application of the F-gas Regulation. One-off cost and recurring 

cost was distinguished. The one-off costs which are for the most part caused by personnel and 

company certification according to Art 5 of the Regulation amount to €617 million. Recurring 

costs are estimated at €1,061 million in 2015 and €1,551 million in 2030. Additional leak 

checking, repair and recording according to Art 3 of the Regulation in the sectors of stationary 

refrigeration and air conditioning account for two thirds of the annual costs. 

In order to estimate the cost effectiveness for a particular year, the one-off cost must be 

annualised. We assume that the one-off measures for the implementation of the Regulation 

will be valid at least for ten years251. Under these conditions the annualised cost for 

certification (and labelling) amount to approx. €60 million (no discounting). 

In the year 2015, for which we assume full application and full effect of the measures of the 

F-gas Regulation, the total annual costs are €1,121 million (table 5-9). The efficiency of the 

Regulation can be expressed by a single coefficient, such as the relationship between the 

annual cost in 2015 and the projected emission reduction of 27.5 Mt CO2 eq in this year. 

The 2015 efficiency coefficient is hence €1,121 million annual costs divided by 27.5 Mt CO2

eq of emission reduction in this year, and amounts to €40.8 /t CO2 eq. By 2030, the specific 

abatement cost by the F-gas Regulation would be in the same order, with €41.0 /t CO2 eq 

because both the cost and the emission reduction will increase to the same extent. 

Table 5-9: Estimate of cost effectiveness of the F-gas Regulation in 2015 and 2030 

Article 5 

annualised cost 

Art 3-6 costs 

per year 

Total 

annual cost 

Emission 

reduction 

Cost 

effectiveness 

 million Euro million Euro million Euro Mt CO2 eq € /t CO2 eq 

2015 60 1,061 1,121 27.5 40.8 

2030 60 1,551 1,611 39.3 41.0 

 

251 50% of certifications are valid for 5 years; the other 50% are not limited in time. As an average, we 

assume ten years before re-certification. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 172 

5.4 Emissions not addressed by the EU F-gas policy framework 

Certain F-gas emissions are not currently addressed effectively by the EU F-gas policy 

framework. These include 

- HFC emissions from mobile air conditioning systems contained in vehicles other than 

motor vehicles: Ship AC, Rail AC. 

- HFC emissions from mobile refrigeration systems like refrigerated trucks, refrigerated 

containers or fishing vessels. 

- HFC emissions from foams other than OCF. 

- HFC emissions from halocarbon production. 

- HFC-23 by-product emissions. 

- PFC emissions (e.g. from primary aluminium production, or from the semiconductor 

industry). 

- SF6 emissions from certain applications such as photovoltaic manufacture, particle 

accelerators, air borne military radar systems, etc. 

- F-gas emissions from Organic Rankine Cycles (ORC; i.e. generation of power from 

heat recovery). 

- Emissions of other F-gases not currently included in the scope of the F-Gas 

Regulation: NF3 emissions, SO2F2 emissions, unsaturated HFCs. 

In chapter 8, options for further EU action addressing the following sectors are discussed: 

HFC emissions from mobile AC in ships and rail vehicles, HFC emissions from mobile 

refrigeration, HFC emissions from foams, HFC emissions from halocarbon production, HFC23 by-product emissions, PFC emissions, SF6 emissions and NF3 emissions from 

photovoltaics industry. 

This section includes background information on some of these sectors while others are 

discussed extensively in chapter 6. 

F-gas emissions from ORC

Organic Rankine Cycles (ORC) are used for the generation of power from heat recovery, e.g. 

heat recovery from geothermal sources or waste heat recovery from industrial processes. 

Several tons of HFCs or PFCs (e.g. HFC-245fa, HFC-365mfc, HFC-134a, PFC-4-1-12) are 

contained in each system. So far, little information on the current extent and future potential 

of ORC application in Europe is available and emissions remain to be investigated. 

In this context AnaFgas does not model this sector in WM/WOM scenarios and no measures 

addressing F-gas emissions from ORC systems are discussed. However, this application of 

F-gases should not be overlooked in future analyses and monitoring efforts. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 173 

HFC-23 by-product emissions 

HFC-23 (CHF3) is a fluorinated greenhouse gas with particularly high GWP (14,800). HFC-23 

emissions arise as unintentional by-products from manufacture of HCFC-22 and HFC-32. 

If not emitted, HFC-23 is recovered and used 

- as refrigerant in low temperature refrigeration systems, 

- as fire extinguishing agent, 

- as etch gas in the semiconductor industry. 

The market for these products is of limited size. Before the mid 1990s HFC-23 was used in 

much larger amounts as intermediate for Halon-1301. 

The HFC-23/HCFC-22 ratio in the manufacture of HCFC-22 is typically in the range between 

1.5% and 4%, depending on how the process is operated. Process optimization can 

decrease the generation of HFC-23 below 2%. However, substantial reduction in by-product 

emissions relies on capture and destruction. Mostly used destruction method is incineration 

of the captured gas at >1,200 °C in a thermal oxidation chamber. In Europe, reactor cracking 

in a hydrogen flame at 2,000 °C also plays a role. This abatement technology relies on the 

existence of a hydrogen-source (from chlorine-alkali electrolysis), and cannot be 

universalized. 

Current best practice technology comprising capture and thermal oxidation of the vent gases 

can achieve a destruction efficiency of up to >99%. However, the impact of “down-time” of 

thermal oxidation units, which is estimated at 5%-10% of the operating time of the HCFC-22 

plant252, needs to be taken into account since HFC-23 is released to the atmosphere during 

this time period253. HFC-23 emissions from HCFC-22 plant with an incineration system 

amount to 0.1 to 0.2% of the HCFC-production. 

Before the mid-1990s, 10 HCFC-22 plants were operated in Europe. 4 of them produced 

HCFC-22 as feedstock, 6 produced for end-use applications, mostly refrigerants. To most 

part HFC-23 by-products were captured and processed to Halon-1301. 

When the production of Halon-1301 discontinued, surplus HFC-23, which could not be 

marketed as refrigerant or fire extinguishing agent, was vented to the atmosphere. By 1995, 

2 plants had installed thermal oxidisers, in 1996 another 2 plants started destruction of HFC23. The abatement installations could not prevent an increase of HFC-23 emissions because 

the production of HCFC-22, which was used as replacement for CFCs, grew at even faster 

pace. In 1997, European HFC-23 by-product emissions amounted to 3,000 t and accounted 

for large shares of European GHG emissions (figure 5-6). In 1999 another 2 plants installed 

thermal oxidation systems so that HFC-23 emissions in 2000 ranged at only half of the 1997 

level (1,500 t). Nevertheless, emissions of HFC-23 contributed with 25% to the total 

European F-gas emissions in 2000 (see table 5-10). By 2003 only 2 plants without 

abatement systems were in operation, one of them closed in 2006. In 2008-2010, the closure 

of 4 further plants reduced HFC-23 by-product emissions to their present level of 100 t 

(2011). 

 

252 IPCC/TEAP SROC, 2005, p. TS 81. 253 In some European plants operation-time >95% has been reported. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 174 

Table 5-10: Quantities and share of HFC-23 by-product emissions (MT CO2 eq; %) in total EU Fgas emissions (MT CO2 eq), 1995-2010 (source AnaFgas; GWP according to 4th AR) 

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 

Total Fgas 

emiss 80.9 84.8 88.3 87.1 75.0 84.2 78.2 79.9 81.1 84.2 88.0 90.2 94.2 102 107 114 

HFC-23 

emiss. 39.6 43.0 44.7 42.2 27.6 21.6 13.4 10.9 9.7 6.5 5.8 3.0 2.2 2.5 2.4 1.7 

Share 

 (%) 49% 51% 51% 48% 37% 26% 17% 14% 12% 8% 7% 3.3% 2.4% 2.5% 2.3% 1.5% 

At the end of 2010, 5 chemical plants with HFC-23 emissions were operated in Europe (in 

France, Germany, Netherlands, Spain, and Italy254). Four of them produce HCFC-22 as 

feedstock for fluoropolymers (PTFE); one plant has been retrofitted for the production of the 

HFC refrigerant blend component HFC-32 in 2002. 

By-product emissions of HFC-23 in EU-27

1995-2011, metric tons

0

500

1,000

1,500

2,000

2,500

3,000

3,500

1995 1997 1999 2001 2003 2005 2007 2009 2011

metric tons

HFC-23 emiss

Figure 5-6: HFC-23 by-product emissions in EU-27. The drop from 3,000 t to 100 t in 1997-2006 

results mainly from installation of abatement equipment in the HCFC-22 plants. 

 

254 In measurements of the atmospheric concentration of HFC-23 at the Swiss station “Jungfraujoch”, 

important HFC-23 emission sources were located and identified in four of these countries (Italy, The 

Netherlands, France and Germany) in addition to UK. The conclusion is that the national inventories 

under-report the emissions by 60-140%. The largest discrepancy was found for Italy. The 

measurements were finished in 2010, before the closure of 1 of the 2 German HCFC-22 facilities and 

of the last UK HCFC-22 facility. Source: Christoph A. Keller et al.: Evidence for under-reported 

western European emissions of the potent greenhouse gas HFC-23, in Geophysical Research Letters, 

VOL. 38, L15808, doi: 10.1029/2011GL047976, 2011. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 175 

Three of these five plants (A, B, and C) are equipped with thermal oxidation systems. In 

2008, plant A reported by CRF 26 t emissions, plant B reported 18 t, C does not report, and 

is estimated here at 30 t emissions255. 

The fourth plant (D) is directly connected to the adjacent crack reactor, and reports 0 t 

emissions. 

The fifth plant (E) is not equipped with an abatement system, and reported 26 t emissions. 

Taking account of estimated emissions from plant C, HFC-23 emissions amount to 100 t in 

2011, when the last production plant for HCFC-22 end-use had closed. These 100 t 

emissions from the remaining five plants A, B, C, D, E is estimated the magnitude for future 

HFC-23 by-product emissions in the WOM/WM scenario in the model AnaFgas. 

HFC-23 emissions are in scope of the UNFCCC and its Kyoto Protocol. Thus, they are 

subject to emission reduction obligations by Annex I countries and can be treated by CDM 

projects for HFC-23 mitigation/capture in developing countries. 

The amendment proposals to the Montreal Protocol currently discussed at international level 

both include strict emission limits for HFC-23 by-product emissions and make its destruction 

mandatory. Details of the two proposals with regard to HFC-23 are summarized in table 5-11. 

Table 5-11: Elements of the Montreal Protocol amendment proposals with regard to HFC-23 

emissions 

Proposal resubmitted by the Federates 

States of Micronesia (FSM) in 2011 

Proposal resubmitted by North American 

countries (NA) in 2011 

Entry into force on 1 January 2014 Entry into force on 1 January 2015 

Prohibits production and introduces a regulatory limit on emissions (from condenser vent and 

additional sources) to 0.1% (mass based) of HCFC-22 production (including feedstock uses), i.e. 

mandates destruction of HFC-23 by technologies to be approved. 

This rule does not apply to plants approved by 

CDM projects before 1 January 2010 (provided 

that HFC-23 is indeed being destroyed). 

HFC-23 destruction is subject to financial 

assistance under the Multilateral Funds 

(excluding costs covered by other financial 

mechanisms). 

This rule applies universally. 

HFC-23 destruction is subject to financial 

assistance under the Montreal Protocol (excluding 

costs covered by other financial mechanisms and 

excluding plants and production lines which are 

being covered by ongoing CDM projects). 

In Europe, there is no law that limits the by-product emissions of HFC-23 or obliges the plant 

operators to install abatement equipment. So far, all abatement systems have been installed 

voluntarily by the chemical companies which resulted in emission reductions by 97% during 

the period 1995-2010. However, further emission reduction potential exists as long as 

- 1 of the 5 remaining HCFC-22 facilities operates without abatement technology for 

HFC-23 emissions. The operator has indicated his intention to apply incineration 

equipment but to date this has not happened yet; 

- the abatement technology installed does not perform HFC-23 destruction to the 

extent technically possible. 

 

255 Although the relevant National Inventory Report and CRF claim explicitly that no emissions from 

this plant occur since 1995, we cannot accept this statement, given that the abatement equipment is a 

common thermal oxidiser with usual technical parameters. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 176 

In addition, it should be noted that HFC-23 emissions also occur from production of other 

halocarbons such as HFC-32 (one production facility in Spain). 

For estimates of HFC-23 emissions and related measures for abatement the quantity of 

halocarbons produced in Europe should be used for determining the type of abatement 

technology, and not the quantity of halocarbons placed on EU markets. HFC-23 emissions 

contribute to climate change no matter whether in Europe or elsewhere. 

Chapter 8 on further EU policy action contains suggestions on how to address HFC-23 

emissions from halocarbon production. 

PFC emissions

PFC emissions are in the scope of the F-gas Regulation and must be reported according to 

Article 6. However, semiconductor manufacture and aluminium production, from where most 

PFC emissions arise, is not included in any provisions of the Regulation. 

Another measure targets PFC emissions from aluminium industry: As laid down in the 

revised EU-ETS Directive (Directive 2009/29/EC), PFC emissions from the aluminium 

industry will be included in emissions trading from 2013 onward. As outlined in chapter 3.3, 

this interaction is assumed to support the introduction of technological improvements aiming 

at emission reductions. The estimated decrease of PFC emissions ranges at ca. 1.3 million t 

CO2 eq in EU 27 by 2020. 

PFC emissions from semiconductor manufacture have so far been addressed by a global 

voluntary agreement by industry with specific emission reduction targets for European 

manufacturers (see chapter 3.2). An extension/ update of a voluntary agreement is 

suggested in chapter 8. 

SF6 emissions 

SF6 emissions from electrical switchgear are addressed by measures set out by the F-gas 

Regulation. Furthermore, prohibition measures have limited the use and related emissions of 

SF6 in some applications such as vehicle tyres, footwear, soundproof windows and large 

magnesium die casting facilities. 

Nevertheless, the use and related emissions of SF6 in other applications are not in the scope 

of the F-gas Regulation so far. These applications include small magnesium die casting and 

the sand casting facilities, photovoltaics and semiconductor industries, secondary aluminium 

production, particle accelerators and AWACS radar systems. Data on these emission 

sources are included in the model AnaFgas. 

Policy options (chapter 8) suggest addressing the use of SF6 in small magnesium die casting 

facilities and recycling of magnesium alloys. 

Other F-gas emissions 

Some other F-gases are currently neither included in the scope of the F-gas Regulation nor 

the basket of fluorinated greenhouse gases covered by the Kyoto Protocol which both 

consider HFCs, PFCs and SF6. Two gases from other substance groups used increasingly in 

Europe include NF3 and SO2F2. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 177 

Use and emissions of NF3 

Like several other fluorinated compounds, NF3 is used in electronics industry for cleaning of 

chemical vapour deposition (CVD) tool chamber-walls from residual silicon film. The gas has 

been used since the mid1990s in semiconductor manufacturing, it was introduced before 

2000 to the production of thin-film-transistor flat panel displays (LCDs), and it is in use from 

2004/2005 onwards in the production of photovoltaic cells of the silicon-based thin-film type. 

For a long time the global warming potential of NF3 had been considered tolerable compared 

to that of SF6 which is also widely used for CVD chamber cleaning in the manufacture of LCD 

and photovoltaic cells256. Although the 2nd IPCC AR (1995) had not specified the GWP value 

of NF3, it had been estimated in the 1990s between 8,000 and 10,000257. The 3rd IPCC AR 

(2001) defined the GWP for the first time, with 10,200; the 4th IPCC AR (2007) however, 

increased the GWP to 17,200. Thereby the GWP of NF3 comes close to that of SF6 (22,200), 

so that the gas shows the second highest GWP value of all known greenhouse gases. 

In 2008, NF3 was criticized in the media since high atmospheric concentrations had been 

measured and indicated annual global emissions of more than 600 t258 which were estimated 

16% of the annual production quantity259. 

In the 1990s, the semiconductor industry was the only user of NF3. After introduction of NF3

into the production of flat panel displays (TFT-LCD) and the rapid expansion of the sector 

after 2000 in Korea, Japan, and Taiwan, the demand for NF3 rapidly increased and caused 

quadrupling of the production capacities for NF3 in the USA and East Asia. The gas replaced 

step by step SF6 which had initially been used as main cleaning agent in this sector. NF3

emissions from the East Asian LCD production were considered the main cause of the steep 

increase in measured atmospheric concentrations260. 

The advantage of NF3 compared to PFCs like CF4 or C2F6 is its high “conversion efficiency” 

(utilisation rate) in the low-pressure plasma chamber. This means that in comparison to most 

PFCs, NF3 fed into the deposition chamber provides significantly more elemental fluorine to 

remove the residue silicon from chamber walls and product carriers. Thereby the cleaning 

time shortens up to 60% compared to the CF4 or C2F6 process, and the throughput of the 

targeted substrates (wafers, photovoltaic cells, displays) increases by up to 20%. The higher 

 

256 In the semiconductor industry SF6 is hardly used for chamber cleaning but for the etch process. 

The common chamber cleaning gases are C2F6, CF4 (also used for etching), and in minor quantities 

C3F8 and c-C4F8. In 2007 (only then) in Austria hexafluorobutadiene (C4F6), which is not listed in 

Annex I, had been used in a quantity of 30 kg. This gas is not considered further here. This also 

applies to C4F8O (octafluorotetrahydrofuran) which had been discussed as CVD cleaning gas in 2003 

in the Netherlands (Philips), but for which no consumption could be found in the course of this study. 

257 The 1999 IPCC Good Practice Guidelines note: “Molina et al. have estimated a GWP-100 of 8,000 

and an atmospheric lifetime of 740 years (Molina 1995).” In 1996, McClear/Taylor from the company 

Praxair estimated the GWP at 9,720. McClear, M./Taylor, A., PFC Recycling, in: European 

Semiconductor, July/August 1996, pp. 41-44. 

258 Weiss, R. F., J. Mühle, P. K. Salameh, and C. M. Harth 2008: Nitrogen trifluoride in the global 

atmosphere, Geophys. Res. Lett., 35, L20821, doi:10.1029/2008GL035913. 

Prather, M. J. and J. Hsu 2008: NF3, the greenhouse gas missing from Kyoto, Geophys. Res. Lett., 35, 

L12810, doi:10.1029/2008GL034542. 

259 Weiss et al 2008 (see above): “This rise rate corresponds to about 620 metric tons of current NF3

emissions globally per year, or about 16% of the poorly-constrained global NF3 production estimate of 

4,000 tons yr_1.” 260 NF3 production is estimated to range around at least 6,000 t/y. Almost 5,000 t are used in LCD 

manufacturing in Korea, Taiwan and Japan. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 178 

productivity from the application of NF3 offsets the higher cost261 of this gas and of its feeding 

equipment262. 

Quantities of NF3 used in Europe

Although the application of NF3 in the European semiconductor industry is growing, the 

companies in the sector rarely discontinue employing existing fluorinated cleaning gases in a 

facility once the application has been technically optimized to the chamber cleaning process 

by pressure, time, temperature, plasma power, flow rate, gas ratios and many further 

parameters. Therefore, PFCs (C2F6, CF4) are still the most important fluorinated compounds 

for CVD chamber cleaning in Europe. According to estimates by the European 

Semiconductor Industry Association EECA-ESIA, and by experts from European gas 

distributors, in 2007 approximately 450 t of these PFCs were used in the semiconductor 

industry, while the sales of NF3 to the sector amounted to 300 t263. 

The main user countries of NF3 in Europe, according to our own estimate, are Germany 

(35%), Ireland (28%), France (14%), Italy (11%), and Austria (7%). Minor quantities are used 

in the Netherlands, Great Britain, Finland, and the Czech Republic. 

In European photovoltaic industry, LCD production does not take place. The only 

application outside the semiconductor industry is manufacturing of thin film silicon solar cells. 

This technology represents globally ca. 5% of the overall production of photovoltaic cells, 

80% of which is of the crystalline type to which SF6 or NF3 are not applied. After 2004, NF3

was introduced to new production lines of silicon-based thin-film solar cells in Germany 

where large-sized tool chambers, similar to those in LCD manufacture, are used for 

deposition and removal of silicon film264. SF6 which is still applied to existing facilities is no 

longer used for new production lines. 

In Germany, thin film silicon photovoltaic cells have been manufactured on small scale from 

the mid1990s. From 2003 onwards, the German production of silicon-based thin-film solar 

cells significantly increased and caused a steep rise in the use of SF6 from 3 t to >50 t in 

2008, and in the use of NF3 from 3 t in 2006 to >30 t in 2008265. 

In 2008 the production of silicon-based thin-film solar cells, using NF3 as chamber cleaning 

gas, also started in Spain. In 2009, the sales of NF3 to the 2 Spanish plants are estimated at 

10 t266. 

NF3 use and emissions from electronics industry in Europe 

The present overall use of NF3 in the European electronics industry is estimated at 340 t, 

including 300 t in the semiconductor industry and 40 t in the photovoltaic industry. In terms of 

global warming, the annual use amounts to 5.8 million t CO2 eq. 

 

261 At the end of 2009, in the European photovoltaic industry the price of SF6 was €20 per kg while the 

cost of 1 kg NF3 was ca €40. 262 There are two types of NF3 based cleaning processes: (1) in-situ plasma cleaning and (2) remote 

plasma cleaning. In the latter, NF3 is already dissociated (by microwaves) in a remote plasma source 

(RPS) upstream of the chamber, thus providing higher efficiency for etching of residual silicon films. 

263 Shane Harte from EECA-ESIA: Communication to Öko-Recherche, 25 November 2010. 264 While in semiconductor manufacture, the wafers in the CVD chamber are sized 300 mm, thin film 

silicon solar cells have the size of up to 5.6 square metres. 265 Öko-Recherche 2009: SF6 and NF3 in the German Photovoltaic Industry, study for the German 

EPA (in German). 

266 Estimate by Kai Schwarz, Air Products GmbH Germany, 15 Oct 2010. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 179 

The emissions of NF3, like those of PFCs or SF6, are lower than the purchased quantities 

which are fed into the CVD chamber for cleaning. Effective emissions mainly depend on two 

factors: 

- the fraction of gas destroyed in the cleaning process (process tool emission factor); 

- the fraction of gas destroyed by the emission control technology (emission control 

factor). 

The semiconductor industry is not of the opinion that emissions monitoring via continuous 

measurements of the waste gas is technically or economically viable. Under the 1999 

Voluntary Agreement of the World Semiconductor Council (WSC), which is represented in 

Europe by the European Semiconductor Industry Association EECA-ESIA, emissions from 

semiconductor manufacturing are calculated based on the methodology suggested in the 

1999 IPCC Guidelines for National Greenhouse Gas Inventories. The emissions reporting of 

the EU Member States under the UNFCCC, provided in CRF tables, follows the same 

methodology. The equation used for the calculation is that of the Tier 2c approach as 

described in the Guidelines. The equation uses industry-wide generic default values, the 

most important of which are the average emission factor of a gas and the average 

destruction efficiency of the abatement tool. 

The operating conditions of F-gases in semiconductor manufacturing vary widely, not only by 

companies but also by fabrication plants and production lines, and are not constant over 

time. This does not only apply to existence or absence of abatement tools for the waste gas 

from the process chamber, but also to the degree of dissociation of the F-gas in the process 

chamber itself (process tool emission factor). This should be kept in mind when using default 

emission values for any fluorinated compound including NF3. 

The 1999 IPCC-Guidelines present for NF3 emissions from semiconductor manufacturing a 

default factor of 0.2 (Table 3.15). The 2006 update of the Guidelines confirms this value for 

in-situ cleans in semiconductor manufacturing and additionally presents a default value for 

photovoltaic manufacturing of 0.3267. A default emission factor of 0.02 is given for “remote” 

application of NF3, which, however, has not been used yet for emissions monitoring. 

Compared to SF6, CF4 and C2F6, the NF3 emission factors are low. This means for the 1999 

default factor that only 20% (30% in case of photovoltaic manufacturing) of the gas fed to the 

cleaning process are released unchanged from the process chamber. 

The 1999 IPCC-Guidelines present for Tier 2c an identical default parameter for the 

efficiency of emission reduction technologies of 0.9 for seven fluorinated compounds 

including NF3. The 2006 values, which include also LCD and photovoltaic cell 

manufacturing,268 do not differ from the 1999 values with the exception for NF3. The 

destruction removal efficiency for NF3 is estimated not only 0.9 but 0.95. This means, only 

5% of the NF3 gas fed to the abatement system is released unchanged to the atmosphere 

The combination of default process emission factor and default abatement tool efficiency 

factor, results in an overall default ratio emissions/use for the semiconductor industry of 2% 

(0.2 x 0.1 = 0.02) in the equation of the 1999 Guidelines and of 1% (0.2 x 0.05 = 0.01) in the 

 

267 2006 IPCC Guidelines, volume 3: Industrial Processes and Product Use, Chapter 6: Electronics 

Industry Emissions, Tables 6.3 and 6.5. 268 2006 IPCC Guidelines, volume 3, chapter 6, Table 6.6: Default Efficiency Parameters for 

Electronics Industry FC Emission Reduction Technologies. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 180 

equation of the 2006 Guidelines. In the photovoltaic industry, for which only the 2006 

Guidelines provide default values, the ratio emissions/use is 1.5% (0.3 x 0.05 = 0.015). It 

must be emphasized that these default emission parameters can only be applied to 

production lines which are actually equipped with properly working exhaust gas treatment 

systems, either for application at the point-of-use or at the end-of-pipe. 

Ratio emissions/use in photovoltaic and electronics

It can be expected that modern production lines for photovoltaic cells established after 2006 

do not run without waste gas control269. Strict emission standards are mandatory for this 

sector. All sector experts from solar cell manufacturing, gas distribution, and waste gas 

management interviewed in the context of another study270, confirmed that the 6 plants using 

NF3 for CVD chamber cleans have been equipped with exhaust gas abatement tools 

(thermal decomposition) from the very beginning. Therefore, the 1.5% NF3 emissions value is 

considered plausible and is used in this study. 

However, in the semiconductor industry, where CVD chamber cleaning with NF3 has been 

introduced in the 1990s, waste gas abatement systems are not installed everywhere. Real 

NF3 emission factors in the semiconductor industry differ from plant to plant, and from 

country to country depending on the actual prevalence of emission control systems. Thus, 

the ratio emissions/use ranges between maximum 0.2 (default process emission factor 

without abatement system) and minimum 0.02 (default process emission factor plus 

abatement factor). 

Estimates of NF3 emissions 

Although NF3 is included in the voluntary agreement of the EU semiconductor industry to 

reduce the 2010 emissions of fluorinated compounds below the 1995 level, and the industry 

collects emission data on NF3, so far, the EU Member States that report F-gas emissions 

from their semiconductor industry do not include NF3 emissions in the CRF tables. This is 

because the gas is not subject to the reporting obligations under UNFCCC. Five of the eight 

Member States with domestic semiconductor industry represent more than 95% of this 

industry in EU and report emissions of other fluorinated compounds. Some Member States 

are already collecting NF3 data for their internal F-gas inventory. So far, annual data of use 

and emissions of NF3 are available from Germany and Austria only. Industries located in 

these countries are estimated to account for one third of the EU use. 

For the entire EU, the availability of data on NF3 has significantly improved when EECA-ESIA 

presented combined data on use and emissions for the period 1995-2007 (table 5-12; some 

 

269 The above mentioned study for the German UBA reports statements of operators of new-erected 

German facilities for thin film silicon cells who claim even efficiencies of >99.96% for their emission 

control systems, referring to real measurements (NF3 input to chamber 5,040 g/h, NF3 mass flow after 

waste gas treatment 2.1 g/h). However, one has to distinguish between real operation and optimal 

operation. The 2006 IPCC Guidelines warn against identity of technical top results with real emissions: 

"An emission control device that can destroy 99 percent of an FC when it is optimised to destroy that 

FC on a certain tool may destroy less than 95 percent of that FC when it is optimised to destroy 

something else or when it is used on a tool for which it was not designed, or if the FC or total exhaust 

flow exceeds a certain limit." 2006 IPCC Guidelines, volume 3: Industrial Processes and Product Use, 

Chapter 6: Electronics Industry Emissions, 6.21. 

270 Öko-Recherche 2009: SF6 and NF3 in the German Photovoltaic Industry, study for the German 

EPA (in German). 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 181 

years are omitted, for lucidity). The time series shows a steady growth in use until 2007, and 

a steady growth in emissions until 2006. The global warming potential of the 2007 emissions 

is ca. 97 kt CO2 eq. The emission factor has significantly decreased from 17% to 2% over the 

same period of time, and is now at the level of the default ratio emissions to input (use) of the 

1999 IPCC Guidelines. 

Table 5-12: NF3 use and emissions of the European semiconductor industry in 1995-2007* 

1995 1997 1999 2001 2003 2005 2006 2007 

NF3 (purchase -kg) 9,705 15,730 24,899 76,592 147,622 193,392 223,343 299,791 

NF3 (emissions-kg) 1,700 1,700 3,000 2,700 5,900 6,500 8,100 5,600 

Implied Emission 

factor 17% 11% 12% 4% 4% 3% 4% 2% 

Source: EECA-ESIA, Brussels, 2010 (recalculated from MTCE units) 

By application of an default NF3 emission factor of 1.5% to the photovoltaic industry and of 

2% to the semiconductor industry to the annual use of the gas in the two sectors, emissions 

can be estimated for 2008/2009 (table 5-13) (from 2007 to 2009 no growth in use and 

emissions in the semiconductor industry is assumed). 

Table 5-13: Emissions of NF3 (metric tonnes; kt CO2 eq) from the EU semiconductor and 

photovoltaic industry in 2008 (preliminary estimates; GWP: 17,200) 

Semiconductor industry Photovoltaic industry 

Input (use) in metric t 300 40 

Input (use) in kt CO2 eq 5,160 688 

Emission factor 2% 1.5% 

Emissions in metric t 6 0.6 

Emissions in kt CO2 eq 103.2 10.3 

The emissions of NF3 from the EU electronics and photovoltaic industry are estimated at 115 

kt CO2 eq in 2008. The share of NF3 emissions in total 2008 F-gas emissions (92,200 kt CO2

eq in AnaFgas) amounts to 0.12%. The share of NF3 in the 2008 EU F-gas use, i.e. before 

decomposition in the process is considerably higher, with 3% (total 2008 F-gas use 200,000 

kt CO2 eq in AnaFgas). 

F-gas emissions from semiconductor manufacturing constantly decreased in the period 

1999-2008271 reflecting both, the commitment to the voluntary agreement on PFC emission 

reductions via continuous process optimization and improved abatement technologies. New 

manufacturing facilities have rarely been established in Europe in the last decade in contrast 

to East Asia where the production has expanded. Growth of EU semiconductor production is 

not expected in the medium and long term. This implies that overall F-gas use and emissions 

will remain rather stable. 

Under the voluntary agreement of the EU semiconductor industry to reduce the 2010 

emissions of fluorinated compounds below the 1995 level, the reduction is caused by the 

predominant gases SF6, CF4, C2F6 and CHF3. NF3 which primarily replaces C2F6 is the gas 

with the highest growth rates. 

 

271 In its Intermediate Status Report of the Progress towards the Reduction of Perfluoro-compound 

(PFC) Emissions from European Semiconductor Manufacturing, EECA-ESIA shows graphically a 

decrease of the emissions of C2F6, CF4, CHF3, NF3, SF6, C3F8, and C4F8 from 0.7 MMTCE (1999) to 

0.46 MMTCE (2005). The data for following years are included in AnaFgas. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 182 

The shift of substances used for chamber cleaning from C2F6 to NF3 is likely to continue, thus 

increasing use and emissions of NF3. If the trends of 2003-2008 continue, the use of NF3 in 

the European semiconductor industry might double until 2030 to 600 t per year, while C2F6

use will decrease to the same extent. 

Emission projections from the highly dynamic photovoltaic industry are very difficult and 

uncertain. This is even more difficult with respect to the thin film silicon cell technology which 

is only one of several low-cost alternatives to crystalline cells. Crystalline cells, however, are 

more efficient and more expensive. As mentioned earlier, silicon-based thin film technology 

represents only 5% of the total worldwide and EU-wide production of solar cells (expressed 

in MW). Assuming that this share of 5% will be kept in the long-run and that grows rates of 

the overall solar cell production of the last decade remain stable during the next 20 years, the 

annual use of NF3 for chamber cleaning will probably increase to 300-400 t/y or even more. 

Like the used quantities, emissions could also increase tenfold by 2030, from today 10 kt 

CO2 eq to 100 kt CO2 eq. 

There is, however, another important uncertainty to be taken into account. Since 2009, in 1 

of the 6 German production plants for thin film silicon solar cells, NF3 has already been 

replaced by elemental fluorine. The highly reactive fluorine gas is produced on-site by 

electrolysis of hydrogen fluoride (HF) stored in tanks. The inventor of the cleaning system, 

which is already in use in a Korean LCD plant, claims elemental fluorine to be not only a 

climate-neutral but also a cost-effective solution in all solar cell plants of the common size 

(capacity >100 MW per year)272. The first plant for thin film silicon solar cells in Italy (which 

started the production in 2010) uses elemental fluorine for chamber cleaning from the very 

beginning. If elemental fluorine proves to be a technically feasible, cost effective and climate 

friendly solution, projected use and emissions of NF3 would need to be revised. 

The introduction of reporting requirements for NF3 under the F-gas Regulation is discussed in 

chapter 8. 

Use and emissions of SO2F2 (sulfuryl fluoride) 

SO2F2 is mainly used as structural fumigant in cereal grain mills and food processing 

facilities. Furthermore, it has been used for fumigation of timber, building and construction 

materials for quarantine pre-shipment purposes for several decades. The use of SO2F2 has 

gained importance in recent years since it is a substitute for methyl bromide in structural 

fumigations and in containers but not in soil fumigation. Methyl bromide is subject to phaseout under the Montreal Protocol273. 

 

272 For details see the mentioned Öko-Recherche study for the German UBA. In addition: 

Pro: S. Petri, P. Stockman, J.-C. Cigal, P. Szych, W. Beyer, Application of molecular fluorine to 

chamber cleaing for thin film silicon solar cell fabrication, 24th European Photovoltaic Solar Energy 

Conference, 21-25 September 2009, Hamburg, Germany. 

Schottler, Martin, Mariska de Wild-Scholten, Carbon footprint of PECVD chamber cleaning. 

Photovoltaics International journal’s second edition in November 2008. 

Contra: Safety and Environmental Considerations of NF3 and F2 Chamber Cleans for Thin Film Silicon 

Solar Cells. White Paper from Air Products and Chemicals, Inc., 2009. 

273 Concerning methyl bromide, the EU went beyond the requirements of the Montreal Protocol and 

established a full use ban since March 2010, except in an emergency to prevent the spread of pests or 

disease (the maximum period of use in such case is 120 days, the maximum quantity is 20 metric 

tonnes) (Commission Regulation (EC) No 1005/2009, Article 12). The use of methyl bromide as a 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 183 

In Europe, sulfuryl fluoride is sold under the trademarks of Vikane and Profume. The 

fumigation process usually takes several hours. The total quantities of sulfuryl fluoride used 

in EU-27 in recent years274 are displayed in table 5-14: 

Table 5-14: European use of SO2F2 (metric tonnes) 2006-2010 

Year 2006 2007 2008 2009 2010 

Quantity (t) 132 222 282 232 209

The decrease of quantities used after 2008 in EU-27 is estimated to be related to a change 

of behaviour and the search for other chemical and non-chemical alternatives to methyl 

bromide such as heat treatment and strict hygiene measures. While methyl bromide 

fumigation was done according to schedule, fumigation with SO2F2 is today carried out only 

when pest infestations have increase to specified levels. Furthermore, the application of 

SO2F2 is more restricted in terms of surveillance, monitoring, sealing and education of 

personnel. However, the impact of the methyl bromide phase out under the Montreal 

Protocol on the use of SO2F2 after 2010 remains to be investigated. 

The producer of SO2F2 has established a mandatory product stewardship programme for all 

users, which is based on a contract with the authorized fumigator. This programme includes 

trainings to promote safe use of the products and self-inspections.275 

Measurements of atmospheric concentrations in Europe indicated seasonal use of SO2F2 in 

Southern France, Germany, and Spain in summer in 2008, 2009 and 2010.276 This partly 

relates to the Member States which have authorized the use of Vikane and Profume: Austria, 

Belgium, France, Germany, Italy, Netherlands, Spain, Sweden, and United Kingdom. A 

mandatory monitoring programme of sulfuryl fluoride concentrations in the troposphere has 

been initiated (Commission Directive 2009/84/EC). 

Calculations of global warming emissions of SO2F2 are not possible at the moment since the 

GWP value is preliminary and emission factors are unknown. While the 4th IPCC Assessment 

Report does not indicate any GWP value for SO2F2, recent research calculated a direct GWP 

of 4,780 (Vassileios et al. 2008)277 but indicated high uncertainty of the atmospheric lifetime 

of SO2F2 of 36 +/- 11 years. Atmospheric loss processes of this gas are known and have 

been included in the calculations. Mühle et al (2009)278 estimate that about two thirds of the 

quantity of sulfuryl fluoride used reached the atmosphere and about one third was destroyed 

or removed possibly during the fumigation process. 

The Pesticides Directive (Commission Directive 2010/38/EC) requires the Member States to 

ensure that the producer of sulfuryl fluoride provides additional information on the 

 

biocide is banned in EU-27 since 1 September 2006 and the use as a plant protection product as well 

as for quarantine and pre-shipment applications is banned since 18 March 2010. 

274 Information provided by Dow Agro Sciences, February 2011. 275 Information provided by Dow Agro Sciences, February 2011. 276 EMPA Material Science and Technology 2010: Kontinuierliche Messung von halogenierten 

Treibhausgasen auf dem Jungfraujoch (HALCLIM-4); project with funding from the Swiss EPA 

(BAFU), pp.21; 38. First progress report, October 2010. 

277 Vassileios et al. 2008: Experimental and theoretical study of the atmospheric chemistry and global 

warming potential of SO2F2. Journal of Physical Chemistry 2008, 112, pp. 12657 – 12666. 278 Mühle, J. et al. 2009: Sulfuryl fluoride in the global atmosphere. Journal of Geophysical Research, 

2009, p. 114. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 184 

atmospheric lifetime and the GWP to be submitted to the Commission by 31 August 2012. 

However, it should be noted that this directive does not refer to biocide uses of SO2F2. 

In view of the measures in place and ongoing research, it can be concluded that 

- SO2F2 is currently covered by monitoring requirements under Directives 98/8/EC and 

2010/38/EC, which does not refer to biocide use. 

- Quantities of SO2F2 used in EU-27 are likely to remain stable, 

- Personnel applying SO2F2 is required to attend regular training. 

- The global warming potential of SO2F2 is not included in any IPCC report yet and loss 

processes have not been fully understood yet, which does not allow substantiated 

calculation of emissions. 

The potential inclusion of SO2F2 in the scope of the F-gas Regulation is considered in 

chapter 8. 

Unsaturated HFCs 

Development of unsaturated HFCs (partially fluorinated olefins) started some years ago 

when the climate impact of HFCs came into focus of the UNFCCC and its Kyoto Protocol. 

The best known unsaturated HFC is the hydrofluoroolefin 2,3,3,3,-tetrafluoroprop-1-ene 

(HFC-1234yf) which has been developed and proposed for use in mobile air conditioning in 

passenger cars as replacement for HFC-134a. 

Like all other HFCs, unsaturated HFCs are synthetic gases constituted of hydrogen, fluorine 

and carbon. However, they are part of a group that has carbon molecules linked with a 

double bond, which makes them olefins. The “o” for “olefins279” is used by the producers to 

distinguish this group from other HFCs. Two substances are increasingly discussed as 

alternatives to the previous generation of HFCs: HFC-1234yf (refrigerant) and HFC-1234ze 

(foam blowing agent, aerosol propellant, and refrigerant)280. Due to their low GWPs of 4 in 

the case of HFC-1234yf281 and 6 in the case of HFC-1234ze, significant emission reductions 

could be achieved through application of unsaturated HFCs in certain sectors as discussed 

in chapter 6. The GWPs of unsaturated HFCs are currently not included in IPCC reports. 

This new group of fluorinated refrigerants started to be commercialized in 2010. It should be 

noted that blends of saturated and unsaturated HFCs being developed for refrigeration and 

air conditioning applications are “preparations” in the sense of the F-gas Regulation and 

hence already considered within the scope of current provisions unless their GWP is <150. 

Furthermore, HFC-1234yf and HFC-1234ze are included in the scope of the two amendment 

proposals to the Montreal Protocol, the North American proposal and the proposal by the 

Federated States of Micronesia (chapter 7). The introduction of reporting requirements for 

these substances, in view of the international discussion related to the use of unsaturated 

HFCs is considered in chapter 8. 

 

279 “Olefin” is another, old term for unsaturated hydrocarbons. 280 In addition to HFC-1234ze [HBA-2], further unsaturated HFCs with GWP <15 are discussed by 

industry experts mostly for use as blowing agents (e. g HFC-1336mzz [FEA 1100], AFA L1). 

281 Nielsen, O.J. et al 2007: Atmospheric Chemistry of CF3CF=CH2: Kinetics and mechanisms of gasphase reactions with Cl atoms, OH radicals and O3.Chemical Physics Letters 439, pp 18-22. 
Chapter 5 Impact & cost-effectiveness of current F-gas policy framework 185 

Another class of fluorinated compounds that replace HFCs are fluorinated ketones. The most 

important species is FK-5-1-12 (3M Novec 1230) which has already been widely used as fire 

extinguishing agent in Europe and elsewhere. In addition, FK-5-1-12 is in use as a cover gas 

for magnesium casting as a replacement of SF6 outside of Europe. The application of this 

fluoro-ketone in the EU magnesium industry is a possible technical option for the coming 

years to substitute SF6 in sand casting and recycling of sand casting alloys, where the 

application temperature is higher than in common die casting. The GWP of FK-5-1-12 is not 

listed in the 4th IPCC Assessment Report but it is estimated at 1. 
Chapter 6 State of technology 186

6. State and potential of technology in the different sectors 

This chapter describes the technical feasibility and cost-effectiveness of the replacement of 

F-gases in sectors currently relying on HFCs and other F-gases. Differences between 

Europe and other parts of the world concerning the feasibility of particular replacement 

options are indicated for each sector. It should be noted that this analysis focuses on HFCs, 

which are the most important group of F-gases and where most of the replacement potential 

can be found. 

An introduction into underlying assumptions of the models used, differences between the 

models, and the methodology of these calculations are given in chapter 2. A description of 

the EU model AnaFgas is attached in annex III. 

Detailed information on the state and potential of technology for each sector included in this 

analysis is outlined in annex VI. All sector assumptions and calculations for the EU-27 under 

the WM scenario are included in the EU sector sheets in annex V. Assumptions for the global 

consumption scenarios are summarized in the data input sheet (DIS) for each sector in 

annex IV. 

This assessment of state and technology in each sector relying on F-gases provides 

important input for the development of policy options at international level to reduce F-gas 

emissions (chapter 7) and for further EU action to reduce F-gas emissions (chapter 8). 
Chapter 6 State of technology 187

6.1 State of technology and HFC use and emission trends 

6.1.1 Common technology by sectors

Common technology used in the different sectors and subsectors is listed in an overview 

table (table 6-1) and includes conventional F-gas technology and established alternative 

(halogen-free) technology. For detailed information on each sector please refer to annex VI. 

HCFC technology listed is today used for new products and equipment in developing 

countries and servicing of existing systems in developed countries. By quantity, the most 

important HCFC used today is HCFC-22 (GWP 1,810; ODP 0.05). HCFC technology still 

represents the state of technology of new and existing products and equipment in developing 

countries. In the USA, new HCFC equipment was sold widely until the end of 2010. In 

Europe, HCFC equipment is becoming more and more outdated technology but still exists to 

some extent. Only reclaimed HCFCs may be used for servicing needs of existing equipment 

and new virgin HCFCs must not be placed on the market any more (Regulation (EC) No 

1005/2009). 

HFC technology is widely applied in all refrigeration, air conditioning, foam, aerosol and fire 

protection sub sectors and can be considered state of technology in Europe and other 

developed countries. The most important HFCs used today include HFC-134a (GWP 1,430) 

and the blends R404A (GWP 3,922) and R410A (GWP 2,088).282 

Technologies not relying on HFCs, PFCs, or SF6 but on alternative substances with low 

GWP (thus called alternative technologies or low-GWP technologies here) are also common 

and widely used in some sectors and sub sectors such as domestic refrigeration, industrial 

refrigeration, certain sub sectors of commercial refrigeration and stationary air conditioning, 

foams, aerosols, solvents as well as the fire protection sector. 

SF6 (GWP 22,800) is used, amongst others, in electrical switchgear and non-ferrous metal 

industry. SF6-free alternatives are used to some extent for medium voltage switchgear. In the 

non-ferrous metal industry, which refers to the magnesium industry in EU-27, the use of SF6

has been banned in large die casting facilities (annual SF6 quantities used >850 kg) by the Fgas Regulation (Article 8). Small die casting facilities (annual SF6 quantities used <850 kg) 

today partly rely on SF6 but also introduced other technologies, such as the use of HFC-134a 

(GWP 1,430, which is considerably lower compared to the GWP of SF6) or SO2. 

 

282 If not otherwise stated, the GWP values in this report are from the 4th IPCC Assessment Report 

(2007). 
Chapter 6 State of technology 188

Table 6-1: State of technology in sectors relying on F-gases (excl. unsaturated HFCs) 

Sector Conventional F-gas technology Established alternative technology 

Domestic 

refrigeration 

- HFC-134a - HC-600a 

Commercial refrigeration 

Centralized systems - HCFC-22 

- R404A, R407C 

- HFC-134a 

- R744 in LT-cascade systems 

- R744 for MT and LT 

- R290, R1270 or R717 with secondary 

loop systems, sometimes R744 LTcascade systems 

Condensing units - HCFC-22 

- R404A, R410A 

- HFC-134a 

Stand alone units - CFC-12 

- HFC-134a 

- R404A 

- R744 for a ice cream freezers and 

beverage vending machines 

- HC (hydrocarbon, mainly R290, 

sometimes R600a) for bottle coolers 

and LT cabinets, etc. 

Industrial 

refrigeration 

- HCFC-22 

- R404A, R407C 

- ammonia (R717) 

- ammonia and CO2 cascade 

Transport refrigeration 

Reefer containers - HFC-134a 

- R404A 

Road refrigerated 

transport 

- HFC-134a 

- R404A, R410A, R407C 

Fishing vessels - HCFC-22 

- R404A 

- ammonia (R717) 

- ammonia and CO2 cascade 

Stationary AC - HCFC-22 

- R410A, R407C 

- HFC-134a (chillers) 

- R404A (chillers) 

- R290 (room AC, chillers, heat pumps) 

- R717 (large chillers) 

- R744 (heat pumps) 

Mobile AC

Road vehicles - HFC-134a 

- CFC-12 

- hydrocarbons (service only) 

(R744 in prototypes) 

Ships and rail - HFC-134a 

Foam - HFC-152a, HFC-134a 

- HFC-245fa 

- HFC-365mfc/227ea 

- HCFC-141b, HCFC-142b 

- HCFC-22 

- hydrocarbons (pentanes) 

- organic solvents/CO2 

- water-CO2

Fire protection - HFC-227ea 

- HFC-236fa 

- HFC-23 

- HFC-125 

- water, water mist, dry chemical, foam 

aerosols; 

- CO2

- inert gases 

Aerosols; OCF 

(excl. MDI) 

- HFC-152a 

- HFC-134a 

- hydrocarbons 

- dimethylether 

Medium voltage 

secondary 

switchgear 

- SF6 - solid insulation 

Non-ferrous metal 

industry 

(Mg industry) 

- SF6

- (HFC-134a) 

- SO2

- HFC-134a 

LT = Low Temperature; MT = Medium Temperature. 
Chapter 6 State of technology 189

6.1.2 Global BAU trend of HFC use until 2030 by sectors

Many sectors relying on HFC technology are likely to grow in the near future and hence 

consumption283 of HFCs is expected to increase. 

A business-as-usual (BAU) projection of global HFC consumption by sectors for the period 

2010-2030 has been calculated for both developed (A2) and developing countries (A5)284. 

Europe forms part of the group of developed countries. This scenario is based on current 

industry trends and considers the accelerated HCFC phase out under the Montreal Protocol 

in developing countries. It also integrates alternative technologies to the extent they likely 

replace conventional HFCs without additional policy measures285. 

Annual HFC consumption comprises HFC quantities used for the first fill of new equipment in 

the particular year and HFC quantities for servicing needs of existing equipment. Servicing 

quantities relate to use-phase emissions, which is losses through leakage and accidents 

(included in leakage rates). 

Table 6-2: HFC consumption (Mt CO2 eq) by sectors in A2 countries in the period until 2030 in a 

BAU scenario 

A2 countries 

(Mt CO2 eq) 2010 2015 2020 2030 

Domestic 

refrigeration 6 7 8 10 

Commercial 

refrigeration 108 121 125 110 

Industrial 

refrigeration 25 31 39 58 

Transport 

refrigeration 29 32 33 33 

Stationary AC 315 417 519 620 

Mobile AC 81 87 92 103 

Foam 37 48 56 75 

Aerosols 16 16 16 16 

Fire extinguishing 15 21 22 22 

Total 633 779 909 1,047

 

283 Under the Montreal Protocol "consumption" means production plus import minus export, minus 

destruction and minus feedstock of controlled substances. It represents the total annual supply of bulk 

substances for emissive uses in a country or world region (see chapter 2.2.4). In this chapter 

"consumption" means the annual F-gas flow into the particular application sectors A5 or A2 countries 

including EU-27. In quantitative terms, the consumption considered herein is considered equal to the 

demand (D) of these sectors for first fill and refill, not accounting for recycling or reclamation of used 

HFCs for re-use in new or existing equipment. For the EU-27, the term “demand” is used in its second 

extension (Demand ext2 ) which includes the F-gas quantities in imported pre-filled equipment which 

are refilled domestically, and the first fill into systems manufactured for export to third countries, which 

are not re-filled domestically. According to chapter 2.2.4, the equation for the 2nd extension of demand 

for HFCs is: Demand ext2 = First fill of systems for domestic use + First fill of systems imported in the EU + 

First fill of systems pre-charged for export from the EU + Refill of systems for domestic use + Refill of 

imported pre-charged systems. In EU-27, first fill of HFCs in systems for export takes place in mobile 

air conditioning of motor vehicles, in addition to OCF cans and medical aerosols, the latter not being 

refilled. 

284 Developed countries are called A2 countries in this report based on the terminology of the Montreal 

Protocol. Developing countries are called A5 countries accordingly. For more details about the 

definitions see chapter 2.2.3 (FN 9). 

285 The EU MAC Directive, which leads to alternatives to conventional HFCs, is an existing political 

measure and therefore included in the BAU scenario for the A2 countries. 
Chapter 6 State of technology 190

The assumptions made for each sector concerning leakage rates, sectoral growth rates and 

replacement patterns during HCFC phase-out are described in detail in annex VI as well as 

annex IV (DIS). 

HFC consumption trends in each sector are shown separately for A2 countries and A5 

countries (tables 6-2 and 6-3). Since this chapter focuses on HFCs, HCFC use trends are not 

shown in the tables but are included in the graphs 6-1 and 6-2. 

In developed countries (A2) HFC consumption is projected to increase to nearly 1.1 GT CO2

eq in total in 2030 in this BAU scenario. HFC demand by the stationary AC sector is growing 

at high rates and is projected to almost double (from 315 MT CO2 eq in 2010 to 620 MT CO2

eq in 2030). 

In developing countries (A5) HFC consumption is projected to reach 2.6 GT CO2 eq in 2030. 

Largest quantities are used in the stationary AC sector, industrial refrigeration, transport 

refrigeration as well as the mobile AC sector. 

Table 6-3: HFC consumption (Mt CO2 eq) by sectors in A5 countries until 2030 (BAU scenario) 

A5 countries 

(Mt CO2 eq) 2010 2015 2020 2030 

Domestic 

refrigeration 12 14 18 24 

Commercial 

refrigeration 8 34 78 171 

Industrial 

refrigeration 12 90 226 529 

Transport 

refrigeration 28 66 127 270 

Stationary AC 30 203 510 1,190 

Mobile AC 62 86 118 224 

Foam 1 19 87 142 

Aerosols 7 7 8 9 

Fire extinguishing 3 5 7 12 

Total 163 524 1,179 2,570

Sectors for which particularly strong increase of HFC consumption is projected include the 

stationary AC and heat pump sector (51% of HFC demand in A5 countries and 59% in A2 

countries in 2030; figure 6-1) and the industrial refrigeration sector (23% of HFC demand in 

A5 countries and 5.5% in A2 countries in 2030; figure 6-2). 
Chapter 6 State of technology 191

Figure 6-1: HFC and HCFC consumption in the stationary AC sector in A2 and A5 countries in 

the period until 2030. 

Figure 6-2: HFC and HCFC consumption in the industrial refrigeration sector in A2 and A5 

countries in the period until 2030. 
Chapter 6 State of technology 192

6.1.3 HFC demand and emissions in EU-27 until 2050 (WM scenario)

Projected F-gas emissions in EU-27 in a WM scenario including the measures set out by the 

F-gas Regulation and the MAC Directive are presented in chapter 5. The main results about 

emissions are repeated here in tabular and graphical form. Data on underlying demand are 

added. 

F-gas demand and emissions in EU-27 are projected to remain at stable levels from about 

2010 onwards (tables 6-4 and 6-5, bottom line “Total”). As already mentioned the term 

“demand” is used in its second extension which includes quantities in imported pre-filled 

equipment and quantities first filled into equipment manufactured for export286. It should be 

noted that, although the demand considered here includes first fill in exported pre-charged 

equipment, the calculation of emissions does not include exported pre-charged equipment 

because pre-charged F-gases emit outside the EU. 

Table 6-4: F-gas demand by sectors in EU-27 as projected in the WM scenario (AnaFgas), 

including imported pre-filled equipment and pre-filled systems for export (demand ext2) 

F-gas demand 

(kt CO2 eq) 2010 2015 2020 2030 2050 

Refrigeration 60,557 49,748 51,919 55,265 57,264 

Stationary AC 40,665 52,485 61,373 72,710 74,243 

Mobile AC motor veh. 39,287 31,705 20,373 10,117 10,130 

Mobile AC ships+rail 2,266 1,888 1,934 1,942 1,987 

Foam 10,935 10,810 10,781 10,810 10,828 

Other 18,684 19,433 21,205 19,545 20,035 

- thereof MDI 7,670 8,167 8,225 8,471 8,961 

Total HFCs 172,395 166,070 167,586 170,389 174,444 

Total HFCs w/o mobile 

AC motor vehicles 133,108 134,365 147,213 160,272 164,314 

SF6 48,209 47,698 46,322 46,298 46,358 

PFCs 1,844 1,844 1,844 1,844 1,844 

Total 222,449 215,612 215,751 218,529 222,690

F-gas demand is projected to stabilise around 220 Mt CO2 eq in the 2010–2050 period. The 

constancy is the result of an absolute decrease in HFC demand caused by the MAC 

Directive by 29 Mt CO2 eq in 2010 to 10 Mt CO2 eq in 2050 (row “Mobile AC motor vehicles) 

HFCs”) and by reduced demand per systems in sectors addressed by the containment 

measures of the F-gas Regulation . The reduction in HFC demand is counterbalanced from 

2015 onwards by the increase of HFC demand by 30 Mt CO2 eq in sectors other than motor 

vehicles, due to growing use (“Total HFCs w/o mobile AC motor vehicles”), in particular in 

stationary air conditioning which also includes imported pre-charged equipment like 

moveable and split systems. 

Table 6-5 shows, over the 2010-2050 time period emissions follow the same trend as the 

demand. In spite of the containment measures of the existing F-gas Regulation (see chapter 

5.2) emissions from stationary air conditioning strongly increase by 25 Mt CO2 eq until 2050. 

 

286 Demand ext2 = First fill of systems for domestic use + First fill of systems imported in the EU + First fill of 

systems pre-charged for export from the EU + Refill of systems for domestic use + Refill of imported precharged systems. 
Chapter 6 State of technology 193

In addition, from 2015 to 2050 emissions from the refrigeration sector increase by 5 Mt CO2

eq. As a result, the reduction in emissions from air conditioning of motor vehicles by almost 

30 Mt CO2 eq. is offset by 2050. 

Table 6-5: F-gas emissions by sectors in EU-27 as projected in the WM scenario (AnaFgas) 

F-gas emissions 

(kt CO2 eq) 2010 2015 2020 2030 2050 

Refrigeration 39,347 32,093 34,363 35,556 37,277 

Stationary AC 15,058 20,641 28,206 36,992 40,971 

Mobile AC motor veh. 32,526 34,819 28,293 6,604 6,889 

Mobile AC ships+rail 1,999 1,789 1,812 1,822 1,846 

Foam 3,299 3,631 3,974 4,634 5,746 

Other 9,155 9,503 9,893 10,143 10,576 

- thereof MDI 2,921 3,065 3,202 3,453 3,886 

Total HFC 101,384 102,476 106,541 95,750 103,306 

Total HFCs w/o mobile 

AC motor vehicles 68,858 67,657 78,248 89,146 101,460 

SF6 5,452 5,583 6,966 2,921 2,533 

PFCs and haloproduction 6,417 5,607 4,982 4,986 4,985 

Total 113,253 113,666 118,489 103,657 110,824 

The effect of containment and recovery measures set out by the F-gas Regulation is 

expected to occur in the period until 2015 if the provisions will be fully implemented and 

applied. 

The sector, where the effects of containment and recovery measures are more significant is 

commercial refrigeration (figure 6-3). 

hŽŵŵĞƌĐŝĂůZĞĨƌŝŐĞƌĂƚŝŽŶ

Ϭ

ρ͕ϬϬϬ

ϭϬ͕ϬϬϬ

ϭρ͕ϬϬϬ

ϮϬ͕ϬϬϬ

Ϯρ͕ϬϬϬ

ϯϬ͕ϬϬϬ

ϯρ͕ϬϬϬ

κϬ͕ϬϬϬ

ϮϬϭϬ ϮϬϭρ ϮϬϮϬ ϮϬϮρ ϮϬϯϬ ϮϬϯρ ϮϬκϬ ϮϬκρ ϮϬρϬ

ŬƚKϮĞƋ

ŵŝƐƐŝŽŶƐ ĞŵĂŶĚ

Figure 6-3: Projected HFC emissions and demand (kt CO2 eq) in commercial refrigeration 

(2010-2050), for EU-27 under WM scenario. After reductions in 2010-2015 due to F-gas 

Regulation, constant long term levels for emissions and demand are projected. 
Chapter 6 State of technology 194

In the stationary AC and heat pump sector, where containment provisions apply to certain 

equipment with charges >3 kg, the effects of these measures are offset by the growth of the 

sub sectors with equipment of charges <3 kg and which are not subject to Article 3 (figure 6-

4). 

h^ƚĂƚŝŽŶĂƌLJн,ĞĂƚWƵŵƉƐ

Ϭ

ϭϬ͕ϬϬϬ

ϮϬ͕ϬϬϬ

ϯϬ͕ϬϬϬ

κϬ͕ϬϬϬ

ρϬ͕ϬϬϬ

ςϬ͕ϬϬϬ

ϳϬ͕ϬϬϬ

ΘϬ͕ϬϬϬ

ϮϬϭϬ ϮϬϭρ ϮϬϮϬ ϮϬϮρ ϮϬϯϬ ϮϬϯρ ϮϬκϬ ϮϬκρ ϮϬρϬ

ŬƚK ϮĞƋ

ŵŝƐƐŝŽŶƐ ĞŵĂŶĚ

Figure 6-4: Trend of HFC demand and emissions under the European WM scenario in 

stationary air conditioning and heat pumps. Before in 2035 the market is saturated, 

considerable growth is expected, which makes stationary air conditioning the largest 

individual HFC sector in Europe. In this graph, demand includes imported HFCs in pre-filled 

systems. 
Chapter 6 State of technology 195

6.2 The market potential of abatement technology 

6.2.1 Selection of sector abatement options

For each sector today relying on HFCs or HCFCs (in A5 countries), cost-effective and 

technically feasible abatement solutions were identified and qualitatively and quantitatively 

compared to the sector-typical conventional HFC technology as reference. 

This comparative analysis was guided by the following main criteria: 

- Safety 

- Energy consumption. 

- Maximum reduction potential of CO2-weighted HFC use and emissions. 

- Cost effectiveness (expressed in abatement cost of €/t CO2 eq). 

Energy consumption is an essential selection criterion. After the preliminary identification of 

alternative options only those options that show at least equivalent energy performance as 

the reference HFC technology are considered further. This criterion is important because 

additional energy consumption would negatively impact the total climate performance of a 

system (TEWI) up to the point where reductions of direct F-gas emissions by replacement of 

HFCs could be offset by additional CO2 emissions from energy production (indirect 

emissions). 

In several cases a standard abatement solution might not be able to achieve the same or 

better energy performance as the reference option in any climatic region due to low 

thermodynamic performance. This applies e.g. to indirect refrigeration or air conditioning 

systems even if they use efficient refrigerants such as propane (R-290) or unsaturated HFCs 

(HFC-1234yf). In some of those cases, the energy consumption of direct HFC systems can 

be matched with the indirect use of gases if additional technical measures (e.g. larger heat 

exchanger surface) are implemented. Such technical optimisation increases, however, the 

investment cost of the abatement option. In the foam sector poorer insulation performance of 

alternative blowing agents must be compensated by increased foam thickness, which 

likewise raises the cost compared to HFC based technology. In those cases an abatement 

option is considered in the analysis but with the additional investment costs accounted. 

Therefore, the comparative analyses include only abatement options when these can, with or 

without technical optimisation, require equal or less energy for operation. 

6.2.2 The concept of penetration rates

Existing and future market penetration is a key parameter for the calculation of the 

consumption and emission reduction potential of any technical alternative to current HFC 

technology. 

Penetration rates 

The penetration rate is defined as the maximum market potential of a technical choice (i.e. 

abatement option) to replace new products or equipment relying upon HFCs in a particular 

sector. Penetration rates are given for each abatement option based on technical feasibility 

to replace existing HFC technology by a specific alternative technology. A penetration rate of 
Chapter 6 State of technology 196

30% in 2015 means that 30% of the new HFC units installed in 2015 could potentially be 

replaced by units of this particular abatement option. 

However, any abatement option is rarely universally applicable to a sector. Thus, maximum 

market penetration for replacement of current HFC technology in a specific sector in 2015, 

2020, 2025 or 2030 can only be met by aggregation of two or more abatement options. 

Constraints to market penetration 

Limitations of each abatement option are due to safety, cost and/or efficiency implications, 

and further parameters. It is therefore necessary to consider the use of each relevant 

abatement option for a specific sector within the context of the various limiting factors. 

• Safety constraints 

The application of refrigerants287 is generally controlled by national regulations, such as 

those dealing with the use of hazardous substances, buildings and so on. Generally such 

regulations are non-specific in terms of how refrigerants can be applied and aim at towards 

“safe use”. However, in many countries, safety standards and codes of practice are available 

which are more specific in the manner by which refrigerants are applied; noting also that 

such standards and codes are not normally legally mandatory but are considered as “best 

practice”. 

Many of the currently used F-Gas refrigerants have a safety classification of lower-toxicity/no 

flame propagation (i.e., class “A1”). This means that they can be applied within most 

situations without consideration of quantity limitations. However, many abatement solutions 

are flammable or have higher toxicity or both (typically “A2”, “A3” and “B2” classifications), 

which results in limitations in terms of the quantity of refrigerant permitted within different 

locations. As such, where standards specifically limit certain technical abatement options in 

particular locations, this can impact on the penetration rate. 

As an example, R717 (class B2) is not permitted to be used in direct systems, so the 

maximum penetration for room air conditioners would be 0%, whilst R290 (class A3) can be 

used in direct systems provided the charge size is below a certain quantity. Thus, the 

penetration would be more than 0% but less than 100% because it would not ordinarily be 

possible to use R290 in systems that require a large charge. 

Whilst safety standards may partially or wholly restrict certain abatement options from being 

used in certain locations, it is possible to redesign systems in order to ensure the refrigerant 

is kept within an alternative location or reduce the quantity of refrigerant in a system. This 

may be applicable where two refrigerant circuits are used instead of one, or an indirect 

system is employed instead of a direct system. 

• Efficiency constraints 

As mentioned previously, it is a basic principle in this study that any abatement option 

considered does not risk offsetting refrigerant-related emissions reduction by consuming 

more energy. Furthermore, this principle is in line with the fact that in many countries, there 

are – or will be – minimum efficiency standards for e.g. room air conditioning systems. 

 

287 Penetration rates are assessed not only for refrigerant using systems but also for fire protection 

equipment, foams, and aerosols. Refrigerants, however, are by far the largest application of HFCs. 
Chapter 6 State of technology 197

Therefore abatement options can only be considered where systems would achieve at least 

the same level of efficiency. In general, most of the abatement options under consideration 

can already provide at least the same level of efficiency as the existing refrigerants. 

In cases, where abatement options have a poorer efficiency than the existing HFC 

technology when used in comparable systems, additional materials and components may be 

required to bring the efficiency up to the required level, and these may incur costs. In 

particular, where indirect systems are used instead of direct systems and the construction is 

such that efficiency may be lost, increases in exchanger surface areas, for example, may be 

necessary to achieve the target level. 

However, in some cases abatement options may not be able to achieve the required 

efficiency level (even with optimization), in which case the penetration rate would be limited. 

As an example, the abatement option transcritical use of CO2 (which is more energy efficient 

than most HFC systems in geographical zones with moderate climate could be used in air 

conditioning systems within temperate climates. The penetration could reach 100% there, but 

in hot climates the ideal cycle efficiency of CO2 (R744) would still be below the minimum 

efficiency of such air conditioners and therefore the penetration would be 0%. In our analysis 

the penetration rate would be reduced according to share of moderate and hot climates. As 

an example, for Europe the penetration rate would be halved compared to the technical 

maximum because CO2 systems are energetically superior north of the Alps but inferior 

south of the Alps. 

• Cost constraints 

In principle any technically feasible abatement option can be used for any application, 

provided unlimited funds are available to implement it. However, the market may not accept 

products at considerably higher cost (price) than existing products. The cost implication of 

using different abatement options which may be affected by several different parameters, 

including safety requirements, desired efficiency, system complexity and special materials. 

Therefore it is important to establish situations where abatement options may result in 

excessively high cost such that the penetration potential of that abatement options would be 

limited. 

• Availability of materials and components 

Some parts are specific to certain refrigerants, e.g. compressors. Whilst it is feasible to use, 

e.g. R744/CO2 in rooftop air conditioners, no suitable compressors are currently available. 

Reciprocating compressors normally used for commercial refrigeration could be applied but 

the efficiency would be much lower than the equivalent (scroll) compressors that an R22 

system may use. Another example is electrical components for flammable refrigerant 

systems. HC chillers need to use “protected” electrical devices to avoid ignition of a leak but 

certain components e.g. low flow switches are not available, except for maybe oil rig 

applications which would lead to overly high costs for use in refrigeration and AC 

applications. Today not every system could be build with each of the abatement options 

using “off the shelf” parts and the systems would need to be improvised, which could lead to 

high costs and/or low efficiency. 
Chapter 6 State of technology 198

• Availability of refrigerants and blowing agents 

Whilst hydrocarbons, CO2, ammonia or water are available in sufficient quantities, new 

developed unsaturated HFCs are not yet commercially available of the necessary scale 

today. However, these gases show promising prospects for replacement of conventional 

HFCs and hence unsaturated HFCs are included in the comparative analyses in this study 

wherever possible. 

This applies particularly to HFC-1234yf (refrigerant) and, to minor extent, HFC-1234ze288

(foam blowing agent, aerosol propellant, refrigerant). The penetration rates of HFC-1234yf 

will still be low by 2015, which is the first year for which production at large scale is 

announced. As the market availability can be assumed to develop over time, the accurate 

quantitative assessment of the penetration rates is key condition for the estimation of the 

HFC reduction potential in the period until 2030. 

• System complexity and design know-how 

Systems running on ODS, HFCs and HFC blends are of similar complexity and design. In 

contrast, design and construction of a refrigeration or air conditioning system running on 

flammable refrigerants or transcritical CO2 systems require additional knowledge and 

training. Therefore, design engineers and technicians need to acquire additional know-how in 

order to install abatement technology properly. 

6.2.3 Determination of penetration rates

In estimating the maximum potential penetration rate, several factors are considered. For 

each of the constraints considered above, the proportion ( ʖ ) for each constraint (ŝ ) – in 

terms of refrigerant quantity, not necessarily number of systems – of the sector that could not 

accommodate the specific abatement option due to each is estimated. 

These factors are estimated for the year 2030, which should therefore account for both (i) 

anticipated technical developments and (ii) market maturity. For example, where charge size 

limits are a limiting factor, it can be assumed that research and development efforts over the 

next 20 years will reduce specific charge sizes (kg/kW) to below today's lowest values, or 

that system components for certain abatement options are widely available such that the 

product development and small production scale costs have been eliminated from the 

purchase price. 

Thus, the overall maximum penetration rate is estimated from 1 – max{ ŝ ʖ }. 

i.e., the maximum possible penetration under business-as-usual should be based on the 

maximum proportion of a sector unable to accommodate the abatement option for any of the 

given constraints. For each abatement option the proportions ( ʖ ) are based on expert 

knowledge of the characteristics of the systems and equipment, system design 

characteristics, requirements of safety standards, technology requirements, etc. and coupling 

these with characteristics of the refrigerants under consideration. 

 

288 Honeywell, the manufacturer of HFC-1234ze, stated that in 2011 HFC-1234ze was “commercially 

available”. It should be noted that by May 2011 this unsaturated HFC was produced at a “small-scale 

production facility”. In May 2011 the company announced to triple the capacities (Honeywell News 

Release, May 12, 2011). 
Chapter 6 State of technology 199

Whilst the constraints detailed above are mechanistic, another constraint may be included to 

account for the “willingness” of the market to adopt a given abatement option, which may be 

a function of the additional considerations necessary to suitably apply a particular abatement 

option. These considerations may include having to get special training for technicians, 

interpretation of complicated standards and so on. Using this approach the maximum 

penetration rate could be scaled down. 

Whilst the maximum penetration rate detailed above represents the best estimate for 2030, 

the penetration rates for the intermediate dates – 2015, 2020 and 2025 – are obtained from 

interpolation between the current status (i.e., penetration of each abatement option in 2010) 

and the 2030 penetration, but also accounting for the typical lifetime of the equipment within 

the sub sector. 

It must be noted here that there is no generally accepted methodology for the determination 

of penetration rates, and that the rates are subjective and with uncertainties. Evidently, 

nobody can exactly forecast and quantify the technical development in the coming 20 years. 

The penetration rates for the numerous individual technical solutions rely on the best 

knowledge of the project experts. The assessment is inter alia a result of detailed literature 

study, and of intensive discussion with the industries concerned289. 

6.2.4 Combination of penetration rates (“penetration mix”) 

It should be pointed out that in reality a sector may comprise a number of different abatement 

options. However, the mix of different technical solutions cannot necessarily be represented 

by the maximum penetration values for each abatement option since the same constraints 

that apply to one abatement option may apply to another (for example, flammability, etc). 

Therefore the maximum penetration rate of each abatement option for any one sector is the 

maximum penetration rate of any one of the abatement option within each of the groups 

listed in table 6-6 (refrigerants only). The groups represent the abatement option that are 

dominated by the same constraints and which are hence mutually exclusive. 

For example, the penetration rates of two flammable refrigerant abatement options in direct 

systems cannot be added since flammability is the same limiting factor. However, the 

penetration rates for Group 1/2 and Group 4 can be added since Group 4 abatement option 

could be applied where it would be impossible to use Group 1 or 2. 

 

289 For example see “Remark on the replacement potential of hydrocarbon refrigerants in split room air 

conditioners” following the Data Input Sheet “Stationary air conditioning – single split type” in annex IV 

which explains in detail the penetration rate assessment for room air conditioners with R-290. Room 

air conditioners with R-290 are the abatement technology with the highest individual HFC reduction 

potential in the study. It should be noted that the assumptions for the relevant variables of R-290 room 

air conditioners are in line with the draft Commission Regulation implementing Directive 2009/125/EC 

of the European Parliament and of the Council with regard to ecodesign requirements for air 

conditioners and comfort fans. 
Chapter 6 State of technology 200

Table 6-6: Classification of abatement options by limiting factors 

Group 1 

Highly flammable 

R600a 

R290/R1270 

Group 2 

Flammable 

Unsaturated HFC 

R717 

Group 3 

Moderate ambient only 

R744 

Group 4 

Indirect operation 

Highly efficient 

R290/R1270 + R744 cascade 

R717 + R744 cascade 

HC + evaporation secondary (e.g. R744) 

Unsaturated HFC+ evaporation secondary (e.g. R744) 

Group 5 

Indirect operation 

Normal efficiency 

HC + liquid secondary 

R717 + liquid secondary 

Unsaturated HFC+ liquid secondary 

Group 6 

Poor performance, high cost 

Air cycle 

Liquid absorption 

Solid adsorption 

In the survey of closed and open applications of HFCs underlying the following section on 

key abatement options, the penetration rates estimated for each individual replacement 

solution for 2015, 2020 and 2030 are presented. The aggregation of these individual 

penetration rates to complementary sector penetration rates follows the least-cost principle, 

which means that in case of equal reduction potential the most cost-effective abatement 

option comes first, the second after, and so on, until the technical maximum for the sector is 

reached. 

The cost of an abatement option is considered as the cost difference between the sectortypical HFC reference system, which is quantified and put in relation to the avoided HFC 

quantity of emissions or demand of this system. The result of the calculation is the specific 

annual abatement cost in €/t CO2 eq of an alternative option, as measure of its cost 

effectiveness. The calculation is shown for each abatement option in the Global Data Input 

sheets (annex IV) and, for Europe, in the EU sector sheets in annex V. 

The 2030 penetration mix for each application sector is shown in percentages, in tables at 

the end of each chapter, for A2 and A5 countries. For the EU the same penetrations mix as 

for the A2 countries is assumed, if not otherwise stated. Corresponding to the percentage of 

the individual abatement options in the 2030 penetration mix, the individual abatement cost 

are aggregated to average sector abatement cost, in €/t CO2 eq. 

The first objective for each sector is identification of those technically feasible alternative 

technologies that provide highest possible emission or demand reduction potential. The cost 

of these technologies is not the primary but the secondary selection criterion, which 

determines the order of different alternative options in the mix. From this it follows that 

abatement options relying upon low or no GWP technologies are preferred choice. However, 

solutions with GWP which are lower than the ones used today, such as blends of HFCs with 

unsaturated HFCs (GWP ~700) or substances like HFC-32 (GWP 675) are also considered 

for the assumed penetration mix, if such solutions, in a given year, are either the only 

alternative to high-GWP HFCs, or can further increase the reduction potential of low-GWP 

options. According to our analysis, only in few sectors (passenger ship air conditioning, room 
Chapter 6 State of technology 201

air conditioners <12 kW, and heat pumps290) inclusion of such solutions could increase the 

reduction potential of the low-GWP options to achieve highest possible reduction effect until 

2030. In all other sectors, the combination of low-GWP solutions alone represented the 

highest possible reduction potential. 

6.2.5 Difference between A2 countries and Europe 

Although the abatement options, their individual penetration rates, and sector penetration mix 

are the same for A2 countries and Europe (EU-27), which is part of the industrialized world, 

the marginal abatement cost per t CO2 eq differ mostly in the following sector presentations. 

This applies to all sectors with closed stationary systems like refrigeration, air conditioning, 

and fire protection. 

The main reason for the deviation is the different nature of the underlying baseline scenarios 

(see chapter 2) for A2 and Europe in this study. For A2 countries reference for the abatement 

option is the conventional HFC technology under business-as-usual, while for Europe the 

reference system is (in most cases) subject to the F-gas Regulation, which means a system 

“with measures” (WM). This system has higher service cost due to application of Articles 3 

and/or 4 and has at the same time lower emissions as a result of the measures of Articles 3 

and/or 4. Both cost difference and emissions difference to the reference systems are lower in 

Europe than in A2 countries. 

In some cases, the global warming emissions of the HFC reference systems in A2 countries 

differ from those of the EU reference systems. This is because in the global model for A2 

countries often a mix of HFCs with different GWP values is applied (e.g. R407C/410A) in 

order to account for the variety of similar refrigerants in the same application in different A2 

countries. In contrast, in the EU calculation model (see EU sector sheets in annex IV) mostly 

one HFC species (e.g. R410A), namely the “typical one”, forms the reference for abatement 

options, even though in reality further HFC species with different GWP are in use. 

 

290 In the sub sectors of room air conditioners <12 kW (movable and single split systems) the 

additional reduction effect from inclusion of HFC-32 lasts only until 2029 because in 2020 the 

penetration mix of low-GWP technologies has reached 100% (lifetime 10 years). 
Chapter 6 State of technology 202

6.2.6 Key abatement options by sectors

For each sector today relying on HFCs or HCFCs (in A5 countries), cost-effective and 

technically feasible abatement technology has been identified and compared to the sectortypical conventional HFC technology as reference (see chapter 6.1.1). Detailed information 

on each sector is given in annex VI. 

The different types of abatement technologies are partly based on alternative technology 

already common today (chapter 6.1.1) and partly on technology at least in prototype state, 

which is expected to be available at large scale in the near future. 

An aggregated market penetration potential, which includes for a sector the most effective 

abatement options which complement each other, with priority on more cost effective 

solutions in case of equal abatement potential, has been determined for A2 and A5 countries 

and is shown for 2030 in the following tables by sectors (“penetration mix”). 

Refrigeration and air conditioning sub sectors 

In most refrigeration sub sectors (table 6-7) the penetration mix of abatement options can 

reach 100% in or before 2030. Exemptions include the industrial refrigeration sector and 

refrigeration in fishing vessels. 

Table 6-7: Key abatement options in the refrigeration sectors and their aggregated market 

penetration potential in 2030 in A2 and A5 countries 

Market penetration of abatement 

options (penetration mix) in 2030 (%) 

Refrigeration 

and air conditioning 

Key 

abatement options 

A2 A5 

Domestic 

refrigeration 

R600a 

CO2 (R744) 

R1234yf 

95 (100*) 

5 

0 

95 

5 

0 

Commercial refrigeration 

Centralized systems R290 indirect + CO2 cascade 

R290 + CO2 + CO2 cascade 

CO2

90 

10 

0 

80 

15 

5 

Condensing units R290 direct 

R290 indirect 

CO2 

40 

30 

30 

60 

30 

10 

Stand-alone units R290 direct 

CO2 

85 

15 

85 

15 

Industrial refrigeration 

Small equipment NH3 95 80 

Large equipment NH3 95 80 

Transport refrigeration 

Refrigerated trucks R290 direct 

CO2 

80 

20 

80 

20 

Refrigerated vans CO2 

HFC-1234yf 

50 

50 

50 

50 

Reefer containers CO2 100 100 

Fishing vessels NH3 + CO2 cascade 95 95 

* For Europe 100% market potential of hydrocarbon refrigerant (R-600a) is assumed already for 2015. 
Chapter 6 State of technology 203

In many air conditioning sub sectors, the penetration mix of abatement options can reach 

100% in or before 2030 (table 6-8). 

Table 6-8: Key abatement options in the stationary and mobile air conditioning sectors and 

their combined market penetration potential in 2030 in A2 and A5 countries 

Market penetration of abatement options 

(penetration mix) in 2030 (%) 

Air conditioning Key 

abatement options 

A2 A5 

Stationary AC 

Moveable AC R290 direct 

CO2 

HFC-1234yf 

40 

20 

40 

50 

20 

30 

Single split AC R290 direct 

CO2 

HFC-1234yf 

40 

15 

45 

50 

10 

40 

Multi split AC R290 indirect 

CO2 

HFC-1234yf 

70 

30 

0 

70 

20 

10 

Rooftop AC R290 indirect 

CO2 

R290 + evaporating 

secondary (CO2) 

65 

35 

0 

80 

10 

10 

Small chillers R290 direct 

CO2 

NH3

60 

20 

20 

60 

20 

20 

Large chillers R290 direct 

CO2 

NH3 

R718 

15 

0 

60 

25 

15 

10 

60 

25 

Centrifugal chillers R290 

HFC-1234ze 

R718 

20 

50 

30 

20 

50 

30 

Heat pumps R290 direct 

CO2 

HFC-1234yf 

60 

20 

20 

60 

20 

20 

Mobile AC – road vehicles 

Passenger cars (incl. 

trucks) 

HFC-1234yf 

R744 

HC indirect 

(100) 

(100) 

0 

(60) 

(60) 

40 

Buses HFC-1234yf 

R744 

HC indirect 

100 

0 

0 

35 

15 

50 

Mobile AC – ships and rail vehicles291

Passenger ships Blends w unsat HFCs 90 

Cargo ships NH3-brine 

Blends w unsat HFCs 

90 

10 

Rail vehicles R744 60 

Not assessed 

 

291 Abatement options for ships and rail vehicles have been assessed for Europe only but not for the 

remaining A2 countries and for A5 countries, due to very limited data availability. 
Chapter 6 State of technology 204

Foam sub sectors 

In all foam subsectors (table 6-9), current HFC blowing agents could be substituted by 

abatement options in or before 2030. 

Table 6-9: Key abatement options in the foam subsectors and their combined market 

penetration potential in 2030 in A2 and A5 countries 

Market penetration of abatement options 

(penetration mix) in 2030 (%) 

Foam blowing agents Key 

abatement options 

A2 A5 

Insulation foams of PU and XPS for the construction sector 

Sandwich panels with 

metal facings, 

continuous (CME) 

HC 

Unsaturated HFC 

90 

10 

90 

10 

Sandwich panels with 

metal facings, 

discontinuous (DIP) 

HC 

Unsaturated HFC 

90 

10 

90 

10 

Sandwich panels with 

flexible facings, 

boardstock (CFF) 

HC 

Unsaturated HFC 

90 

10 

Spray foam (SPR) Unsaturated HFC 

H2O-CO2 

50 

50 

50 

50 

XPS Foam Boards 

(XPS) 

HC incl. organic 

solvent+CO2 

Unsaturated HFC 

85 

15 

85 

15 

PU Foam for refrigeration applications and integral skin

Domestic refrigeration 

(DOR) 

HC 100 100 

Commercial 

refrigeration (COR) 

HC 

Unsaturated HFC 

50 

50 

100 

0 

Refrigerated trucks, 

reefer containers 

(RTRU) 

HC 

Unsaturated HFC 

90 

10 

90 

10 

Integral foams (INT) H2O 

Unsaturated HFC 

50 

50 

100 

0 

Fire protection and technical aerosols 

Table 6-10 includes technical aerosols292 (excluding MDI293) and the fire protection sector. In 

fire protection, the key abatement option could fully substitute the use of HFC-23 (GWP 

14,800) as fire extinguishing agent in or before 2030. The use of HFC-227ea, in contrast, can 

be replaced in most but not all applications. 

 

292 There is currently no definition of technical aerosols in the legal text. FEA (Fédération Européenne 

des Aerosols) suggests the following definition: Technical aerosols are aerosol dispensers used in 

maintenance, repair, cleaning, testing, disinsecting, manufacturing, installation and other applications 

where a non-flammable formulation is required for safety reasons. (Communication to ÖkoRecherche, 15 May, 2011). This definition also separates novelty aerosols from “technical” aerosols. 

293 HFCs are used in Metered-Dose Inhalers for the treatment of asthma and other respiratory 

diseases. Health aspects related to the application of MDIs as compared to potential abatement 

technology need specific investigation. 
Chapter 6 State of technology 205

With regard to technical aerosols, it is estimated that the market penetration potential of 

unsaturated HFCs will cover 85%/95% of the applications. 

Table 6-10: Key abatement options in the aerosol and fire protection sectors and their market 

penetration potential in 2030 in A2 and A5 countries 

Market penetration of abatement options 

(penetration mix) in 2030 (%) 

Fire protection 

Technical aerosols 

Key 

abatement 

options A2 A5 

Fire protection 

Equipment with HFC-227ea FK 5-1-12 90 80 

Equipment with HFC-23 FK 5-1-12 100 100 

Technical aerosols Unsaturated HFCs 95 85 

Electrical switchgear and magnesium die casting 

For both sectors, the assessment of abatement options for the use of SF6 focused on 

Europe. Analyzes do not refer to A2 and A5 countries and the global situation. 

Table 6-11: Key abatement options in the electrical medium voltage secondary switchgear and 

magnesium casting sectors and their market penetration potential in EU-27 in 2030 

Other sectors Key 

abatement options 

Market penetration of 

abatement options 

(penetration mix) in 

2030 (%) 

Medium voltage secondary switchgear Solid insulation 40 

Magnesium die casting and recycling HFC-134a, SO2 100 

Since in magnesium die casting large facilities (SF6 use >850 kg/y) already were required to 

substitute the use of SF6, alternative options for small facilities are readily available and could 

reach full market penetration earlier than 2030. In the switchgear sector SF6 is currently the 

only technical solution for voltage >52 kV. Below 52 kV, in so called medium voltage, SF6 or 

air is used at the interface between high and medium voltage (primary level); at the interface 

between medium and low voltage (secondary level) SF6 clearly dominates the market (ca. 

98%) but solid insulation is technically possible today. 
Chapter 6 State of technology 206

6.3 Abatement costs and global HFC consumption reduction 

In the previous section, technically feasible replacements of conventional HFC technologies 

were presented for each sector and the optimum penetration mix for each sector was shown. 

In this section, the consumption reduction potential for 2030 (kt CO2 eq) and the abatement 

cost for 2030 (€/t CO2 eq) for each sector are summarized for both developed (A2) and 

developing countries (A5). This section only refers to HFCs. All sector specific abatement 

costs are based on the penetration rate mix in 2030, which aggregates abatement costs of 

individual options to sector values. 

6.3.1 Developed countries (A2)

Table 6-12: Consumption reduction potential (kt CO2 eq) per sector in developed (A2) countries 

in 2030 and abatement costs (€/t CO2 eq)* 

Sector Sub sector 

Consumption 

Abatement Cost 

(€/t CO2 eq) 

Pot. consumption 

Reduction 2030 

(kt CO2 eq) 

Domestic Refrigeration Refrigerators + Freezers 18.1 11,200 

Centralized systems -12.9 35,300 

Condensing units 1.4 71,400 

Commercial 

Refrigeration Stand-alone equipment -16.9 4,000 

Small industrial refrigeration 2.0 4,000 Industrial Refrigeration Large industrial refrigeration -6.0 73,800 

Transport Trucks and trailers -6.6 25,100 

Refrigeration Ships (Containers) 9.0 4,600 

Moveable type 8.4 13,200 

Split type 17.5 209,900 

Multi-spilt 46.3 149,200 

Ducted rooftop 47.7 50,400 

Chillers small 22.9 13,800 

Chillers large -42.0 64,400 

Centrifugal Chillers 16.2 9,300 

Stationary A/C 

Heat pumps (heating only) 64.2 17,800 

Passenger cars -3.0 73,200 Mobile A/C** 

Buses 29.0 2,300 

XPS 1.3 42,000 

Spray Foam 9.3 18,700 

Sandwich panels disc (DIP) 7.0 11,000 

Sandw. panels metal (CME) 4.9 6,500 

Sandw. flexible, boardstock (CFF) 1.4 1,300 

Domestic Ref. 8.0 10,800 

Commercial Ref. 17 4,400 

Refrigerated Trucks 5.9 1,700 

Foam 

Integral Foam 10.5 3,600 

Fire Protection Fire protection 3.8 21,900 

Aerosols Aerosols 9.5 16,300 

Total 1,016,200 

* Figures of A2 include Europe, but are not specific European values, see table 6-14. 

** Maritime and rail sectors are listed only for Europe and not for A2 and A5, due to lack of global data. 
Chapter 6 State of technology 207

In the business-as-usual scenario, the total HFC consumption in developed countries is 

projected to reach 1,395 Mt by 2030 (without MDIs). At this time, technically feasible 

abatement options can cover 1,016 Mt CO2 eq (= 73%). This is called the reduction potential 

(Table 6-12). 

Stationary air conditioning is the sector with the highest reduction potential. Single and multisplit air conditioners account for 24% and multi-split systems for 19% of the total. Other large 

sub sectors are passenger cars (9%), commercial condensing units (7%), and chillers (6%). 

75% of the overall reduction potential can be reached at abatement costs below €20. Some 

important sectors feature negative cost, amongst them chillers, refrigerated trucks, large 

industrial refrigeration plants, and passenger car air conditioning. 

There are 4 sub sectors with abatement cost >20 €/t CO2 eq including buses, multi split 

systems, ducted air conditioners, and heat pumps. 

Figure 6-5: Marginal Abatement Cost Curve for A2 countries in 2030. The red line on the right 

indicates total HFC consumption in A2 countries in 2030. 

Figure 6-5 illustrates that an HFC consumption reduction of approx. 760 Mt CO2 eq can be 

abated at costs <20 €/t CO2 eq. 
Chapter 6 State of technology 208

6.3.2 Developing countries (A5)

In the business-as-usual scenario, the total HFC consumption in developing countries is 

projected to reach 2,650 Mt by 2030 (without MDIs). At this time, the technically feasible 

reduction potential amounts to 2,490 Mt CO2 eq. (= 94%) (Table 6-13). 

Table 6-13: consumption reduction potential (kt CO2 eq) per sector in developing (A5) countries 

in 2030 and abatement costs (€/t CO2 eq) 

Sector Sub sector 

Consumption 

Abatement Cost 

(€/t CO2 eq) 

Potential 

consumption 

reduction 2030 

(kt CO2 eq) 

Domestic 

Refrigeration Refrigerators + Freezers 8.7 26,500 

Centralized systems -7.1 92,400 

Stand-alone equipment -40.8 25,500 

Commercial 

Refrigeration 

Condensing units -4.9 109,600 

Industrial Small industrial refrigeration 1.6 41,200 

Refrigeration Large industrial refrigeration -4.0 781,700 

Transport 

Refrigeration Trucks and trailers -39.1 310,000 

Moveable type 7.3 15,300 

Split type 9.3 657,900 

Multi-split 34.4 648,200 

Ducted rooftop 28.1 26,400 

Chillers small -2.0 18,300 

Chillers large -47.9 104,700 

Centrifugal Chillers 11.7 16,300 

Stationary A/C 

Heat pumps (heating only) 45.8 23,400 

Passenger cars 4.2 233,800 Mobile A/C* 

Buses 27.6 12,500 

XPS 8.1 16,800 

Spray Foam 5.0 48,500 

Sandw panels metal (DIP) 3.0 29,900 

Sandwich panels with metal facings, 

continuous (CME) 2.2 9,500 

Domestic Ref. 4.0 53,300 

Commercial Ref. 13.0 10,800 

Refrigerated Trucks 6.4 6,400 

Foam 

Integral Foam 10.0 6,300 

Fire Protection Fire protection 3.8 12,900 

Aerosols Aerosols 8.5 8,000 

Total 2,490,500 

* The maritime and rail sectors are analysed only for Europe and not for all A2 and for A5, due to lack 

of global data. 

Stationary air conditioning is also in developing countries the sector with the highest 

reduction potential. Single and multi-split air conditioners account for 22% and multi-split 

systems for 19% of the total. Other large sub sectors are large industrial refrigeration plants 

(18%), refrigerated trucks (11%), and passenger cars (7%). 
Chapter 6 State of technology 209

78% of the overall reduction potential can be reached at abatement costs <€20. Some 

important sectors like chillers, refrigerated trucks, or industrial refrigeration plans feature 

negative cost. 

The sub sectors with abatement cost >20 €/t CO2 eq are the same sectors as in A2 countries 

including buses, multi-split systems, ducted air conditioners, and heat pumps. 

Figure 6-6: Marginal Abatement Cost Curve for A5 countries in 2030. The red line on the right 

indicates total HFC consumption in A5 countries in 2030. 

Figure 6-6 illustrates that an HFC consumption reduction of almost 2,000 Mt CO2 eq can be 

abated at costs <20 €/t CO2 eq. 
Chapter 6 State of technology 210

6.4 Abatement cost, emission and demand reductions in EU-27 

In chapter 6.2, technically feasible and cost effective replacements of conventional HFC 

technologies were presented for each sector. In this section on abatement options in Europe, 

both demand294 reduction potential and emission295 reduction potentials for 2030 (kt CO2 eq) 

as well as the abatement cost for 2030 (€/t CO2 eq) for each sector are summarized. 

6.4.1 Demand reductions in EU-27 by 2030

It is important to know that in the given context demand in its 1st and 2nd extension includes 

not only those F-gas (HFC) quantities that are filled into new or existing equipment in one of 

the 27 Member States but also F-gas quantities that are imported in pre-filled equipment to 

one of the 27 Member States. Pre-filled equipment, in particular stationary split air 

conditioners contribute to EU emissions once they have been installed within the territory of 

the European Union. Therefore, demand for F-gases in the EU is bigger than sales of Fgases in bulk quantities to the EU market (chapter 2.2.4). 

In the WM scenario, the total HFC demand of the relevant sectors in Europe is projected to 

range at 160.3 Mt CO2 eq in 2030 (see table 6-4, HFCs without MAC of motor vehicles). By 

then, technically feasible abatement options for HFCs can cover 141.9 Mt CO2 eq (table 6-

14, HFCs total w/o motor vehicles). This is a reduction potential of 88.5%. 

By inclusion of mobile air conditioning of trucks and buses the 2030 demand for HFCs can 

be reduced by additional 5.7 Mt CO2 eq (table 6-14, MAC trucks and buses). 

In addition, SF6 demand of 3.3 Mt can be abated (table 6-14, SF6 application). 

The total F-gas demand reduction potential amounts to 150.9 Mt CO2 eq. 

Stationary air conditioning is the sector with the highest HFC reduction potential by far (72.1 

Mt CO2 eq; almost 50% of the 141.2 kt CO2 eq HFC demand reduction potential w/o motor 

vehicles, followed by commercial refrigeration (34.4 Mt CO2 eq; 24%). Single split systems 

represent the sub sector with the highest reduction potential in stationary air conditioning, 

and centralised supermarket systems show the highest reduction potential in commercial 

refrigeration. The abatement cost in the two large sectors are of similar size, with €10.9 in 

commercial refrigeration and 8.7 €/t CO2 eq in stationary air conditioning (if heat pumps are 

excluded). 

95% of the overall demand reduction potential of HFCs (without motor vehicles) can be 

reached at abatement cost <20 €/t CO2 eq, and 95.5% at abatement cost <50 €/t CO2 eq. 

Four sectors feature negative costs, amongst them the large sector of industrial refrigeration. 

There are four HFC sub sectors with abatement cost >16 €/t CO2 eq including passenger 

ships, refrigerated vans, heat pumps, and rail vehicles, in addition to the MAC sub sectors of 

buses and trucks, and the SF6 sub sector of MV secondary switch gear. 

 

294 Demand includes first fill in imported pre-charged systems and first fill in domestically manufactured 

systems for export to third countries (2nd extension of the term demand, see chapter 2.2.4). 295 Emissions are those which take place in the EU. i.e. although demand includes pre-charged 

exported equipment, emissions of those are not counted as EU emissions. 
Chapter 6 State of technology 211

Table 6-14: Demand abatement cost and reduction potential by alternative options in sectors 

and sub sectors relying on F-gases in EU-27 in 2030 

Sector Sub sector Abatement Cost 

(€/t CO2 eq) 

Potential Demand 

Reduction 2030 

(kt CO2 eq) 

Domestic Refrigeration Refrigerators/Freezers - 0 

Stand-alone systems -0.3 219 

Condensing units 0.7 8,949 

Commercial Refrigeration 

Centralized systems 14.6 25,214 

Small Industrial equipment -0.6 2,186 Industrial Refrigeration 

Large Industrial equipment -15.5 6,557 

Refrigerated Vans 37.2 516 

Refrigerated Trucks 2.0 4,325 

Transport Refrigeration 

Fishing vessels 3.2 539 

Rail vehicle AC 414.2 129 

Cargo ship AC 15.8 353 

Mobile Air Conditioning* 

Passenger ship AC 33.1 160 

Moveable systems 4.4 5,369 

Split systems 10.8 45,428 

Multi-split/VRF systems 7.0 6,426 

Rooftop systems 3.1 1,489 

Chillers (displacement) 2.2 6,851 

Centrifugal chillers 5.5 460 

Stationary 

Air Conditioning 

Heat Pumps 74.7 6,147 

Fire protection Fire protection 227ea 7.4 2,578 

Fire protection 23 1.0 2,946 

Aerosols Non-medical aerosols 10.0 3,637 

XPS-152a -1.6 460 

XPS-134a 0.3 4,092 

PU-Spray 10.0 4,801 

Foam 

PU other 0.2 2,058 

HFCs total w/o motor 

vehicles average 10.7 141,888 

Mobile Air Conditioning Trucks 37.2 4,017 

trucks and buses* Buses 42.7 1,694 

MAC 

trucks and buses average 38.8 5,711 

Total HFC sectors average 11.7 147,599 

Selected SF6 Magnesium casting 0.4 250 application 

sectors MV secondary switchgear 33.9 3,103 

SF6 application average 31.4 3,353 

 

Total average 12.2 150,952 

* Passenger cars are not included in the table because the abatement technology is already part of 

the WM scenario (MAC Directive). 
Chapter 6 State of technology 212

EU-27 MACC demand reduction vs. WM scenario 2030

-50

0

50

100

150

0 40,000 80,000 120,000 160,000

ktCO2eq

€/ktCO 2eq

Figure 6-7: Marginal Abatement Cost Curve for F-gas demand reductions in EU-27 in 2030 in 28 

HFC sectors and two SF6 sub sectors. The HFC quantities include pre-filled imported 

equipment. 

Figure 6-7 illustrates that F-gas demand reductions of 135 Mt CO2 eq can be abated at costs 

<20 €/t CO2 eq in 23 of the analysed 28 HFC sub sectors (including trucks and buses) and 2 

SF6 using sub sectors in EU-27. 

6.4.2 Emission reductions in EU-27 by 2030

As stated, demand for F-gases includes new equipment, no matter if it is first filled within or 

outside the EU, plus refill in existing equipment within the EU to account for losses during 

use-phase. Emissions likewise include leakage in the use-phase, but do not account for first 

fill. Instead, emissions include emissions on disposal when old equipment is 

decommissioned. Values of emissions are lower than values of demand because end-of-life 

emissions from equipment are not as high as the first fill into the equipment, once there is 

some recovery. In addition, first fill exceeds the quantity for disposal as long as there is 

growth in the F-gas bank in the equipment stock. 

In the WM scenario, total F-gas emissions of the 26 analysed HFC sub sectors (without 

motor vehicles) in Europe are projected to range at 89.1 Mt by 2030 (table 6-5, total HFCs 

without motor vehicles). By then, technically feasible HFC abatement options can cover 69.6 

Mt CO2 eq or 78% (table 6-15). 

If mobile air conditioning of trucks and buses is included, the 2030 emissions of HFCs can be 

reduced by additional 5.8 Mt CO2 eq. (table 6-15, MAC trucks and buses) 

In addition, SF6 emissions of 0.3 Mt can be abated (table 6-15, SF6 application). 

The total F-gas emission reduction potential amounts to 75.8 Mt CO2 eq. by 2030. 
Chapter 6 State of technology 213

Stationary air conditioning (excluding heat pumps) is the sector with the highest reduction 

potential (32.1 Mt CO2 eq; 46%), followed by commercial refrigeration (18.8 Mt CO2 eq; 

27%). Single split systems represent the sub sector with the highest reduction potential in 

stationary AC, and centralised supermarket systems show the highest reduction potential in 

commercial refrigeration. The abatement costs in the two large sectors are in the same 

range, with €16.2 (stationary air conditioning w/o heat pumps) and 18.8 €/t CO2 eq 

(commercial refrigeration). 

Table 6-15: Emission abatement cost and reduction potential by alternative options in F-gas 

applying sectors and sub sectors of EU-27 in 2030 

Sector Sub sector Abatement Cost 

(€/t CO2 eq) 

Potential Emission 

Reduction 2030 

(kt CO2 eq) 

Domestic Refrigeration Refrigerators/Freezers 1.0 12 

Stand-alone systems -0.8 149 

Condensing units 1.2 3,927 

Commercial Refrigeration 

Centralized systems 23.7 14,471 

Small Industrial equipment -0.9 871 Industrial Refrigeration 

Large Industrial equipment -21.6 2,612 

Refrigerated Vans 45.1 421 

Refrigerated Trucks 2.6 2,990 

Transport Refrigeration 

Fishing vessels 3.4 405 

Rail vehicle AC 555.6 26 

Cargo ship AC 16.7 320 

Mobile Air Conditioning* 

Passenger ship AC 35.0 125 

Moveable systems 8.9 2,781 

Split systems 19.0 22,970 

Multi-split/VRF systems 13.1 2.827 

Rooftop systems 8.2 573 

Chillers (displacement) 5.9 2,512 

Centrifugal chillers 11.1 82 

Stat Air Conditioning 

Heat Pumps 130.2 2,282 

Fire protection Fire protection 227ea 22.3 440 

Fire protection 23 3.1 961 

Aerosols Aerosols 10.0 3,637 

XPS-152a -1.6 460 

XPS-134a 1.0 1,553 

PU-Spray 61.6 1,369 

Foam 

PU other 3.5 587 

HFCs total w/o motor 

vehicles average 18.7 69,633 

Mobile Air Conditioning Trucks 43.1 4,170 

trucks and buses* Buses 48.5 1,616 

MAC 

trucks and buses average 44.6 5,785 

Selected SF6 Magnesium casting 0.4 250 application 

sectors MV secondary switchgear 347.3 97 

SF6 application average 97.2 347 

 

Total average 21.0 75,765 

* Passenger cars are not included in the table because the abatement technology is already part of 

the WM scenario (MAC Directive). 
Chapter 6 State of technology 214

94% of the overall emission reduction potential of 69.6 Mt CO2 eq of HFCs without motor 

vehicles can be reached at abatement costs <25 €/t CO2 eq. Some important sectors feature 

negative cost, e.g. the industrial refrigeration sector. 

There are five HFC sub sectors with abatement cost >25 €/t CO2 eq: passenger ships, 

refrigerated vans, PU spray foam, heat pumps, and rail vehicles, in addition to the MAC sub 

sectors of buses and trucks, and the SF6 sub sector of MV secondary switch gear. The 

emission abatement cost for rail vehicles and MV switchgear are higher than 300 €/t CO2 eq. 

EU-27 MACC emission reduction vs. WM scenario 2030

-50

0

50

100

150

0 20,000 40,000 60,000 80,000

ktCO2eq

€ / tCO 2eq

Figure 6-8: Marginal Abatement Cost Curve for emission reductions in EU-27 in 2030 in 28 HFC 

sectors and two SF6 sub sectors. 

Figure 6-8 illustrates that HFC emission reduction of 65.7 Mt CO2 eq can be abated at costs 

<25 €/t CO2 eq in 22 of the analysed 28 HFC sub sectors and 2 SF6 using sub sectors in EU27. 
Chapter 7 Options for further international action 215

7. Options for further international action to reduce F-gas 

emissions 

7.1 Projection of global HFC consumption and the need for 

international action 

Growing consumption of HFCs and hence emissions are mainly driven by the phase out of 

ODS under the Montreal Protocol (chapter 3.1). The Montreal Protocol regime controls 

production and consumption of ODS but the choice of alternatives to ODS technology is not 

regulated. HFCs were developed as ozone-friendly substitutes for ODS in the early 1990s 

and their use has increased largely since. However, their significant global warming potential 

and related climate impact has caused global concerns. 

Figure 7-1 and table 7-1 show projections of global HCFC and HFC consumption in a 

business as usual scenario (BAU) in the period until 2030, as calculated by the global 

AnaFgas model on HFC consumption developed within this project (see chapter 2). In this 

chapter, the term consumption is used in its definition under the Montreal Protocol which 

follows the equation Consumption = Production + Imports – Exports – Destruction – 

Feedstock. It should, however, be kept in mind that the annual flow of substances in A2 and 

A5 countries has been calculated in this study on the basis of the demand for first and refill of 

substances in the individual application sectors (see chapter 2.2.4). 

As outlined earlier, developed countries are referred to as A2 countries based on the 

terminology of the Montreal Protocol. Developing countries are referred to as A5 countries 

accordingly.296 For simplification, it is assumed that the classification of countries into one 

group or the other remains constant over time although this might not reflect future reality. 

HFC consumption in A5 countries is projected to increase drastically in the next decades 

while HCFC consumption will decrease due to ODS phase out under the Montreal Protocol. 

HFC consumption in A2 countries is likely to reach stable levels around 2030. 

As highlighted in other reports, under a restricted Kyoto scenario with future control caps on 

total CO2 emissions in Non-Annex I countries, a partially uncontrolled consumption of 

HFCs297 and related emissions may lead to a significant share of HFC emissions. In 

unconstrained BAU scenarios, the share of HFCs of total GHG emissions ranges around 6% 

in certain projections (Gschrey et al. 2011298) and even at 9-19% in extreme projections 

(Velders et al 2009299). The share would be substantially higher in scenarios where CO2

emissions were restricted, but not the consumption of HFCs. 

 

296 Under the Montreal Protocol, the decision whether a particular country is considered A5 or Non-A5 

country depends on the annual per capita consumption of ODS. For details see footnote 10, chapter 2. 

297 HFCs are controlled substances under the national emission targets in Annex I countries. 

Therefore, they are limited by national preferences of Annex I in their efforts to constrain their overall 

greenhouse gas emissions. In Non-Annex I HFC could potentially grow unconstrained. Therefore, it is 

not correct to consider growth in Annex I as “uncontrolled”, even though tighter mechanisms to 

maintain and reduce HFCs will be economically essential to achieve national emission targets in most 

of the Annex I countries. 

298 Gschrey, B.; Schwarz, W.; Elsner, C.; Engelhardt, R. 2011: High increase of global F-gas 

emissions until 2050. Greenhouse Gas Measurement and Management 1, p.85-92. 

299 PNAS 2009, Schellnhuber, Velders, Molina et al.: Reducing abrupt climate change risk using the 

Montreal Protocol and other regulatory actions to complement cuts in CO2 emissions, p. 1-6. 
Chapter 7 Options for further international action 216

Figure 7-1 Consumption (demand) of HCFCs and HFCs in A2 and A5 countries projected in a 

business as usual scenario (BAU) in the period 2010-2030. 

Table 7-1: Consumption of HCFCs and HFCs in A2 and A5 countries projected in a business as 

usual scenario (BAU) in the period 2010-2030, in Mt CO2 eq 

Consumption A2 countries A5 countries World 

 Mt CO2 eq HFC HCFC HFC HCFC HFC HCFC 

2010 633 88 163 513 796 601 

2011 659 59 217 508 876 567 

2012 687 55 279 499 966 554 

2013 716 51 351 485 1,067 536 

2014 747 47 432 467 1,179 514 

2015 779 43 524 443 1,304 486 

2016 804 39 628 374 1,432 413 

2017 830 34 743 312 1,573 346 

2018 856 30 873 259 1,729 289 

2019 882 26 1,018 219 1,900 245 

2020 909 22 1,179 197 2,089 219 

2021 927 19 1,292 184 2,219 203 

2022 944 16 1,410 171 2,355 187 

2023 962 13 1,536 159 2,497 172 

2024 977 10 1,668 146 2,646 156 

2025 993 7 1,808 134 2,801 141 

2026 1,005 6 1,948 117 2,953 123 

2027 1,016 5 2,094 102 3,110 106 

2028 1,026 4 2,246 87 3,273 91 

2029 1,037 3 2,405 74 3,441 76 

 2030 1,047 1 2,570 62 3,616 63 
Chapter 7 Options for further international action 217

As outlined in chapter 3.1, F-gas markets are global markets. This means that HFC 

production often takes place in one country while HFC consumption and related emissions 

during and at the end of product life may take place in other countries. Local or regional 

policy action can hence only address the contribution of HFCs to global warming to minor 

extent, while international action can result in emission reductions at large scale. 

Current policy discussions at international level treat the question on how to link the work on 

F-gases, in particular HFCs, done under the climate regime (UNFCCC) and further phase out 

of ODS under the Montreal Protocol more closely. 

Activities under the UNFCCC and the Kyoto Protocol addressing HFC emissions have been 

described in chapter 3.2 and include monitoring and reporting requirements, reduction 

targets for emissions from all GHG and projects under the CDM and JI mechanisms (see 

chapter 3). So far, action under the climate regime has resulted in certain, but comparably 

small reductions of F-gas emissions. For example, cumulated emission reductions being 

achieved through CDM projects on F-gases in developing countries in the first commitment 

period (2008-2012) amount to <5 Gt CO2 eq in total, largely (>90%) resulting from HFC-23 

destruction projects. JI projects yield emission reductions of ca 12 Mt CO2 eq during the 

same period which are also caused by HFC-23 destruction to large extent. 

The Montreal Protocol holds a special role as it addresses most industries and sectors which 

rely on F-gases while not addressing these gases. It could be possible to abate HFC 

emissions at a global level in a similar way as ODS by applying the approach of the Montreal 

Protocol. 

Key advantages of the Montreal Protocol to control production and consumption of HFCs 

include the following aspects: 

- Reductions in the production and consumption of similar chemicals in developed and 

developing countries were achieved. 

- Experiences of funding the incremental cost of phasing out similar chemicals through the 

Multilateral Fund (MLF) for the implementation of the Montreal Protocol are available. 

- The technical bodies of the Montreal Protocol hold expertise on all sectors related to 

HFCs. 

This way forward is exactly suggested by two proposals for an amendment of the Montreal 

Protocol with regard to HFCs submitted in 2009-2010 and updated in 2011, one by the 

Federated States of Micronesia (FSM) and one by Northern American (NA) countries 

including the USA, Canada and Mexico. Both proposals suggest control of production and 

consumption of HFCs and are currently being discussed at international level. Detailed 

descriptions of the FSM and NA amendment proposals will be outlined in chapter 7.3. 

The next sections include general considerations for a framework on HFCs (chapter 7.2). 

Scenarios for the control of HFC production and consumption in line with the approach of the 

Montreal Protocol are presented and compared in chapter 7.3. The scenarios referred to in 

this comparison include scenarios according to the FSM and NA amendment proposals as 

well as two scenarios on global HFC consumption (see chapter 2.2) based on the 

assessment of HFC abatement technology by sectors (see chapter 6) undertaken within this 

project. 
Chapter 7 Options for further international action 218

7.2 Scenarios for the control of consumption and production of 

HFCs 

7.2.1 Presentation of the scenarios

The scenarios based on the amendment proposals to the Montreal Protocol (FSM, NA) 

suggest control steps for production and consumption of HFCs in both developed and 

developing countries. The phase down schedules applied in the FSM and NA proposals 

differ with regard to the control levels in developed and developing countries. The FSM 

scenario is more ambitious than the NA scenario with regard to A2 countries, while the NA 

scenario is stricter concerning phase down in A5 countries. 

The other two scenarios included in the comparison are based on the work undertaken within 

this project in terms of technical feasibility of HFC abatement technology (chapter 6). 

Replacement of current HFC technology in a particular sector by the abatement options 

assessed to the extent considered possible (indicated as penetration mix) results in 

reductions of HFC consumption in this sector. A combined analysis of potential reductions of 

HFC consumption in all sectors has lead to 2 scenarios: 

− A reduction scenario (RED) is based on all technically feasible abatement options 

identified for each sector at the maximum penetration rates in a particular year. 

− A reduction scenario which considers cost aspects (RED10) is based on technically 

feasible abatement options at abatement costs <10 €/t CO2 eq identified for each 

sector at the maximum penetration rates in a particular year. 

Figure 7-2 shows a comparison of the RED, RED 10 and the business as usual (BAU) 

scenario derived from the model on global HFC consumption developed within this project. In 

2030, global HFC consumption as compared to the BAU scenario (3,705 Mt CO2 eq) can be 

reduced by -3,523 Mt CO2 eq in the RED scenario and by -2,652 Mt CO2 eq in the RED10 

scenario. 
Chapter 7 Options for further international action 219

Figure 7-2: Scenarios calculated by the model on global HFC consumption include the 

business as usual (BAU) scenario, a reduction scenario (RED) taking into assuming application 

of all technically feasible abatement technology as assessed in chapter 6 and a reduction 

scenario (RED10) which only considers technically feasible abatement technology at costs of 

<10 €/t CO2 eq. 

The implementation of each HFC consumption reduction scenario (FSM, NA, RED, RED10) 

would lead to different implications for A2 and A5 countries, which are compared in the 

following sections. Since the end of the BAU projections (2030) lies right in the middle of the 

proposed phase-down scenarios, the BAU projections are extrapolated until 2050. For A2, 

the growth rates from 2020-2030 are further applied until 2050. This is justified because the 

consumption trend of A2 countries stabilizes at low growth rates between 2020 and 2030. In 

A5 countries, half of the growth rates from 2020-2030 are assumed for the period of 2030-

2050, because market saturation is approached but not yet reached. The further the 

projections reach into the future, the higher the associated uncertainties. 
Chapter 7 Options for further international action 220

7.2.2 Comparison of scenarios for A2 countries

A comparison of the four scenarios for A2 countries by technical elements is summarized in 

table 7-2. Baseline and reduction steps of the RED and RED10 scenario are adjusted to the 

calculated trends for introduction of abatement technology in these scenarios. 

The baseline ranges between 697 Mt CO2 eq (RED) and 732 Mt CO2 eq (NA), freeze levels 

start in 2014 or 2015 with a step between 85% and 90%. The intermediate control steps are 

adapted to the calculated regression of the scenarios. 

Final consumption tails range from 10% to 15% in the scenarios. The comparably late control 

steps of the RED10 scenario illustrate the increasing market penetration of alternative 

technologies at abatement costs below 10 €/t CO2 eq over time (as presented in chapter 6). 

Table 7-2: Comparison of the scenarios: Technical elements for A2 countries 

Summary 

A2 countries 

NA FSM RED RED10 

Proposed Baseline 

85% of HCFC 

plus HFC 

consumption 

Combined HCFC 

and HFC 

consumption 

25% of HCFC 

baseline plus 

HFC consumption 

25% of HCFC 

baseline plus 

HFC consumption 

Baseline years 2005-2008 2004-2006 2004-2006 2004-2006 

Year of 

first control level 2015 2014 2014 2014 

Proposed first control 

level (freeze level) 90% 85% 85% 85% 

Final phase down level 15% 10% 10% 10% 

Year of final step down 2033 2031 2028 2046 

Total baseline 

(Mt CO2 eq) 732 724 697 697 

2015 90% 2014 85% 2014 85% 2014 85% 

2017 80% 2017 70% 2016 70% 2018 70% 

2020 70% 2020 55% 2019 50% 2022 60% 

2025 50% 2023 45% 2022 30% 2026 50% 

2029 30% 2026 30% 2025 15% 2031 40% 

2033 15% 2029 15% 2028 10% 2036 30% 

 2031 10% 2041 20% 

Control schedule 

 

 

 

 

 

 

 2046 10% 

Figure 7-3 compares the regression trends of the individual phase-down scenarios for A2 

countries in the period until 2050 in order to better illustrate the differences. In 2030, the 

RED10 scenario still includes relatively high HFC consumption of around 300 Mt CO2 eq 

while the RED and FSM scenarios already (almost) reached their final control steps. 

In 2050, the highest tail consumption of >100 Mt CO2 eq is scheduled in the NA scenario. 

The FSM, RED and RED10 scenarios end at tail consumptions of around 80 Mt CO2 eq. 
Chapter 7 Options for further international action 221

Figure 7-3: Comparison of different HFC trend scenarios in A2 countries based on the analyzed 

scenarios. 

Figure 7-4 compares the phase-down steps for A2 countries in the different scenarios. In the 

early stages of phase down, FSM and RED scenario follow the same sequencing of steps. 

Figure 7-4: Comparison of phase down steps in A2 countries according to the compared 

scenarios. 
Chapter 7 Options for further international action 222

Figure 7-5 illustrates the relative differences of the scenarios for A2 countries regarding their 

aggregate reduction potential. The scenario with the lowest consumption reduction until 

2030, the RED10 scenario, was chosen as reference. The cummulated reduction is highly 

influenced by the early reduction steps. This is the main reason why NA shows a lower 

reduction potential than the other scenarios. As outlined above, the 2050 projections are to 

be considered highly uncertain. 

Figure 7-5: Accummulated consumption reductions (Mt CO2 eq) in A2 countries achieved in the 

NA, FSM and RED scenarios relative to the RED10 scenario. 
Chapter 7 Options for further international action 223

7.2.3 Comparison of scenarios for A5 countries

The comparison of the four scenarios for A5 countries is summarized in table 7-3. Baseline 

and reduction steps of the RED and RED10 scenario are adjusted to the calculated trends 

for introduction of abatement technologies (chapter 6). The definition of the RED 10 scenario, 

allowing only abatement options at or below 10 €/t CO2eq, results in only one reduction step 

to 85% of the baseline. Compared to the soaring BAU consumption, reductions are still 

significant, even though they will never reach the potential of any other scenario. 

The NA scenario includes a combined HCFC and HFC baseline, while an HCFC baseline is 

applied in the FSM, RED and RED10 scenarios. Freeze dates range between 2015 and 

2019. Early freeze dates will avoid uncontrolled growth of HFC consumption between 2010 

and the freeze. While freeze dates in the NA, FSM and RED10 scenario are set in 2017-

2019, an earlier control is established in the RED scenario. 

Finally, the consumption tail ranges from 10% (RED, FSM) to 15% (NA) and 85% (RED10). 

The intermediate control steps in RED allow A5 countries a longer period for the phase 

down. Final consumption tails range from 10% to 15% in the scenarios. The comparably late 

control steps of the RED10 scenario illustrate the increasing market penetration of alternative 

technologies at abatement costs <10 €/t CO2 eq over time (as presented in chapter 6). 

Abatement technologies at costs <10 €/t CO2 eq are available for most sectors except for 

e.g. refrigerated containers, air conditioning in buses, centralized commercial systems. 

Table 7-3: Summary of scenarios for A5 countries 

Summary 

A5 countries 

NA FSM RED RED 10 

Proposed Baseline HCFC 

consumption 

HCFC 

consumption 

HCFC 

consumption 

HCFC 

consumption 

Baseline years 2005-2008 2007-2009 2005-2007 2007-2009 

Year of first control level 2017 2020 2015 2019 

Proposed First Control 

level (Freeze level) 100% 85% 100% 100% 

Final phase down level 15% 10% 10% 85% 

Year of final step down 2043 2036 2040 2019 

Total baseline 

(Mt CO2 eq) 563 654 543 654 

2017 100% 2020 85% 2019 85% 2019 85% 

2021 80% 2023 70% 2022 72% 85% 

2025 70% 2026 55% 2025 60% 85% 

2029 50% 2029 45% 2028 50% 85% 

2035 30% 2032 30% 2031 40% 85% 

2043 15% 2035 15% 2034 30% 85% 

 2037 10% 2037 20% 85% 

Control schedule 

 

 

 

 

 

 

 2040 10% 2050 85% 

Figure 7-6 compares the regression trends of the individual phase-down scenarios for A5 

countries in the period until 2050. All scenarios appear to be quite close in early stages of the 

phase down schedules. Tail consumption in both 2030 and 2050 varies largely between the 

RED10 scenario and the group of NA, FSM and RED scenarios since the last control step of 

the RED10 scenario is reached at 560 Mt CO2 eq in 2019 already. 
Chapter 7 Options for further international action 224

Figure 7-6: Comparison of the A5 countries trend scenarios of proposed and alternative 

schedule. 

Figure 7-7: Comparison of A5 countries phase-down steps for NA, FSM and RED scenario. 
Chapter 7 Options for further international action 225

Figure 7-8: Accummulated consumption reductions (Mt CO2 eq) in A5 countries achieved in the 

NA, FSM and RED scenarios relative to the RED10 scenario. 

Figure 7-8 illustrates the relative differences of the scenarios for A5 countries regarding their 

reduction potential. The scenario with the lowest consumption reduction in 2030, the RED10 

scenario, was chosen as reference. As outlined above, the 2050 projections are to be 

considered highly uncertain. 
Chapter 7 Options for further international action 226

7.2.4 Comparison of HFC consumption reductions in the scenarios

The total accumulating consumption reduction versus the BAU scenario are compared for 

the RED10, NA, FSM, RED scenarios in table 7-4. 

The FSM scenario results in significantly higher consumption reductions in A2 countries than 

the NA proposal. RED has significant higher consumption reductions in the period until 2030 

in A2 countries as the other scenarios. Global emission reductions would be 24% higher in 

the RED scenario compared to RED10. 

In the time frame until 2030, cumulative consumption reductions range between 22.9 and 

28.3 Gt CO2 eq. The difference of the regressions of each of the scenarios in comparison to 

the unconstrained BAU scenario appears almost insignificant. However, the BAU scenario 

for the year 2030 is the worst case scenario, assuming that almost no transition to HFC-free 

technologies has taken place. 

The relative difference between the most and the least environmentally ambitious scenarios 

amounts to 5.4 Gt CO2 eq of additional accumulated consumption reductions in 2030, which 

might be a better indicator for the evaluation of differences between the scenarios (table 7-4; 

figure 7-9). 

Given the high uncertainties of projections until 2050, the following reduction potentials are to 

be treated as trend only. Accumulated reduction potentials until 2050 range at108 Gt CO2 eq 

(RED10) and 125 Gt CO2 eq (RED). 

Table 7-4: Overview of accumulated HFC consumption reductions (Gt CO2 eq) from freeze to 

2030 achieved under the various scenarios and compared to the RED10 scenario (%) 

Region Scenario 

Consumption reduction 

until 2030 

(Gt CO2 eq) 

Consumption reduction in 

comparison to the RED 10 

scenario 

World 

 RED 10 22.9 100% 

 RED 28.3 124% 

 FSM 25.5 111% 

 NA 24.1 105% 

A2 countries 

 RED 10 8.1 100% 

 RED 10.9 135% 

 FSM 9.3 115% 

 NA 7.5 92% 

A5 countries 

 RED 10 14.8 100% 

 RED 17.4 118% 

 FSM 16.1 109% 

 NA 16.7 112% 
Chapter 7 Options for further international action 227

Figure 7-9: Comparison of lowest vs. highest scenario reductions (World) 
Chapter 8 Options for further EU action 228 

8. Options for further EU action to reduce F-gas emissions 

8.1 Options for the review of the F-gas Regulation 

Technically feasible and effective policy options for further EU action should aim at a costeffective contribution to the EU’s emission reduction commitments, in particular the emission 

reductions agreed for the non-ETS sectors under Decision 406/2009/EC (Effort Sharing 

Decision)300 for 2020 and longer-term emissions reductions as outlined in the Commission’s 

“Roadmap for moving to a competitive low carbon economy in 2050” (COM(2011)112). 

The identification of policy options for further EU action addressing emissions of fluorinated 

greenhouse gases is based on the projected impact of the current Regulation, takes into 

account emission sources not yet covered (chapter 5) and includes the options listed in 

Article 10 of the Regulation. 

The initial starting point for identifying policy options is the WM scenario (chapter 5). This 

scenario is used as reference scenario. 

Option A Business-as-usual (do nothing). 

Option B reflects the development of F-gas emissions if current provisions would be 

suspended. 

Option C takes non-regulatory approaches into account. 

Option D describes further regulatory action and includes several sub-options addressing 

particular sectors, types of measures and/or types of F-gas emissions. 

Option E includes market-based approaches such as activities under the EU-ETS, tax 

schemes as well as deposit-refund schemes. 

Policy options for further action describe different ways forward and in most cases are 

mutually exclusive. Therefore, the underlying approaches vary significantly although certain 

sub-options might complement each other. 

 

300 OJ L 140, 5.6.2009, p. 136. 
Chapter 8 Options for further EU action 229 

8.1.1 Option A: No policy change

This option represents the current situation and assumes full implementation and application 

of the provisions of the F-gas Regulation in all Member States and sectors. 

The assessment of the emissions is illustrated by the WM scenario of the model AnaFgas 

(chapter 5). F-gas emissions are projected to remain at stable levels from 2015 onwards. 

8.1.2 Option B: Discontinue existing provisions

Option B assumes that current provisions of the F-Gas Regulation are suspended. The 

development of emissions will gradually align with the scenario prior to the measures set out 

by the F-gas Regulation (WOM scenario in the model AnaFgas) except for the sector of 

mobile air conditioning of passenger cars which is covered by the MAC Directive and 

included in the WM scenario. 

As outlined in chapter 4, existing provisions have not been fully implemented and applied in 

all Member States yet. Delay and problems of implementation vary between sectors and 

Member States. 

It should be noted that general suspension of existing provisions would disadvantage 

Member States and industry compliant with current legislation. Such measure would also not 

be in line with the climate and energy package and the 2050 roadmap, that require 

contributions from all sectors to the EU emission reduction targets in 2020 and beyond until 

2050. 

This option would not be consistent with EU emission reduction targets since long-term 

emissions would grow. 

Option B that the current provisions of the F-gas regulation would be suspended was 

discarded from further analysis because such approach would not be in line with the EU’s 

climate and energy package and with the EU’s overall objective that all relevant sectors 

should contribute to the mitigation of greenhouse gas emissions in the future. 
Chapter 8 Options for further EU action 230 

8.1.3 Option C: Non-regulatory approaches at EU level

Some specific measures for the abatement of F-gas emissions could be implemented via 

voluntary agreements or via regulatory approaches. These are addressed under option C 

and option D respectively and an assessment of pros and cons for the respective option is 

provided. 

Option C includes non-regulatory approaches which comprise voluntary agreements, open 

methods of coordination and the provision of information and guidelines. 

Sub-option C-1: Environmental agreements and self-regulation 

In chapter 3 on F-gas policies, the report describes in which areas voluntary agreements 

related to fluorinated gases already exist at international, European or Member State level. 

This section explores additional areas for voluntary agreements with industry. 

Environmental agreements are a form of self-regulation as they are not binding at 

Community level. However, the Commission can encourage them, recognize them or 

propose that the legislature makes use of them (co-regulation). While self-regulation does 

not involve the adoption of a legislative instrument, the Commission can nevertheless decide 

to introduce a monitoring and evaluation system. Such environmental agreements can 

generally be recognized at Community level: 

• by a recommendation from the Commission accompanied by adoption of the 

agreement or by an exchange of letters between the Commission and 

representatives of the sector, recognizing the agreement; 

• by a recommendation from the Commission accompanied by a Council and 

European Parliament decision setting up a monitoring and reporting system. 

Co-regulation concerns agreements concluded in the framework of a Community legislative 

instrument laying down the objectives to be achieved, the timetable to be met, monitoring 

methods and penalties to be imposed for non-compliance. Details for implementation are set 

out in the agreements. In general, it is the Commission that takes the initiative for such 

agreements. 

According to the communication on environmental agreements at Community level301, the 

criteria that should also be taken into account in the establishment and assessment of 

environmental agreements are the following: 

• Representativeness: signatories to environmental agreements should represent 

the majority of the economic sector concerned and should be responsible and 

organised; 

• Quantified and staged objectives: the objectives of the agreements must be 

clearly stated. If the agreement covers a long period, intermediate objectives must 

likewise be specified. There must be reliable indicators to measure the extent to 

which objectives have been achieved; 

 

301 European Commission 2002: Communication from the Commission to the European Parliament, 

the Council, the Economic and Social Committee and the Committee of the Regions - Environmental 

Agreements at Community Level Within the Framework of the Action Plan on the Simplification and 

Improvement of the Regulatory Environment, COM(2002) 412 final of 17.7.2002. 
Chapter 8 Options for further EU action 231 

• Monitoring and reporting: Environmental agreements should include a 

monitoring and reporting system for achieving the objectives; 

• Cost-effectiveness of administration: Administrative costs should not be higher 

than those of other available instruments; 

• Involvement of civil society: Agreements should be accessible to the public on 

the internet, and the same applies to the relevant reports and accounts. Interested 

parties should be able to express their opinions. 

If the voluntary agreement does not produce the results envisaged, the Commission could 

still propose binding regulatory legislation; however emission reductions would then be 

considerably delayed. Past experiences with voluntary agreements at EU and Member 

States level have not always been successful, and for any new voluntary agreements it 

would be essential that staged targets are agreed and that an appropriate monitoring and 

reporting system is established that provides early signals whether the objectives of the 

agreement is met to allow for appropriate measures by the Commission in case of noncompliance with the agreement. 

In the following section a number of new or enhanced voluntary agreements are considered 

as a way to achieve further F-gas emission reductions. For the assessment of the proposed 

specific options the criteria provided by the Commission’s communication were used (with 

the exception of the involvement of civil society which would be an issue for the further 

implementation of such agreements). Voluntary agreements seem to be a promising option 

for sectors where few actors are involved as this would allow simple follow-up. 

It is generally considered that particular applications of HFCs for which negative abatement 

costs have been estimated in the cost assessment (see annex V and VI), would be 

interesting options for voluntary agreements. 

Option C-1 a: Voluntary agreements with industry to phase-out HFCs in commercial 

refrigeration

The Paris-based Consumer Goods Forum (CGF), which includes more than 400 of the 

world's largest consumer goods manufacturers and retailers302, announced on 29 November 

2010 at COP 16 in Cancún a commitment to start phasing out the use of HFCs in 

refrigeration equipment as of 2015. HFCs shall be replaced with non-HFC refrigerants 

(natural refrigerant alternatives) where these are legally allowed and available for new 

purchases of point-of-sale units and large refrigeration installations.303 As part of this 

voluntary commitment the company Coca-Cola announced that its vending machines should 

be HFC-free by 2015. 

The Forum also recognized that barriers exist to wide scale adoption of more climate-friendly 

refrigeration, namely legislative restrictions in some markets, availability, cost, safety, 

maintenance and servicing and committed to work to overcome those barriers by 

strengthening existing collaborative platforms and initiatives and to use its collective 

influence to encourage our supply base to develop natural refrigerant technologies that meet 

business demand under commercially viable conditions. 

 

302 The Consumer Goods Forum includes well-known brands such as Carrefour, Coca-Cola, Johnson 

& Johnson, Kellogg, Kraft, L'Oréal, Nestlé, Procter & Gamble, Tesco, Unilever, and Wal-Mart. 

303 The Consumer Goods Forum (2010): TCGF Board Resolution on Sustainable Refrigeration. 

Published at http://www.ciesnet.com/pfiles/publications/copenhagenpaper.pdf 
Chapter 8 Options for further EU action 232 

This initiative could be used as a starting point for a more formal voluntary agreement with 

industry for the phase-out/phase-down of HFCs. The specific applications addressed are 

stand-alone hermetic refrigeration systems which use HFC-134a or R-404A, condensing 

units in small commercial refrigeration and centralized systems in supermarkets. 

Representativeness 

The Consumer Goods Forum as initiator comprises a large number of important international 

retailers and includes a majority of the sector concerned. It already took responsibility and 

announced a voluntary agreement at COP 16 in Cancún. The Consumer Goods Forum is a 

global, parity-based industry network, driven by its members. It brings together the CEOs 

and senior management of over 650 retailers, manufacturers, service providers and other 

stakeholders across 70 countries. The Forum provides a global platform for knowledge 

exchange and initiatives around five strategic priorities – Emerging Trends, Sustainability, 

Safety & Health, Operational Excellence and Knowledge Sharing & People Development. 

Thus the forum is representative and through the membership of CEOs and senior managers 

it includes the key responsibles that are able to implement adopted strategies in the 

companies. 

Quantified and staged objectives 

The objectives of the voluntary agreements stated in Cancún and available from the 

Consumer Goods Forum webpage are not clearly stated. This refers to the starting point, to a 

target year and to the quantification of the share of HFC refrigerants that should be replaced 

until the target year. Thus, the targets and the period needs to be further specified. 

Monitoring and reporting 

The proposed voluntary action by the Consumer Goods Forum does not mention any 

monitoring and reporting system for achieving the objectives. Such system would need to be 

established and would need to monitor and report 

• the existing amount of HFC refrigerants covered by the participating companies; 

• the replacement of HFC refrigerant by natural refrigerant alternatives; 

• any effects of potential accompanying measures to reduce leakage from 

appliances with HFCs; 

• recycling and re-use of HFCs. 

The Forum could provide guidance and assistance to the individual companies related to 

collecting of data, the monitoring and reporting. 

Potential emission reductions 

The potential additional emission reduction that can be achieved with the phase-down of 

HFCs in centralized systems, commercial hermetic systems and condensing units is 

estimated at 18,818 kt CO2 eq in 2030, thus the sector offers a rather high emission 

reduction potential. 

Cost-effectiveness 

Emission reduction costs for a phase-down of HFCs in closed stationary centralized systems, 

commercial hermetic systems and condensing units are rather low and vary from -0.8 €/t CO2 

eq for commercial hermetic systems to 23.7 €/t CO2 eq for centralized systems. 
Chapter 8 Options for further EU action 233 

Option C-1b: Voluntary agreement with refrigerated transport industries to phase 

down HFCs in transport refrigeration 

A VA on phase down of HFCs in transport refrigeration equipment has been suggested by 

industry as in this sector only a relatively small number of manufacturers304 place equipment 

on EU markets and could hence contribute to a phase down of HFCs in transport 

refrigeration. However, the operators of equipment ultimately decide for the type of 

equipment and would need to be involved to large extent in order to successfully establish 

such VA. The number of operators of transport refrigeration equipment in EU-27 is unclear 

and no large end-user association for this sector is known to be able to implement, monitor 

and control such VA. Therefore, this option for a VA is not followed further in this work. 

Nevertheless, attempts of the transport refrigeration industry to address F-gas emissions 

from their sector on a voluntary basis could complement other action. 

Option C-1c: Voluntary agreements with photovoltaics industry to replace NF3 

As explained in chapter 5, NF3 was introduced to new production lines of silicon-based thinfilm solar cells in Germany and Spain after 2004 where large-sized tool chambers, similar to 

those in LCD manufacture, are used for removal of silicon from tools after deposition. The 

quantity of NF3 used by the solar industry is still very small with about 40 tons of NF3 in 2008/ 

2009. The photovoltaic plants that use NF3 for CVD chamber cleaning have been equipped 

with exhaust gas abatement tools (thermal decomposition) from the very beginning. 

The solar industry is very interested to keep a positive climate-friendly image, therefore it is 

considered possible that thin film silicon solar cell plants would be interested to replace NF3

by e.g. elemental fluorine. 

Thin silicon-film producers in Europe that would need to be included in a voluntary 

agreement are the producers Inventux, Sunfilm, Malibu, Masdar, Signet Solar, Inventux, 

Gadir Solar, and T-Solar (state 2010). The objective that needs to be agreed would be a 

replacement of NF3. For replacement of SF6 further companies should be addressed, e.g. 

Schott and Bosch. As few companies are involved, specific timelines would need to be 

agreed. Monitoring would be rather simple as few companies are concerned for which the 

phase out of NF3 use would need to be monitored. 

In this study, emissions for 2008/2009 are estimated at 10.3 kt CO2 eq and are projected to 

increase to about 100 kt CO2 eq. by 2030. According to suppliers of abatement equipment no 

additional costs would arise to operators. 

Option C-1d: Voluntary agreement to replace HFC-134a in XPS foam

In chapter 6 it was explained that the replacement of HFC-134a by low GWP alternative 

blowing agent for XPS foams corresponds to abatement costs of as low as 1.0 €/t CO2 eq305. 

Due to the low costs, this application seems to offer a potential to achieve a voluntary 

agreement with industry who at the same time can significantly improve the environmental 

image of their product. 

 

304 As outlined by the industry association Transfrigoroute, only two companies account for ca. 85% of 

the equipment placed on the market in EU, another 7-10 manufacturers contribute the remaining 15%. 

305 The industry association EXIBA disagrees with the estimated level of abatement costs. 
Chapter 8 Options for further EU action 234 

XPS foam industry to be included in a voluntary agreement is represented at European level 

by the industry association EXIBA, which, however, does not represent all manufacturers. 

However EXIBA has expressed the view that “a voluntary agreement as proposed could not 

occur for the following reasons: i) Replacement of HFCs has already occurred for a majority 

of XPS products with CO2 based blowing agents, ii) the technically feasible alternative using 

unsaturated HFCs is currently not possible since these substances are hardly available yet 

and not in large commercial quantities, iii) EXIBA might not represent all EU XPS 

manufacturers using HFC-134a.” 

The objective that needs to be agreed would be a timeline for the replacement of HFC-134a 

by alternative blowing agents. As very few companies are involved, specific timelines could 

be agreed. Monitoring would need to monitor the point in time and quantities of HFC-134a 

that individual companies would replace by low GWP blowing agents. 

Emissions reductions that can be achieved with the replacement of HFC-134a in XPS foams 

are estimated to be 1,553 kt CO2 eq by 2030. 

Option C-1e: Renewed voluntary agreement for reducing F-gas emissions in the 

semiconductor industry

As described in chapter 3, the semiconductor industry (including all the countries where 

production is located) had committed to a voluntary agreement to reduce F-gas emissions of 

HFC-23, PFCs, SF6 and NF3

306 by 10% until 2010 (baseline 1995). This target has been 

reached and a new voluntary agreement for the post-2010 period could be prepared and 

agreed with the semiconductor industry. 

Global representativeness as for the first voluntary agreement should again be the objective. 

At EU level the representative organisation is the European Semiconductor Industry 

Association (EECA-ESIA). At global level, it is the World Semiconductor Council. A voluntary 

agreement should target NF3, HFC-23, PFCs and SF6 emissions from semiconductor 

industry just as the previous agreement307. The emission reduction potential of such 

agreement is not estimated in this work as plant-specific circumstances would need to be 

taken into account. 

Option C-1f: Voluntary agreement for phasing out HFC-134a in domestic refrigeration

Domestic refrigeration has been identified as another sector with rather low mitigation costs 

of 1.0 €/t CO2 eq by 2030 if HFC-134a would be completely phased out. However, the 

achievable emission reduction is only about 12 kt CO2 eq until 2030 because remaining 

HFCs are already being phased-out in Europe, and will be of negligible size by 2030. The 

domestic refrigeration sector has in the past served as “lighthouse sector” for sustainability in 

the context of ODS phase out, but today only very few units containing F-gases are imported 

to Europe. Such voluntary agreement is thus excluded in the screening process for policy 

options (chapter 8.2). 

 

306 In the semiconductor industry the term “PFC” means “perfluorocompounds”, not perfluorocarbons, 

and is used also for SF6 and NF3. In addition it includes HFC-23 although it is not fully but only partly 

fluorinated (containing hydrogen). In the IPCC GL the term “fluorinated compounds (FC)” is used. 

307 The World Semiconductor Council (WSC) stated on their 15th Meeting (May 26, 2011) in Fukuoka 

(Japan) to intend “a new voluntary agreement for the next 10 years”. It shall target at a reduction in 

Normalized Emission Rate (NER) in 2020 to 0.22 kgCO2e/cm2

, which is equivalent to a 30% NER 

reduction from 2010 aggregated baseline. It should be noted that such a reduction per cm2

 substrate 

is a relative reduction which does not necessarily imply reduction in absolute emissions. 
Chapter 8 Options for further EU action 235 

Option C-1g: Voluntary agreement to replace HFC-23 in fire protection

In the EU, Spain is the main user of HFC-23 as fire extinguishing agent (with a very high 

GWP of 14,800) with more than 93% of the total European use (2008).308 Six further Member 

States apply HFC-23 in comparably small quantities309. As described in chapter 6, the fluoroketone FK 5-1-12 is available as abatement option. Due to the limited regional use of HFC23, a voluntary agreement to replace HFC-23 can be considered. 

An objective of full replacement of HFC-23 until 2015 could be set. The emission reduction 

that can be achieved until 2030 is estimated at 961 kt CO2 eq. The estimated mitigation costs 

are low with 3.1 €/t CO2 eq in 2030. Yet, it should be noted that phase out of HFC-23 in fire 

protection is likely to result to large extent in replacement by HFC-227ea, which would limit 

the emission reduction potential, unless restrictions for the use of this substance also apply. 

The total number of EU based original equipment manufacturers and fillers of fire 

suppression systems is rather high (estimated at 30), with 3 companies accounting for ca. 

60% of the total market of all kind of fire protection systems (Tyco, UTC, and Minimax). 

In Spain several local companies are also important suppliers of HFC-23 installations. In 

Central Europe an Austrian company sells such systems. However, there is no EU wide 

association which represents the majority of fillers, thus making an agreement difficult. The 

organization EUROFEU underlined an interest to work with the Commission in the 

development of a voluntary agreement concerning the use of HFC-23 in fire protection. 

Option C-1h: Voluntary agreement for destruction of HFC-23 emissions from 

halocarbon production

F-gas emissions from sectors addressed by current measures of the F-gas Regulation do not 

include fugitive and by-product emissions in the halocarbon production (chapter 5). So far, 

one of the five operators of halocarbon plants which cause HFC-23 by-product emissions 

does not operate an abatement system for by-product emissions (chapter 5). Installation of 

such system is said to be "in preparation". The other four manufacturers have each installed 

abatement systems on a voluntary basis. Due to the limited regional scope, a voluntary 

agreement should be considered, in particular as the producers already announced its 

intention to install an abatement system. 

The emission reduction that can be achieved until 2030 is estimated at 370 kt CO2 eq. The 

estimated mitigation costs are low with 2 €/t CO2 eq in 2030. Monitoring would be relatively 

easy as few Member States and companies are concerned. The industry association that 

could be involved in such agreement is EFCTC (association of fluorocarbon producers). 

This option is particularly relevant for consistency with a potential international HFC 

agreement and would be in line with European climate policies which support HFC-23 

destruction in developing countries through the CDM. 

 

308 The industry association ASSURE states that „the Spanish market for HFC-23 is more a reflection 

of the relatively low cost of the product in the country and historical preference for HFC-23 systems 

rather than a result of its specific technical properties“. 

309 Amongst them, only Portugal, France and Austria used up to 5 metric t, each in 2008. Spain used 

255 t. Data from AnaFgas. 
Chapter 8 Options for further EU action 236 

Sub-option C-2: Improved co-ordination 

Improve compliance with existing legislation

Low compliance with provisions of the F-gas Regulation has been identified for several 

sectors in different Member States (chapter 4). Although rules and penalties on infringements 

of the provisions have been established at national level, industry experts pointed out that 

lacking compliance was also due to the low level of control and enforcement by authorities. 

Authorities confirmed that inspections were rarely carried out and were mostly restricted to 

reported data. 

This finding implies that encouraging co-operation between Member States on ways to 

improve compliance, the exchange of best practice in the implementation and agreement of 

additional guidelines for the enforcement authorities could be added value at Community 

level. Areas that should be specifically tackled by such measures of coordination are 

• Additional guidance for environmental inspectors could contribute to raise 

awareness about the areas of use and the emissions of F-gases. Synergies with 

the ODS Regulation should be underlined in order to minimize administrative 

efforts and related costs. 

• Exchange of best practices about mechanisms for a more efficient control by 

authorities. 

• Exchange of best practices for leakage control. 

• Integration of relevant certification systems under the Pressure Equipment 

Directive, the Energy Performance of Buildings Directive and the Renewable 

Energy Directive at Member State level in order to facilitate compliance with these 

requirements and to enhance cost-effectiveness of certification. 

Industry has started an initiative for improved co-ordination by implementing the homepage 

www.figaroo.org, a webpage dedicated as a pan-European resource for users of HFCs, 

designed to share information and best practice, to make a success of the F-Gas Regulation. 

The UK set up the initiative REAL Zero ‘Refrigerants emissions and leakage zero’ 

(http://www.realzero.org.uk/) to help achieve significant reductions in carbon emissions due 

to refrigerant leakage from installed systems. REAL Zero is a project carried out by the 

Institute of Refrigeration, with the support of the Carbon Trust and the objective is building a 

better understanding of where and why leakage occurs and how to prevent it. The initiative 

offers training, additional practical guidance, toolkits, guidance notes and conducts case 

studies. 

Improved co-ordination at EU level for the implementation and application of the F-gas 

Regulation could take up these initiatives and promote additional guidance and best 

practices across Member States. This could be implemented by conferences at EU level 

inviting Member States with related initiatives as well as business and industry that are 

involved in effective implementation initiatives. 

For the implementation of the EU-ETS two ‘ETS compliance conferences’ have been held so 

far with the aim to improve compliance across Member State and to open a communication 

channel with the policy-making process at Member State level. The focus is on 

implementation of the ETS monitoring and verification provisions at regional and, possibly, 
Chapter 8 Options for further EU action 237 

local levels, and the facilitation of the participation of Competent Authorities in the exchange 

of experiences. The work of the compliance forum is supported by additional research 

projects in Member States on the status and ways of implementation of monitoring and 

verification under the ETS. 

A similar approach could be implemented for the F-gas Regulation to address the important 

area of compliance with the existing regulation at Member State level and further promote 

the best practice examples and initiatives from Member States and businesses. 

Calculations of F-gas emissions in the WM scenario of this study are based on the 

assumption that the F-gas Regulation is fully applied. This sub-option summarizes ideas to 

improve compliance with existing legislation but will not lead to additional emission 

reductions beyond the level of the WM scenario. It is thus not analyzed further in the course 

of this chapter. 

Sub-option C-3: Enhanced technical standards 

Article 10(2d) requires an assessment of the need for Community standards relating to the 

control of emissions of F-gases from products and equipment, in particular as regards foam, 

including technical requirements with respect to the design of products and equipment. 

A standard is a technical document designed to be used as a rule, guideline or definition, and

standardization is the voluntary process of developing technical specifications based on 

consensus among all interested parties (industry including Small and Medium-sized 

Enterprises, consumers, trade unions, NGOs, authorities, etc).310 

The standardization process is carried out by independent standards bodies, acting at 

national, European and international level. The three European Standardization 

Organizations (ESOs) include CEN – Committee for European Standardization (Comité 

Européen de Normalisation, Europäisches Komitee für Normung), CENELEC – European 

Committee for Electrotechnical Standardization, and ETSI – European Telecommunications 

Standards Institute. They are recognized as competent in the area of voluntary technical 

standardization and listed in Annex I of European Directive 98/34/EC. 

The CEN is the relevant standards body for the most relevant equipment containing F-gases. 

All CEN activities are undertaken by a group of stakeholders, manufacturers, users, research 

organizations, government departments and consumers. 

Standardization supports market-based competition, so as to achieve objectives such as the 

interoperability of complementary products and services, or to provide agreed test methods 

and requirements for health, safety, organizational and environmental performance. Through 

the development of European standards and the withdrawal of conflicting national standards, 

standardization has played a leading role in the achievement of a Single Market for goods. 

Most standards are prepared at the request of industry. The European Commission can also 

request the relevant standards bodies to prepare standards in order to implement European 

legislation. This type of standardization activity is 'mandated' by the European Commission. 

In most cases, such initiatives are supported by the EFTA Secretariat. Draft mandates are 

drawn up by the Commission services through a process of consultation with a wide group of 

 

310 European Commission: European standardization policy, 2010; 

http://ec.europa.eu/enterprise/policies/european-standards/standardisation-policy/index_en.htm 
Chapter 8 Options for further EU action 238 

stakeholders. Before being formally addressed to the ESOs, they are submitted for opinion to 

the Member States in the Standing Committee of the 98/34/EC Directive.

The ESOs, which are independent organisations, have the right to refuse a mandate if they 

do not think that standards can be produced in the area being covered. In practice this 

refusal happens rarely due to the informal consultation mentioned above. 

Three types of mandates could be considered: 

- study mandates to check the feasibility of standardization; 

- mandates requesting the elaboration of a standardization programme; 

- mandates for the development and adoption of European standards (reference Art 10). 

The target of ESOs is to develop standards in 3 to 4 years depending on the complexity of 

the issue and the consensus building between various stakeholders. If standards are 

developed based on mandates given by the European Commission, the time needed to draft 

a mandate and the time given to the standardization organisations for response need to be 

added. The drafting will take ca. 6-18 months and response from standardization bodies is 

usually given within 6 months.311 

European Standards are a key component of the Single European Market and are highly 

important for manufacturers inside and outside Europe as they increase product safety and 

quality and lower transaction costs and prices. A standard codifies best practice and is 

usually state of the art relating to products, services or systems. A European Standard 

automatically becomes a national standard in all Member States, but remains voluntary to 

use.

Existing standards and reductions of F-gas emissions: Products and equipment relying 

on F-gases are addressed by various international, European and national standards, which 

set out specifications, performance requirements, and safety measures (see chapter 3 on 

existing standards). 

Standards can support reductions of F-gas emissions by transferring best practices to 

markets and thereby replacing previous technologies and methods. Regulatory mechanisms 

often refer to existing standards, which anticipated legislation, e.g. Article 3(5) of the F-Gas 

Regulation refers to the ISO 14520 standard. 

In the context of the overall policy target of GHG emission reductions, it should be noted that 

- standards are voluntary to use. Monitoring of technical parameters, reporting to 

databases/institutions and evaluation is not included; 

- the impacts of standards on emission reductions within a particular time frame are 

almost impossible to quantify as they depend on market uptake of standardized 

products and equipment or on the number of personnel and companies applying the 

standards. 

Standards cannot be considered as an effective tool to achieve significant emission 

reductions within a particular time but are likely to contribute to long-term emission 

reductions through the consensus-based introduction of best practices. 

 

311 Written communication from Aare Viljanen, European Commission, DG Enterprise and industry, 

Standardisation; 28.10.2010. 
Chapter 8 Options for further EU action 239 

As standards contain technical specifications for products and equipment, F-gas emissions 

from various sectors cannot be covered under one standard only, but would have to be 

controlled through standards specific to each application. Therefore, covering large shares of 

F-gas emissions would require several standardization procedures to get started. 

Since the effects of such voluntary measures on F-gas emissions cannot be determined in 

the short and medium term, this option is not considered further in the screening of options. 

Nevertheless, industry should be encouraged to continue the exchange of best practices in 

the various sectors. 
Chapter 8 Options for further EU action 240 

8.1.4 Option D: Regulatory approaches 

Sub-option D-1: Include F-gases currently not included in Annex I of the F-gas 

Regulation 

Article 10(2)b of the F-gas Regulation requires the Commission to publish a report which 

shall, in the light of future assessment reports of the IPCC, assess whether additional 

fluorinated greenhouse gases should be added to Annex I. This annex lists 17 HFC 

substances, 7 PFC substances and with their GWP values as presented in the 3rd IPCC 

assessment report from 2001. 

Certain fluorinated greenhouse gases currently not addressed by the F-gas Regulation 

including NF3, SO2F2 (sulfuryl fluoride) and unsaturated HFCs have been screened for their 

quantitative significance to the EU F-gas inventory (chapter 5). 

As for NF3, it is suggested to include this substance in reporting provisions as well as those 

PFCs and HFCs for which a GWP was listed in the IPCC’s 4th Assessment Report and which 

have not been included in the reporting guidelines (HFC-152, HFC-161, c-C3F6 and PFC 9-1-

18). 

Based on the findings on SO2F2 stated in chapter 5.3, no additional benefit would result from 

including this gas in Annex I of the F-gas Regulation. 

In case an international HFC agreement will include unsaturated HFCs, it will be necessary 

to establish monitoring and reporting requirements for these substances. However, in the 

absence of such agreement, unsaturated HFCs should not be included in the scope of the Fgas Regulation as their projected emissions are very low. Other abatement options with 

similar emissions will not be reported either. 

Sub-option D-2: Enhance application and monitoring of the Regulation 

Sub-option D-2a: Enhance labelling requirements

Labelling requirements currently apply to refrigeration products and equipment containing 

PFCs, refrigeration and AC products and equipment (other than those contained in motor 

vehicles), heat pumps, fire protection systems and fire extinguishers, if they contain HFCs or 

preparations containing HFCs, switchgear containing SF6 or preparations containing SF6, 

and all F-gas containers. The label must include the chemical name of the F-gas contained 

by using the accepted industry nomenclature and the quantity of F-gas. 

Provisions on labelling allow responsible installation, servicing, maintenance, and end-of-life 

treatment of equipment and products containing F-gases. Therefore, labelling requirements 

could help to communicate relevant information on types and quantities of F-gases contained 

in products and equipment currently not covered by relevant provisions and raise awareness 

of operators of equipment and users of products. 

With regard to end-of life, F-gas banks contained in foams seem to be particularly important 

to be treated properly particularly in the future due to their long lifetime. High disposal 

emissions could be avoided by providing information on the F-gas banked in particular foam 

products. 
Chapter 8 Options for further EU action 241 

It is estimated that labelling requirements could be extended through the review of the F-gas 

Regulation to all types of foams containing F-gases312 and all mobile AC equipment 

containing F-gases. Based on information on labelling costs of products and equipment 

already covered by provisions, costs for extended labelling requirements are assumed to be 

rather low. Yet, the emission reduction potential of this option can hardly be determined. 

This option should be considered rather an additional step for improved management of Fgas banks than a measure resulting in significant emission reductions on its own. 

Sub-option D-2b: Improve definitions and clarify provisions under the F-gas 

Regulation

Certain needs for clarification of provisions in the F-gas Regulation have been identified by 

experts and stakeholders in the course of the project. In particular, it was suggested to 

streamline definitions and provisions with other European legislation, e.g. the ODS 

Regulation (EC) No 1005/2009. Usually the same operators of equipment, service 

companies, industry associations and authorities deal with both ODS and F-gases. 

Examples for terms and definitions, which could benefit from further clarification, include: 

• “as soon as possible repair detected leakage” 

The time period for repair of leakage could be specified. Article 3(1b) could be revised e.g. 

according to the wording of the ODS Regulation and then read “as soon as possible repair 

detected leakage and in any event within 14 days”. 

• “operator” 

The term “operator” is defined as follows (Article 2(6)): “the natural or legal person exercising 

actual power over the technical functioning of the equipment and systems covered by this 

Regulation: a Member State may, in defined, specific situations, designate the owner as 

being responsible for the operator’s obligations”. This definition is interpreted differently in 

national legislation in the Member States, e.g. in France it always refers to the owner of 

equipment. 

Article 2(6) clarifies that ownership is not a decisive criterion to be used to identify the 

operator. However, it suggests that Member States may designate the owner as being 

responsible for the operator’s obligations even though the owner does not have actual power 

over the technical functioning of the system or equipment. 

Guidance of the European Commission underlines that Member States who want to refer to 

that clause should make sure that legislative, regulatory or administrative provisions clearly 

identify the defined and specific situations in which the owner is responsible for the 

operator’s obligations. It might hence be useful to clarify the definition in this respect. 

• “hermetically sealed system” 

The term “hermetically sealed system” is defined as follows (Article 2(11)): “a system in 

which all refrigerant containing parts are made tight by welding, brazing or a similar 

 

312 The industry association EXIBA stated concerns with regard to the long product life of insulation 

foams of several decades and that no marking or labelling would last sufficiently long. – Further input 

to this matter is expected from a study on behalf of the EU Commission assessing policy options for 

the management of ODS and F-gas banks in the EU with a particular focus on foams. 
Chapter 8 Options for further EU action 242 

permanent connection which may include capped valves and capped service ports that allow 

proper repair or disposal and which have a tested leakage rate of less than 3 grams per year 

under a pressure of at least a quarter of the maximum allowable pressure”. 

This definition seems to have created confusion among stakeholders concerning the scope 

of the provisions of the F-gas Regulation. It could be revised and changed to e.g. “factory 

sealed systems”. 

• “preparation” 

Preparations are defined (Art 2(5)) “for the purposes of the obligations in this Regulations, 

excluding destruction, a mixture composed of two or more substances at least one of which 

is a fluorinated greenhouse gas, except where the total global warming potential is less than 

150. The total global warming potential of the preparation shall be determined in accordance 

with Part 2 of Annex I”. 

It should be noted that certain F-gases are in the scope of the provisions if used as pure 

substances (e.g. HFC-152a which has a GWP of 120; HFC-41 which has a GWP of 97) but 

out of the scope if contained in a blend with GWP <150. This seems to counteract the 

objective of the Regulation which is to contain, prevent and thereby reduce F-gas 

emissions313. 

• Containment and recovery provisions 

Article 3 of the F-gas Regulation sets out provisions on HFC containment and applies to 

stationary refrigeration, air conditioning and heat pump equipment and fire protection 

systems but excludes mobile applications such as transport refrigeration and mobile AC 

(which is partly covered by the MAC Directive). Article 3(1) requires operators to use “all 

measures which are technically feasible and do not entail disproportionate cost” to carry out 

containment measures. 

Article 4 of the F-gas Regulation states provisions on recovery. Article 4(1) covers stationary 

equipment and requires operators to put “in place arrangements for the proper recovery [of 

HFCs] ... to ensure their recycling, reclamation, and destruction.” This means that HFCs 

banked in stationary equipment are subject to mandatory recovery for recycling, reclamation 

and destruction. Provisions for mobile equipment, in contrast, are less stringent and apply “to 

the extent that it is technically feasible and does not entail disproportionate costs... to ensure 

their recycling, reclamation, and destruction” (Article 4(3)). 

Both containment and recovery provisions remain unclear about technically feasible 

measures and the actual cost thresholds for these measures, which creates uncertainty 

among operators of equipment. In order to provide further guidance, sector specific 

requirements for cost-effective containment and recovery may be laid down. 

• Certification and liability 

According to Article 5(3), operators are required to ensure that personnel are holding the 

necessary certifications and are hence liable to check the certification status. However, 

personnel and companies involved in installation, maintenance or servicing of the equipment 

and systems covered by Article 3(1) as well as for the personnel involved in the activities 

 

313 In contrast, the industry association FEA states that this definition has fostered innovation for Fgases and products reducing F-gas emissions significantly. 
Chapter 8 Options for further EU action 243 

provided for in Articles 3 and 4 are not liable at all. Therefore, penalties apply only to 

operators of equipment and not to non-certified personnel and companies which may 

undertake the relevant activities. 

Further improvement of the provisions should take this aspect into account and consider 

assigning liability also to personnel and companies subject to certification provisions. 

• Streamlining with other pieces of EU legislation 

Terms and definitions set out by ongoing reviews of other pieces of European legislation 

should be checked for complementarities/overlaps in order to further streamline EU 

legislation and avoid confusion. This would apply, for example, to the requirements for 

certification of personnel set out by the Pressure Equipment Directive, the Energy 

Performance of Buildings Directive, the Renewable Energy Directive and the F-gas 

Regulation. Potentials for the combination of trainings and/or certificates could be explored. 

The emission reduction potential of this option cannot be calculated and the costs for 

improving definitions and providing further guidance are estimated to be rather low. This 

option should be considered rather an additional step for improvement of the existing 

legislation and its application than a measure resulting in significant emission reductions on 

its own. 

Sub-option D-2c: Improve reporting system for fluorinated gases

Article 10(2)(f) requires the Commission to consider the modification of the reporting 

requirements in Article 6(1), in particular the one tonne quantitative limit, and for the 

competent authorities to report periodically to the Commission estimated emissions based on 

representative samples to improve the practical application of those reporting requirements. 

Current reporting provisions require producers, importers and exporters of F-gas quantities of 

>1 tonne per year to communicate the following information to the European Commission: 

- Total production of each F-gas; 

- Total imported quantities of each F-gas in the Community; 

- Total exported quantities of each F-gas from the Community; 

- Total quantity of each F-gas placed on EU market and their intended applications; 

- Any quantities of each F-gas recycled, reclaimed or destroyed, imported or exported 

for recycling, reclamation or for destruction. 

The format for reporting by producers, importers and exporters of F-gases is set out by 

Commission Regulation (EC) No 1493/2007. 

Quantities of F-gases contained in imported or exported pre-charged equipment are 

presently not subject to reporting provisions. 

Several sub-options for enhancing the reporting obligations are to be considered: 

• Extending the company reporting requirements to quantities contained in 

imported or exported pre-charged products and equipment 

Within an analysis of existing F-gas policies, data on quantities of F-gases contained in precharged equipment and currently not covered by reporting requirements have been collected 
Chapter 8 Options for further EU action 244 

(cf. chapter 4.2.7). Pre-charged equipment in large numbers is imported to or exported from 

EU-27 in several sectors including 

- Mobile air conditioning (import and export of motor vehicles) 

- Stationary air conditioning (import of factory-made devices) 

- One component foam (export of cans) 

- High-voltage switchgear (export of systems containing SF6) 

- Metered Dose Inhalers (export of aerosol cans). 

Imported and exported quantities of F-gases contained in pre-charged equipment have been 

estimated (table 4-25). 

As outlined in chapter 4.2.7, exports of F-gas contained in pre-charged equipment amounted 

in 2008 to ca. 8,000 tonnes and imports of F-gas contained in pre-charged equipment are 

about 8,700 tonnes. Imported quantities of F-gases contained in pre-charged equipment 

represent almost 13% of the total import of bulk F-gases covered under reporting obligations. 

Export of F-gases contained in pre-charged equipment represents ca. 42% of the exported 

quantities reported under Article 6(1). 

While imports and exports of quantities contained in pre-charged equipment balance each 

other almost out in absolute quantities, when taking into account the composition of imported 

and exported quantities by individual F-gas types, an additional layer of information becomes 

evident: Due to the high GWP of SF6, the emission potential from F-gases contained in 

exported pre-charged equipment is higher than the emission potential of imported 

equipment. For the future, however, F-gases in imported pre-filled air conditioning systems 

will significantly grow in quantities314. 

Reported data on F-gas quantities produced, imported and exported according to Article 6 

currently do not allow calculation of banks. Hence future potential emission might be 

underestimated and could lead to decisions based on incomplete information. 

If F-gas quantities contained in imported and exported pre-charged equipment would be 

included in reporting obligations, a more detailed overview of F-gas banks could be possible. 

• Review of the one-tonne threshold 

The reporting obligation under Art 6(1) covers only entities which produce and/or import 

and/or export more than one metric tonne per year of F-gases or preparations containing Fgases. This one tonne limit hardly distorts the total data outcome as discussed in chapter 

4.2.7. 

• Introducing reporting obligations for reclamation and destruction of F-gases by 

specialized facilities 

Under Art 6, producers, importers and exporters are required to report quantities of F-gases 

recycled, reclaimed or destroyed. However, data on the actual extent of destruction of 

recovered F-gases in the Member States are available to very limited extent only since the 

largest share of destruction is undertaken by entities which do not produce or import or 

export, at specialised destruction facilities. 

 

314 For conceptual clarification of F-gases in imported and exported pre-filled equipment see 2.2.4. 
Chapter 8 Options for further EU action 245 

Reporting obligations for F-gases could be extended to F-gas quantities destroyed by 

destruction facilities and reclaimed by specialized entities in destruction or reclamation 

facilities in order to complete the data on F-gas banks and stocks in EU-27. In some Member 

States, reclaimed and destroyed quantities of F-gases are already subject to reporting and 

monitoring (cf. chapter 4.2.6) and help to control these waste streams. 

Reporting obligations for destruction facilities would be in line with provisions of the ODS 

Regulation (EC) No 1005/2009 (Art 27(5)). Since usually the same facilities are dealing with 

both ODS and F-gases it is assumed that established reporting schemes within destruction 

companies could be used at low additional cost. Costs for reporting by reclamation facilities 

will be higher since they are presently not subject to reporting provisions. 

• Specifying further the reporting systems which Member States need to 

establish under Art 6(4) with a view to evaluate long-term trend in leakage rates 

from certain applications 

Article 6(4) requires Member States to establish reporting systems for the relevant sectors 

with the objective of acquiring, to the extent possible, emission data. This provision remained 

unclear for some experts from authorities and industry, while others elaborated and 

established reporting systems allowing calculation of emissions in certain Member States. 

Within the assessment of the status of implementation and application of the F-gas 

Regulation (chapter 4.2.7), it has been considered that the provisions do not require the setup of new monitoring and reporting systems in addition to existing national systems for CRF 

reporting under the UNFCCC. Additional systems or tools were considered useful only if they 

allow verification of emission trends and emission factors over time. 

Examples for such systems are being planned or set-up in Hungary, Bulgaria, Lithuania, 

Estonia and Poland. Key component of these systems is a central database of all stationary 

refrigeration and air conditioning equipment with charges >3 kg. In this way, it is possible to 

determine the refrigerant bank in the country. Reporting obligations arise for operators of 

equipment, service companies, as well as reclamation and destruction facilities. It should be 

underlined that the establishment of such equipment inventories is rather costly and requires 

certain administrative efforts and time. As outlined, today only one Member State uses at 

least partially such a system for estimation of emissions (Hungary). 

In order to evaluate long-term trends of emission rates, in particular leakage rates of certain 

applications, another approach could provide useful information: The underlying assumption 

is that complete inventories of equipment and F-gas banks require comparably high effort to 

be established and maintained. 

At present, it can be assumed that data on banks and emissions exist at the level of 

individual installations only as recording provisions apply. The records (logbooks), in 

particular if kept electronically, could hence be used as basis for emission monitoring and 

calculation of emission factors. Instead of assessing the records of the entire equipment 

stock in a particular Member State, monitoring of banks and emissions could be based on a 

statistical sample survey over several years based on records of a certain number of 

selected installations. In this way, a reliable overview of the quantitative development of Fgas emissions and emission rates in the most important applications could be gained. 
Chapter 8 Options for further EU action 246 

It is estimated that such approach of a monitoring system based on statistical sample 

surveys would also fulfil the requirements of Article 6(4) at lower cost than the establishment 

and maintenance of a full equipment inventory in most cases. 

Article 6(4) could benefit from further specifications of such reporting systems which also 

take into account current experiences and knowledge gained in the countries where such 

databases have been developed. However, new and creative approaches should be 

possible, too. 

• Including additional gases in reporting provisions in the light of new gases 

being included in Annex I of the Regulation 

If additional gases are included in Annex I of the Regulation (see sub-option D-1), reporting 

requirements will need to be adjusted in order to take into account such change and to 

complement current provisions. 

HFCs (such as HFC-161 and HFC-152) and PFCs (PFC 9-1-18, c-C3F6) listed in the 4th IPCC 

AR, although not commonly used today, should be considered for inclusion in Annex I. 

SO2F2 (sulfuryl fluoride) was found to be covered by extensive monitoring and reporting 

requirements already. 

The use of HFC-1234yf and other unsaturated HFCs is presently not required to be reported 

since unsaturated HFCs are not listed in Annex I of the F-gas Regulation. It should be noted 

that GWP values for these substances have been published in peer reviewed scientific 

publications but were not included in any IPCC report yet (chapter 5). Unsaturated HFCs are 

being commercialized on a mass-produced basis, are likely to be used in mobile air 

conditioning systems of passenger cars this year (2011) and in other applications in the near 

future. As outlined in option D-1, in case an international HFC agreement will include 

unsaturated HFCs, monitoring and reporting of these substances will be required. However, 

as long as no such agreement exists, reporting of unsaturated HFCs is not suggested as 

projected emissions are rather low. 

The inclusion of NF3 in the reporting under the F gas regulation would also ensure a coherent 

approach across different legal instruments in the EU. As part of the proposal for the revision 

of Decision No 280/2004/EC concerning a mechanism for monitoring Community 

greenhouse gas emissions and for implementing the Kyoto Protocol on the monitoring 

(Monitoring Mechanism Decision)315, the Commission considers including NF3 in Member 

States reporting requirements for national greenhouse gas inventories. 

The EU also proposed to include a mandatory reporting requirement for NF3 and additional 

fluorinated gases for which the IPCC proposed GWPs in its 4th Assessment Report in the 

revision of the reporting guidelines for Annex I GHG inventories under the UNFCCC.316

It will be possible to integrate additional reporting requirements into existing national and 

European data collection and reporting schemes at comparably low cost in most cases. 

Whether additional undertakings would be subject to reporting obligations will depend on the 

decision which additional gases to include in Annex I. 

 

315 OJ L 49, 19.2.2004, p. 1. 316 UNFCCC 2010: Views on the revision of the UNFCCC Annex I reporting guidelines – submissions 

from Parties. FCCC/SBSTA/2010/MISC.7. 
Chapter 8 Options for further EU action 247 

• Update GWPs according to the latest Assessment Report by the IPCC 

Article 10(2)(k) requires the Commission to consider the amendment of the global warming 

potential of fluorinated greenhouse gases, taking into account technological and scientific 

developments and the need to respect industrial product planning schedules. 

The development of emissions in the scenario with measures in the period 1995-2050 have 

been recalculated by using different global warming potentials as listed by three IPCC 

Assessment Reports for each substance emitted (figure 8-1). 

Figure 8-1: Development of emissions in the WM scenario in 1995-2020 based on the same 

tonnage of F-gas emissions (black line) but calculated by using different values for the global 

warming potential according to the 2nd, 3rd and 4th IPCC Assessment Reports for each F-gas 

emitted. The F-gas Regulation refers to the values of the 3rd Assessment Report, while 

reporting under the UNFCCC and the Kyoto Protocol is currently based on values from the 2nd

Assessment Report. 

F-gas emissions are ca. 10% higher when calculated by referring to the values for global 

warming potentials from the latest IPCC Assessment Report (4th AR, 2007, top curve) than 

according to the current way of calculating by using values from the 3rd AR (2001, middle 

curve). 

An overview of changes of GWP values for common F-gases is provided in table 8-1. The 

global warming potentials of almost all types of F-gases have been increased in the 4th

Assessment Report. 
Chapter 8 Options for further EU action 248 

Table 8-1: Global warming potentials (GWP100) of common types of F-gases according to the 

3rd and 4th IPCC Assessment Reports 

Fluorinated greenhouse gas GWP100 from 3rd AR GWP100 from 4th AR 

HFC-23 12,000 14,800 

HFC-32 550 675 

HFC-43-10-mee 1,500 1,640 

HFC-125 3,400 3,500 

HFC-134a 1,300 1,430 

HFC-152a 120 124 

HFC-143a 4,300 4,470 

HFC-227ea 3,500 3,220 

HFC-236fa 9,400 9,810 

HFC-245fa 950 1,030 

HFC-365mfc 890 794 

PFC-14 (CF4) 5,700 7,390 

PFC-116 (C2F6) 11,900 12,200 

PFC-218 (C3F8) 8,600 8,830 

PFC-3-1-10 (C4F10) 8,600 8,860 

PFC-4-1-12 (C5F12) 8,900 9,160 

PFC-5-1-14 (C6F14) 9,000 9,300 

PFC-318 (c-C4F8) 10,000 10,300 

SF6 22,200 22,800 

The changes of global warming potentials are based on recent scientific findings on the 

contribution of each substance to atmospheric global warming, compared to CO2. 

Certain impacts of this option are to be noted: 

Blends with GWP just below 150 are currently being used for use in PU canned foams and 

novelty aerosols. By updating the GWP values referred to in the F-gas Regulation, these 

preparations could exceed the GWP 150 threshold and therefore fall within the scope of the 

relevant prohibition. 

Decision 2007/742/EC for the award of eco label to heat pumps relies on the GWP values 

used in the F-gas Regulation through a reference. It also foresees that the refrigerant 

contained in heat pumps should have a GWP <2,000 which allows the use of R-410A which 

was considered energy efficient. By updating the GWP values of the F-gas Regulation, R410A would have a GWP of 2,082. Consequently, heat pumps running on R-410A would not 

be eligible for the eco label any more. If appropriate, eco label criteria could be revised based 

on the TEWI principle and in line with ecodesign criteria. 

Sub-option D-3: Improve containment and recovery in certain sectors 

Existing containment measures such as regular leakage control by certified personnel, 

maintenance of records and installation of leakage detection systems apply to stationary 

refrigeration, air conditioning and heat pump equipment and fire protection systems (table 8-

2). Sectors subject to these provisions include commercial refrigeration, industrial 

refrigeration, stationary air conditioning, heat pumps and fire protection. 
Chapter 8 Options for further EU action 249 

Table 8-2: Overview of requirements for regular leakage control 

Frequency of leak checks of 

stat. equipment and systems 

System charge 

Normal 

System charge 

Hermetically sealed 

None <3 kg <6 kg 

Annually 

3 kg – 30 kg; 

30 kg – 300 kg 

if automatic leak detection 

system in place 

6 kg – 30 kg; 

30 kg – 300 kg 

if automatic leak detection 

system in place 

6 monthly 

30 kg – 300 kg; 

>300 kg if automatic leak 

detection system in place 

30 kg – 300 kg; 

>300 kg if automatic leak 

detection system in place 

3 monthly >300 kg >300 kg 

Equipment containing charges <3 kg of F-gases are exempt from these measures under 

existing provisions. With regard to the sectors identified to cause high F-gas emissions in 

future decades according to the model AnaFgas, this charge-based exemption is de-facto 

relevant for room air conditioning equipment (average charge of movables: 0.75 kg; average 

charge of single split systems: 1.5 kg), for domestic heat pumps (average charge: 2.6 kg), 

and for a large number of commercial condensing units. 

With regard to recovery, the scope of current provisions does not refer to minimum charges 

and the requirements apply generally for stationary equipment listed in Article 4(1) as well as 

products and equipment, including mobile equipment unless it is serving military operations, 

to the extent that is technically feasible and does not entail disproportionate cost (Article 

4(3)). 

Certain sectors are also covered by recovery provisions set out by other pieces of European 

legislation (table 8-3). 

Table 8-3: Overview of EU legislation with regard to RRRD for sectors relying on F-gases 

Legislative act Sectors/applications covered by provisions on RRRD 

WEEE Directive Treatment before disposal of 

- waste household appliances and small commercial refrigeration 

equipment containing ODS or gases with a GWP >15; 

- separate collection and treatment of ODS in accordance with 

Regulation 1005/2009; 

- refrigerants and foam contained in appliances. 

ELV Directive Before further treatment of end-of life vehicles, removal of 

- CFCs and HFCs contained in air conditioning systems. 

Waste Directive 2008/98/EC Recovered F-gases are considered hazardous waste, which is 

addressed by certain waste management measures. Collection, 

transportation, treatment and disposal must be carried out in a way 

that protects human health and the environment. Hazardous waste 

must not be mixed with other wastes. At least 70% of construction 

and demolition waste (by weight) will be recovered by 2020. 

- Implications for construction foams containing ODS and HFCs. 

As pointed out earlier (chapter 2; chapter 4.2.6), data on recovered quantities of F-gases and 

their mass flow are also rare: Quantities recovered on-site and used for recycling are not 
Chapter 8 Options for further EU action 250 

registered in any statistics but should be recorded in the logbooks specific to each system. 

Little statistical information is available on F-gas quantities reclaimed or destroyed as 

reporting provisions do not apply to specialized reclamation and destruction facilities that 

would be able to provide this kind of information. 

Little evidence for any current effectiveness of containment and recovery measures since 

2006 has been found and quantitative data are widely lacking (chapter 4.2.6). Furthermore, 

the wording of both containment and recovery provisions remains vague about measures 

considered “technically feasible and do not entail disproportionate cost” and should be 

supported by additional guidance on these aspects. 

Therefore, several sub-options to improve containment and recovery have been identified: 

D-3.a) Extending the scope of Articles 3 and/or 4 to transport modes; 

D-3.b) Lowering the applicable F-Gas charge threshold of certain equipment already covered 

by Article 3; 

D-3.c) Extending the training and certification requirements to personnel undertaking 

activities not currently covered by Article 5; 

D-3.d) Introducing maximum leakage rates in certain applications; 

D-3.e) Introducing obligation for producers and suppliers of F-gases to take back recovered 

F-gases for reclamation and destruction. 

a) Extending the scope of Articles 3 and/or 4 to transport modes 

Article 10(1) requires the Commission to consider the extension of the provisions of Article 3 

to air conditioning systems, other than those fitted to motor vehicles referred to in Directive 

70/156/EEC, and refrigeration systems contained in modes of transport. 

A recent study317 investigated whether the provisions of Article 3 and/or Article 4(1) of the Fgas Regulation should be extended to the following sectors: 

- Refrigerated road transport: vans (<3.5 t), trucks (>3.5 t), trailers (classification 

according to Directive 70/156/EEC); 

- Rail transport: trains (railway vehicles, metro, trams); 

- Maritime and inland waterway transport: sea-going merchant ships, ships for 

refrigerated cargo, fishing vessels, inland navigation vessels. 

In a business as usual scenario, emissions of F-gases from these sectors in 2020 were 

estimated. Emission reduction potentials and costs of the measures of Art 3 and 4 were 

calculated and compared for each sector. 

Calculations based on data of the model AnaFgas were undertaken in order to reconsider 

the assessment of the 2008 study for the European Commission. 

The sector specific costs for containment and recovery measures according to Articles 3 and 

4(1) were taken from the service cost table in annex II and were used for a detailed 

 

317 BIPRO 2008: Study on the potential application of Art 3 and 4(1) of Regulation (EC) No 842/2006 

on certain fluorinated greenhouse gases to air conditioning and refrigeration systems contained in 

different transport modes. Final report, prepared for the European Commission, DG Environment. 
Chapter 8 Options for further EU action 251 

comparative analysis of sector-typical systems not subject to measures (reference) and the 

same systems in the sub sectors concerned when the measures of Articles 3 and 4(1) are 

applied318. In the sub sector of refrigerated vans (av. charge 1.5 kg), only the application of 

Art 4(1) is considered. The calculations are shown in sector sheets 7-9, and 17-19 (in annex 

V). Based on these datasets, potential emission reductions and abatement costs for these 

sectors currently not covered by certain containment provisions were calculated. The 

classification of sub sectors is more detailed in AnaFgas which distinguishes the road 

vehicles into vans and trucks & trailers319, but the following table 8-4 groups the sub sectors 

into the structure applied in the BIPRO assessment in order to facilitate reading. 

Inland waterway vessels are not considered because emissions are negligible. 

Table 8-4: Emissions from the relevant sectors in the WM scenario (identical with WOM 

scenario), emission reduction potentials of the application of Articles 3 and 4(1) to these 

sectors (kt CO2 eq) (option D-3a) and abatement costs (€/t CO2 eq) in 2030 

Sector Sub sector WM 

Emissions 

2030 

(kt CO2 eq) 

Option D-3a 

Reduction 

potential 

(kt CO2 eq) 

Marginal 

Abatement 

costs 

(€/t CO2 eq) 

Marginal 

Abatement 

costs 

according 

to BIPRO 

study 

(€/t CO2 eq)

Vans 421 11 291 Refrigerated 

road transport Trucks and 

trailers 3,646 1,430 46 119 

Rail 

transport 122 16 340 1,413 

Cargo ship 

AC 684 273 10.5 

Passenger 

ship AC 1,015 405 8.5 Maritime 

transport 

Fishing vessel 

refrigeration 906 360 0.5 

22 

Total 6,795 2,494 - - 

GWP values of IPCC 4th AR. Option D-3a includes the first time application of Articles 3+4(1) to 

sectors for which the F-gas Regulation (WM) does not apply yet. In the sub sector of refrigerated vans 

(av. charge 1.5 kg), only application of Art 4(1) is assumed (not Art 3). 

Estimated annual emissions, emission reductions and cost data differ from the 2008 

calculations of the BIPRO assessment320, but are of the same order of magnitude and 

confirm in principle the BIPRO findings: 

 

318 It should be mentioned that the cost of Art 3 include only those leakage checks that are carried out 

in addition to the state without F-gas Regulation. The estimated percentage of existing leak checking 

compared to requirements by Article 3 is listed in the cost table in annex II. 

319 Assumptions in AnaFgas on average charges of refrigerated vans are 1.5 kg and 6.5 kg of 

refrigerated trucks and trailers. 

320 This is due to several methodological aspects: 

- The annual containment & recovery costs are lower in AnaFgas. 

- BIPRO does not distinguish refrigerated road vehicles into vans and trucks &trailers. 

- In emission calculations, the GWP values according to IPCC 4th AR were applied. 

- Calculations of emissions and emission reduction potentials refer to the year 2030. 

- In the WOM scenario certain parameters such as charges and leakage rates remain 

unchanged while BIPRO assume gradual decrease of charges and leakage rates.
Chapter 8 Options for further EU action 252 

• Marginal abatement costs for containment and recovery measures in the maritime 

transport sector (AC systems in cargo ships and passenger ships, refrigeration systems in 

fishing vessels) are comparably low. 

• Marginal abatement costs for containment and recovery measures in the rail sector are 

comparably high. 

• Marginal abatement costs for refrigerated road transport vary depending on the charge 

size of the system. In the sub sector of refrigerated trucks & trailers the cost per t CO2 eq 

are €46. In the sub sector of refrigerated vans, where Art 3 does not apply (charge <3 kg) 

the application of Article 4(1) causes small emission reductions, resulting in high marginal 

abatement cost of € 291/tCO2 eq. As a consequence, we do not consider refrigerated 

vans in further assessment. 

The calculations based on the model AnaFgas and the assumptions made within this project 

largely confirm the findings of the BIPRO assessment undertaken earlier on behalf of the 

European Commission. Under Option D-3a, application of Art 3 and 4 to mobile equipment 

including refrigerated road vehicles, fishing vessels, and air conditioning of railcars and seagoing ships could reduce projected emissions of 6,785 kt CO2 eq in 2030 (WM scenario) by 

2,494 kt CO2 eq (36%) to 4,301 kt CO2 eq321. 

b) Lowering the applicable F-gas charge threshold of certain equipment already 

covered by Article 4(1)

The scope of containment provisions could potentially be extended to applications containing 

charges <3 kg. Some Member States have introduced minimum charges <3 kg nationally, 

such as France (2 kg), Denmark (1.5 kg). In this way, additional equipment could be subject 

to containment measures which currently apply to equipment containing charges 3 kg of Fgases (6 kg for hermetically sealed systems). 

In the model AnaFgas, there are five stationary F-gas application sectors with average 

system charges <3 kg: domestic refrigerators, hermetic commercial refrigeration equipment, 

moveable air conditioners, single split air conditioners, and domestic heat pumps. 

Refrigerators, commercial hermetics and moveable air conditioners are factory sealed 

(“hermetically sealed”) which implies that threshold charge size for these systems is 6 kg. 

All systems, whatever the threshold, are subject to Article 4(1) which makes recovery by 

certified personnel mandatory. Accounting for this, the model AnaFgas assumes for the WM 

scenario a considerable reduction in disposal emission factors for the five sectors which 

takes place gradually in the period 2010-2015. 

Table 8-5 shows for these sectors average charges and projected emissions in 2030 in the 

WOM and WM scenarios (Article 4(1)), annualised recovery cost (end-of-life322), the specific 

 

321 The emissions reduction is slightly lower if rail vehicles will be subject only to Art 4(1) as BIPRO 

suggested. 

322 In this study, recovery generally means recovery at end-of-life. The term recovery is broader in the 

F-gas Regulation (see definition in Art 2 and chapter 4.2.6) and includes all removal from equipment, 

even in the use-phase, e.g. on service. So far, no method exists for a clear distinction of removal 

emissions in the use-phase from the total of use-phase emissions. In the model AnaFgas all 

emissions in the lifetime are considered use-phase emissions. This approach is deemed justified the 

more so as the containment measures of Art 3 of the F-gas Regulation by certified personnel imply 
Chapter 8 Options for further EU action 253 

emission abatement cost in €/t CO2 eq, and the total cost arising to the operators in the 

sectors from application of Article 4(1). 

Emissions and charges are taken from the model AnaFgas. The annualised costs of the oneoff recovery measure are divided by the lifetime resulting in cost of service in €/year (4th

column), for detailed calculation see service cost table in annex II. Based on a hourly working 

rate for recovery of €50, the annualised cost for split air conditioners is €5.0, for heat pumps 

is € 3.33, for hermetic commercial refrigerators and moveable air conditioners is €2.50. Oneoff recovery costs for the domestic refrigerators are estimated very low, at €1.50 which is 

€0.10 per year (lifetime is 15 years). This assumption is related to the provisions of the 

WEEE Directive (collection systems) (see table 8-3 on European legislation). 

The marginal abatement costs per t CO2 eq are estimated based on the detailed comparative 

analyses of sector-typical systems, which are displayed in the EU sector sheets 1, 2, 10, 11, 

16 in annex V to this report. 

The calculation of the WM sector cost, i.e. the cost arising to the operators of the systems in 

2030, follows a different approach. AnaFgas includes the annual number of units for 

decommissioning in each sector. Multiplication of these numbers of units with their one-off 

recovery cost (not the cost in column 4 which represent the one-off recovery cost already 

divided by the lifetime years) results in the sector cost in the last column to the right (col. 6). 

Table 8-5: WM scenario: Emissions reduction potential and costs of application of Art 4(1) to 

the five sectors with average charges <3 kg/6 kg (reference year 2030) – according to AnaFgas 

Sector

1. 

average 

charge 

(kg) 

2. 

2030 WOM 

emiss. 

(kt CO2 eq) 

3. 

2030 WM 

emiss. 

(kt CO2 eq) 

4. 

WM Art 

4(1) 

service 

(€/year) 

5. 

WM 

Marginal 

abatement

cost 

(€/t CO2 eq) 

6. 

WM 

sector costs 

(M€/year) 

Domestic 

refrigeration 0.12 15 12 0.10 87 2.7 

Commercial 

hermetics 0.40 266 149 2.50 125 5.7 

Moveable AC 0.75 4,366 2,781 2.50 46 34.3 

Split AC 1.5 33,569 22,970 5.00 46 96.7 

Heat pumps 

(ground source) 2.4 3,577 2,713 3.33 29 9.7 

Total 41,793 28,625 149.2 

The total emissions under the WM scenario are 28,625 kt CO2 eq which is a reduction 

relative to the WOM scenario by 13,168 kt CO2 eq. The specific abatement costs €/t CO2 eq 

are moderate for heat pumps and moveable and split air conditioners, with €29 and €46 (2x), 

respectively. 

It should, however, be noted that the marginal abatement cost for commercial hermetics and 

domestic refrigerators are higher and amount to 125 €/t CO2 eq and 87 €/t CO2 eq. 

 

diligent handling of refrigerants and thus prevention of release to the atmosphere to the extent 

possible. 
Chapter 8 Options for further EU action 254 

The total costs of the application of Art 4(1) that arise in the year 2030 to the operators/endusers in the five sectors amount to €150 million, on condition that the recovery scheme has 

completely been established. These costs do not account for the fact that recovery had been 

carried out to some extent prior to the F-gas Regulation323. Therefore, the additional cost to 

the operators is lower than €150 million. It should be noted that in the large sector of split 

room air conditioners appropriate end-of-life treatment had not been well-developed before 

2006 (it virtually did not exist). Another uncertainty refers to the state of application of Article 

4(1) to such small systems in EU-27. 

Additional application of Article 3 (Option D-3b) to the five sectors would significantly 

increase the expenditure on working time and, consequently, the costs to the sector 

operators, while savings in refrigerant refill which arise from reduction in use-phase 

emissions are not very high. Anyway, domestic and commercial refrigerators, and factory 

sealed (moveable) air conditioners are not refilled in the use-phase. The extremely high cost 

increase can be seen in table 8-6. 

The 1st data column is the same as in the previous table. However, the 2nd column shows the 

emissions that would arise if additionally the measures of Art 3 (regular leak checks, 

recording) apply. The new emissions total 21,171 kt CO2 eq in 2030 which is 7,455 kt CO2 eq 

less than in the WM scenario (table 8-5, col. 3). 

In column 3 and 4 of table 8-6, for the five sectors the annualised service costs for 

application of Article 4(1) and for application of Art 3 alone are shown in € per year (data are 

taken from the cost list in annex II). Column 5 reveals the marginal abatement cost of the 

additional application of Article 3 (regular leak checks) to the systems with charges <3 kg. In 

the last column to the right the additional costs to the operators in the five sectors are listed, 

in million € per year. 

Table 8-6: Application of Art 4(1) and Art 3 to the five sectors with average system charges 

<3 kg/6 kg (reference year 2030) in a WAM scenario – according to model AnaFgas 

 

Sector

1. 

average 

charge 

(kg) 

2. 

WAM em

(Art 3+4(1)) 

in 2030 

(kt CO2 eq) 

3. 

WM 

Art 4

service 

(€/year) 

4. 

Option D-3b 

Art 3 

service 

(€/year) 

5. 

Art 3 add. 

abatement 

cost 

(€/t CO2 eq) 

6. 

Option D-2b

add. cost 

(M€/yr) 

Domestic 

refrigeration 0.12 11 0.10 67 324,722 186.4 

Commercial 

hermetics 0.40 136 2,50 70 29,575 402.6 

Moveable AC 0.75 2,137 2.50 72 3,707 2,474.1 

Split AC 1.5 16,913 5.00 132 2,015 12,731.8 

Heat pumps 

(ground source) 2.4 1,974 3.33 127 2,204 1,237.2 

Total 21,171 1.67 17,032 

The additional decrease in emissions from 28,625 (WM) to 21,171 (WAM), by 7,455 kt CO2

eq, from additional application of Art 3 to the five sectors is very expensive. The total costs to 

 

323 This is different for domestic refrigerators, where the assessment of the costs of Art 4(1) accounts 

for the fact that the equipment has already been subject to the WEEE Directive. 
Chapter 8 Options for further EU action 255 

the operators would rise from €150 million per year (Art 4(1) only) to €17.0 billion (17,032 

million). This is a result of the quite high abatement cost per t CO2 eq which range from 

€2,015 (split air conditioners) to an extremely high value of €324,722 for domestic 

refrigerators. The high calculated marginal abatement costs are a consequence of the low 

absolute emissions which arise from low-charged systems, and the low absolute emission 

reduction which can be achieved by annual leak checking. 

The relation of additional cost to additional emission savings, i.e. WAM vs. WM scenario, is 

somewhat improved if the minimum charge for the application of Article 3 would not 

completely be omitted but lowered from 3 kg/6 kg to 1 kg in order to include only heat pumps 

and split air conditioners. In that case the emission reduction would be 6,796 kt CO2 eq 

(WAM vs. WM) and the specific abatement cost would be lowered to values between € 2,000 

and € 3,700/t CO2 eq. 

Alternatively, a minimum charge of 2 kg which would de-facto limit the extension of 

provisions in Article 3 to heat pumps would not lead to significantly higher emission reduction 

vs. the WM scenario. The emission reduction potential would be 740 kt CO2 eq. 

In conclusion, the extension of Article 3 of the F-gas Regulation to systems with HFC 

charges <3 kg could decrease the 2030 emissions from the affected sectors by up to 7,455 kt 

CO2 eq, compared to the WM scenario. However abatement costs would be extremely high. 

c) Extending the training and certification requirements to personnel undertaking 

activities not currently covered by Article 5 

The requirements for certification of personnel and companies according to Art 5 are 

established by several Commission Regulations setting out minimum requirements and the 

conditions for mutual recognition of certificates by Member States324. 

Certification of personnel is a prerequisite for careful execution of containment measures 

(Article 3) such as regular leakage checks, and recovery (Article 4). Member States must 

ensure that the companies involved in carrying out these activities only take delivery of Fgases if the relevant personnel hold the personnel certificates. 

Based on examples from different Member States and suggestions from experts and 

stakeholders, the extension of the training and certification requirements set out by Article 5 

to personnel undertaking certain activities not presently covered by the provisions, is 

considered. 

Examples from Member States refer mostly to mobile F-gas applications: 

- Personnel recovering F-gases from all types of mobile refrigeration and mobile air 

conditioning equipment containing charges >3 kg of F-gases (Sweden). 

- Personnel undertaking installation, maintenance, servicing and any other activities 

related to refrigerants contained in AC systems in motor vehicles (Hungary; Sweden). 

 

324 Certification requirements (cf. chapter 4.2.2) apply in the stationary refrigeration, air conditioning 

and heat pump sector (303/2008), the fire protection sector (including fire extinguishers for recovery 

only) (304/2008), the high-voltage switchgear sector (305/2008), the sector of F-gas based solvents 

(306/2008) and the MAC sector (307/2008). Member States are required to establish training and 

certification programmes for the sectors listed above and to notify these schemes to the Commission 

(308/2008). 
Chapter 8 Options for further EU action 256 

- Attestation could be changed to certification based on an exam according to 

Commission Regulation (EC) No 307/2008 (Germany, Netherlands, Spain) in order to 

streamline the provisions for the MAC sector with those for other sectors. 

Furthermore, existing exemptions from certification requirements e.g. for personnel 

undertaking brazing, soldering or welding in the stationary refrigeration, air conditioning and 

heat pump equipment (Regulation (EC) No 303/2008, Article 4(3b)), could be potentially 

revised in order to improve leak-tightness of permanent joints. However, the F-gas 

Regulation is at different stages of implementation and application in the Member States 

(chapter 4), where conditions for professional education and qualification vary largely. It is 

hence considered that additional certification requirements can be established at national 

level in order to account for national circumstances. 

d) Introducing maximum leakage rates in certain applications

Article 10(2e) requires an assessment whether maximum leakage rates for installations could 

be established. Full implementation, application and control of existing containment 

measures according to Article 3 are considered prerequisites for this measure. The control of 

leakage rates would need to rely on the information gathered in the records required by Art 

3(6) since they are specific for each system. 

From a legal point of view, the establishment of maximum leakage rates would lead to clear 

identification of leaks and hence provide an additional tool for control and enforcement of 

containment measures resulting in F-gas emission reductions. 

Maximum leakage rates have been set through international and European standards in the 

fire protection sector (ISO 14520325, adopted as EN 15004326) and the high voltage 

switchgear sector (IEC TR 62271-303327), and anticipated the measures introduced by the Fgas Regulation. 

In the refrigeration and air conditioning sector, a number of standards also relate to leakage 

of stationary refrigeration and AC systems: For example, EN 378 provides minimum 

tightness of systems and frequencies for maintenance and EN 16084 refers to tightness of 

components and joints. The number of personnel and companies applying these standards is 

unknown although it is likely that most large companies do follow them. Nevertheless, the 

impacts of these standards on reductions of emissions from stationary refrigeration and air 

conditioning systems have not been evaluated yet and hence cannot be quantified reliably. 

As outlined in chapter 4.2.5, compliance with the containment measures of the F-gas 

Regulation varies largely in the refrigeration and air conditioning sector and is relatively low 

in small companies. It is hence likely that small companies operating refrigeration and air 

conditioning equipment would be less compliant with maximum leakage rates than large 

companies, no matter whether these were established through a regulation or a standard. 

The identification of national policies in the Member States stricter than provisions of the Fgas Regulation has shown that currently 3 Member States implemented maximum leakage 

rates for stationary refrigeration and air conditioning equipment containing F-gases: 

Germany, Belgium, and Luxembourg. 

 

325 ISO 14520: Gaseous fire-extinguishing systems – physical properties and system design. 326 EN 15004: Fire extinguishing systems – Components for gas extinguishing systems. 327 IEC TR 62271 High voltage switchgear and control gear – Part 303: Use and handling of sulphur 

hexafluoride (SF6) (2008) defines tightness classes of equipment and sets maximum leakage rates. 
Chapter 8 Options for further EU action 257 

Belgium and Luxembourg have established maximum leakage rates of generally 5% in order 

to establish the basis for a definition of leakage. An evaluation of these rates and related 

compliance is not available. 

Maximum leakage rates for stationary refrigeration and air conditioning equipment containing 

F-gases in Germany are based on a national standard agreed by industry and were 

established in August 2008 (table 8-7). 

Table 8-7: Maximum leakage rates for stationary refrigeration and AC equipment in Germany 

Certain disadvantages of the German standard on maximum leakage rates have been 

identified: 

- Maximum leakage rates apply during normal operation of equipment and do not 

include losses of refrigerant during accidents and other damage. Hence regular 

leakage could be excluded from the calculation of the leakage rates by declaring the 

quantities emitted during equipment damage in the records. 

- Technical problems in accurately determining low leakage rates by common leak 

detection systems and devices. Currently no standards are known allowing the 

calibration of leak detectors and demonstrating compliance of the detector with the 

provisions of Regulation (EC) No 1516/2007 (Article 6). Most of the current standards 

are vacuum standards which cannot be considered appropriate under other 

circumstances. 

- Compliance with the rates set out by legislation in Germany was reported by certain 

industry experts to be not possible on a large scale, even if all available measures to 

improve containment were taken because the rates were unrealistically low in 

practice. 

- Maximum leakage rates do not relate to the refrigerant used and its GWP although 

high losses of a substance with high GWP causes higher global warming emissions 

than leakage of a refrigerant with low GWP. 

- The maximum leakage rates do not encourage the use of equipment with low charges 

of F-gases. Hence the establishment of large F-gas banks is still supported. 

No analysis of the status of implementation and compliance of industry with the maximum 

rates set out in Germany has been undertaken so far. 

It should be noted that maximum leakage rates for certain applications could help to define 

leakage as compared to bad service practices. However, the choice of maximum leakage 

rates would need to be supported by experiences on best practices and determination of 

such rates. No information on the actual impact of maximum leakage rates on F-gas 

emissions has been available to this point which does not allow considering this measure as 

an effective instrument to reduce F-gas emissions. Therefore, this sub-option is not followed 

further in the screening and comparison of options in this work. 

Charge Date of manufacture of equipment 

Before 30/06/2005 01/07/2005 - 30/06/2008 After 01/07/2008 

<10 kg 8% 6% 3% 

10-100 kg 6% 4% 2% 

>100 kg 4% 2% 1% 
Chapter 8 Options for further EU action 258 

e) Introducing producer responsibility schemes for reclamation and destruction of 

F-gases

A recent study328 recommends producer responsibility schemes to promote recovery and 

appropriate treatment of used F-gases. It is suggested that HFC producers could offer takeback programs for unwanted chemicals for the purpose of reclamation or destruction to allow 

users to return unwanted F-gases at low or no cost to producers via distributors. It is also 

outlined that chemical producers would be able to reclaim the used F-gases more costeffectively than they could produce virgin chemicals, which could then be sold within the EU 

or abroad. This finding, however, has not been confirmed by industry experts contacted 

within the current project who pointed out that reclamation of used F-gases was rarely 

possible for technical reasons and linked to high costs of the reclamation process. Reclaimed 

gases are usually added to virgin chemicals of the same type and are not placed on the 

market separately329. 

The introduction of obligations for producers and suppliers of F-gases to take back used Fgases for reclamation and destruction would be in line with EU waste legislation which 

supports producer responsibility schemes in order to promote life-cycle thinking and the 

integration of environmental costs into the price of products (e.g. WEEE Directive). 

Germany has introduced an obligation for producers and suppliers of F-gases to take back 

recovered F-gases for reclamation and destruction in national legislation in 2009 in order to 

set out clear responsibilities for users of F-gases. It is estimated that returned quantities of Fgases have not significantly increased yet due to the short time since entry into force of the 

legislation. Quantitative data are available to very limited extent at present. It should be noted 

that service companies returning F-gases to distributors or producers have to pay fees of ca. 

€4/kg depending on the quantities and levels of purity of the gases. Distributors and 

producers subsequently decide whether the returned gases can be reclaimed by the 

company itself, or need to be destroyed in specialized destruction facilities. It is considered 

likely that the fee to be paid by service companies limits their efforts to return recovered Fgases for reclamation. Costs also apply when recovered F-gases are delivered directly to 

destruction facilities: Destruction facilities charge fees of around €2/kg of F-gases returned. 

In other countries, no-cost schemes for recovered refrigerants are established and funded 

e.g. via taxes on import and production of F-gases as well as products and equipment 

containing F-gases or deposit-refund schemes apply (see options E-2 and E-3). 

Due to the variety of existing approaches and the differences of market structures between 

Member States, it is considered that producer responsibility schemes may be appropriate if 

implemented at national level. When introducing such schemes, experiences from existing 

schemes in other Member States should be taken into account, in particular with regard to 

mechanisms to minimize costs for service companies to return used gases in order to 

effectively promote recovery for reclamation and destruction and overcome costs passed to 

consumers. 

 

328 ICF International: Identifying and Assessing Policy Options for Promoting the Recovery and 

Destruction of Ozone Depleting Substances (ODS) and Certain Fluorinated Greenhouse Gases (Fgases) Banked in Products and Equipment; Final Report prepared for the European Commission, May 

2010; p. 58.

329 Communication via telephone and email with Westfalen AG and TEGA, Germany. 
Chapter 8 Options for further EU action 259 

Sub-option D-4: Ban the use and/or the placing on the market of open F-gas 

applications 

Article 10(2)(j) requires the Commission to consider the inclusion of further products and 

equipment containing fluorinated greenhouse gases in Annex II to the Regulation, taking 

account of energy-efficiency. 

Current measures for the control of use (Art 8) refer to SF6 and preparations thereof in 

magnesium die casting relying on quantities of SF6 >850 kg/year and in the filling of vehicle 

tyres. Bans of placing on the market (Article 9) apply to products and equipment containing 

F-gases as listed in Annex II: Non-refillable containers, non-confined direct evaporation 

systems containing refrigerants, fire protection systems and fire extinguishers containing 

PFCs, windows, footwear, tyres, one-component foams (except when required to meet 

national safety standards) and novelty aerosols. 

These bans have already effectively reduced emissions from these sectors and applications 

(see chapter 5.2.2) and are included in the WM scenario of the model AnaFgas. Additional 

bans could potentially address additional open applications of F-gases in order to achieve 

further emission limitations. 

a) Use of SF6 in magnesium casting 

The use control of SF6 for die casting in plants with annual SF6 use >850 kg leads to 

reduction in emissions from the magnesium casting sector of 1,452 kt CO2 eq by 2030 

(calculation AnaFgas). Remaining emissions from the sector are projected to range at 625 kt 

CO2 eq in 2030. 

In this context, Article 10 requires an assessment whether the substitution of SF6 is 

technically feasible and cost-effective in the entire sector which includes not only die casting 

in plants with SF6 use <850 kg/year but also sand casting and the recycling of die casting 

and sand casting alloys. A study of this matter was undertaken in 2009330 and resulted in the 

following findings: 

• Technical options to reduce SF6 emissions by containment, recovery, or substitution 

are not currently feasible in two sub sectors of the magnesium industry in Europe 

including magnesium sand casting and recycling of special magnesium alloys, which 

are used in sand casting. 

• For magnesium die casting a full ban of the use of SF6 was recommended. 

• For recycling of magnesium die casting alloys a ban of the use of SF6 was 

recommended. 

Abatement costs and reductions of F-gas emissions in magnesium die casting (<850 

kg/year) were found to vary according to the substitute chosen, either HFC-134a or SO2. In 

recycling of magnesium die casting alloys, only one alternative is the likely technical 

alternative choice: SO2. Abatement costs and emission reductions of recommended options 

are summarized below (table 8-8). 

 

330 Öko-Recherche 2009: Service contract to assess the feasibility of options to reduce emissions of 

SF6 from the EU non-ferrous metal industry and analyse their potential impacts; Final Report, 

prepared for the European Commission. 
Chapter 8 Options for further EU action 260 

Table 8-8: Abatement costs and emission reductions resulting from a use ban of SF6 in 

magnesium die casting (<850 kg/year) and recycling of magnesium die casting alloys (GWP 

from 4th IPCC AR), updated to reference year 2030 

Mg die casting Recycling of Mg die 

casting alloys 

Alternative SO2 HFC-134a SO2

SF6 emission reduction kt CO2 eq 171 160 85 

Net costs k€ 50 146 -19 

Abatement costs €/t CO2 eq 0.29 0.91 -0.22 

All operators of die casting and recycling plants are facing costs for new equipment. The 

annual savings from the application of the new cover gas, however, are in the same range. 

Therefore, on an annual basis the additional costs that arise to the operators are low, in the 

recycling of die casting alloys even negative. Emission reductions in magnesium die casting 

are lower in case of conversion to HFC-134a due to the global warming potential of HFC134a, which negatively impacts total emission reductions (difference of 11 kt CO2 eq). 

Ban and substitution of SF6 in magnesium die casting and recycling of die casting alloys 

results in maximum emission reductions from the magnesium sector by 256 kt CO2 eq in 

2030, below the 625 kt CO2 eq emissions from the total sector in the WM scenario. 

b) Open applications of HFCs

In the following sections, potential bans to the placing on the market non-medical aerosols as 

well as XPS and PU foam products are considered. 

Another open application of F-gases is metered dose inhalers (MDI) for the treatment of 

asthma and further respiratory diseases. The emissions in 2030 are projected at 3,450 kt 

CO2 eq (AnaFgas). Replacement of HFCs in this sector is excluded from subsequent 

assessment because this form of aerosols represents a use which requires special 

investigation by experts from the medical and pharmaceutical industry. 

The key abatement options with alternatives to HFCs in the European aerosol and foam 

sectors have been discussed in annex IV, V and VI and are presented in chapter 6 of this 

report. The analyses resulted in sector-specific emission abatement cost per t CO2 eq. This 

information, together with the reduction potential for the year 2030, is repeated here in 

tabular form (table 8-9). 

Table 8-9: Emission abatement potential and cost of switching to alternative options in 5 

sectors of open HFC-application 2030 

EU-27 – emissions abatement vs. WOM/WM scenario in foam and aerosols 2030 

Sub sectors XPS with 

134a 

XPS with 

152a 

Spray 

foam Other PU 

Nonmedical 

Aerosols 

emission abatement 

cost €/tCO2 eq 1.0 -1.6 61.6 3.5 10.0 

emission reduction ktCO2 eq 1,553 460 1,369 587 3,637 

Source: chapter 6.4 of this report, annex VI, and EU sector sheets 22-26 in annex V. 
Chapter 8 Options for further EU action 261 

The assessment of open F-gas applications (except for MDIs) which are not yet subject to 

the F-gas Regulation shows varying results. In technical aerosols, XPS foam and “other” PU 

foam applications specific abatement cost of 10 €/t CO2 eq or less could be achieved if 

available low-GWP alternatives to HFCs are introduced. 

The calculated abatement costs per t CO2 eq amount to €10.0 for technical aerosols, to €1.0 

for XPS with HFC-134a and negative costs for HFC-152a (€-1.6), and €3.5 for PU 

applications other than spray foam. PU spray foam is the largest PU sector using HFCs, but 

so far replacement of HFCs cannot be carried out with abatement cost below 50 €/t CO2 eq. 

In this sector social impacts must also be duly considered (prevalence of small enterprises). 

The maximum emission reduction potential amounts to 7,606 kt CO2 eq in 2030, if bans on 

HFCs are introduced in 2015 in all sectors. Without the PU spray foam application, the 

emission reduction potential in 2030 is reduced to 6,237 kt CO2 eq. 

As shown in annex V, EU sector sheets 22-26, 100% sector penetration rate of abatement 

options can be achieved by 2015 in all sectors except for the non-medical aerosol sector. 

Here, only 95% of HFC applications can be replaced by alternative propellant gases. A ban 

on HFCs as of 2020 is feasible if the remaining 5% can clearly be identified as exemptions. 
Chapter 8 Options for further EU action 262 

Sub-option D-5: Ban the placing on the market of certain closed applications 

containing F-gases where energy efficient and safe alternatives are available 

In chapter 6 alternative technologies to conventional HFC technology for the abatement of 

emissions are presented. Detailed data on the comparative calculations of sector typical HFC 

reference cases of the WM scenario and several replacement solutions are shown in the EU 

sector sheets in annex V to this report. 

The results include 

- HFC emissions in the WM scenario in 2030. 

- The individual penetration rates of alternative options in the years 2015, 2020, and 

2030 and the sector penetration mix of the alternative options in the same years, 

which provide important information for the feasibility of bans in these years. 

- The aggregated emission reduction potential in 2030, vs. WM emissions (kt CO2 eq). 

- The marginal abatement cost of the emission reduction by the aggregated alternative 

solutions (€/t CO2 eq). 

Table 8-10: Emission abatement cost and technically feasible reduction potential of switching 

to alternative options in closed systems of F-gas sectors and sub sectors of EU-27 (2030) 

Sector Sub sector Marginal 

emission 

abatement cost 

€/t CO2 eq 

Potential 

emission 

reduction 2030 

kt CO2 eq 

Domestic Refrigeration Refrigerators/Freezers 1.0 12 

Stand-alone systems -0.8 149 

Commercial Refrigeration Condensing units 1.2 3,927 

Centralized systems 23.7 14,741 

Small Industrial equipment -0.9 871 Industrial Refrigeration Large Industrial equipment -21.6 2,612 

Refrigerated Vans 45.1 421 

Transport Refrigeration Refrigerated Trucks 2.6 2,990 

Fishing vessels 3.4 425 

Rail vehicle AC 556.6 26 

Mobile Air Conditioning Cargo ship AC 16.7 320 

Passenger ship AC 35.0 125 

Moveable systems 8.9 2,781 

Split systems 19.0 22,970 

Multi split/VRF systems 13.1 2,827 

Rooftop systems 8.2 573 

Chillers (displacement) 5.9 2,512 

Centrifugal chillers 11.1 82 

Stat Air Conditioning 

Heat Pumps 130.2 2,282 

Fire protection HFC-227ea 22.3 440 Fire protection Fire protection HFC-23 3.1 961 

Electrical equipment MV secondary switchgear SF6 347.3 97 

Total 19.5 62,125 
Chapter 8 Options for further EU action 263 

At the end of chapter 6, the sector-specific abatement costs and the emission reduction 

potential for the year 2030 have been summarized in a Marginal Abatement Cost Curve 

(MACC). Certain sectors are repeated here (table 8-10), notably closed systems containing 

refrigerants and fire extinguishing agents, in order to discuss sub-option D-5. 

The total emission reduction potential by 2030 amounts to 62,125 kt CO2 eq. Reductions in 

individual sectors range from 12 kt CO2 eq (domestic refrigerators) to 22,970 kt CO2 eq (split 

room air conditioners). Abatement cost average €19.4, ranging from €-21.6 (large industrial 

refrigeration) to €347.3 (MV secondary switchgear) and €556.6 (rail vehicle air conditioning). 

The emission reduction potential which is shown in table 8-10 represents the technically 

feasible maximum by 2030. It arises under the condition that in every year since 2015 the 

market potential of alternative technical solutions is completely been utilised for new 

equipment. The market potential of most abatement technologies (their penetration rates) is 

considered to grow over time, but in many cases even their combination will not reach 100% 

before 2025-2030. Placing on the market bans, however, cannot follow gradually the growth 

trend of replacement solutions; they cannot be established before the penetration mix of 

alternative technologies has reached 100% or, if less, if the difference from 100% can clearly 

be defined for exemptions. 

In order to quantify the 2030 emission reduction specifically attributable to placing on the 

market bans, those sectors where the penetration mix is still below 100% in 2030 are 

excluded. In the remaining sectors a placing on the market ban is considered to be feasible 

in the year in which the penetration mix reaches 100% (or 95% with clearly definable 

exemptions). 

It must be noted that full replacement of F-gases in new equipment does not result in the 

immediate termination of emissions from the existing stock. Depending on the lifetime, usephase emissions and disposal emissions from closed systems continue arising for many 

years. The shorter the time from a ban year to the year 2030, the lower the specific emission 

reduction potential from the prohibition measure in 2030. 

Table 8-11 reveals that the emission reduction potential from feasible placing on the market 

bans is significantly lower than the technically feasible emission reduction potential shown in 

the preceding table 8-10. 
Chapter 8 Options for further EU action 264 

Table 8-11: Sub option D-5. F-gas emission reduction potential by 2030, resulting from placing 

on the market bans on closed systems, and first year of 100% market penetration of alternative 

technologies 

Sector Sub sector Potential 

emission 

reduction 2030 

kt CO2 eq 

Penetration rate 

mix 100% 

Domestic Refrigeration Refrigerators/Freezers 12 2015 

Stand-alone systems 147 2020 

Commercial Refrigeration Condensing units 2,849 2020 

Centralized systems 12,055 2020 

Small Industrial equipment 67 2030 (95%) Industrial Refrigeration Large Industrial equipment 202 2030 (95%) 

Refrigerated vans 421 2020 

Transport Refrigeration Refrigerated trucks/trailers 322 2030 

Fishing vessels Not 100% 

Rail vehicle AC Not 100% 

Mobile Air Conditioning Cargo ship AC 232 2020 

Passenger ship AC Not 100% 

Moveable systems 2,781 2020 

Split systems 22,970 2020 

Multi split/VRF systems 2,172 2020 

Rooftop systems 573 2020 

Chillers (displacement) 1,989 2020 

Centrifugal chillers 9 2030 

Stat Air Conditioning 

Heat Pumps 1,356 2020 

Fire protection HFC-227ea Not 100% 

Fire protection Fire protection HFC-23 961 2015 

Electrical equipment MV secondary switchgear SF6 Not 100% 

Total 49,119 

The 2030 emission reduction potential of placing on the market bans amounts to 49.1 Mt 

CO2 eq, which is 78.5% of the maximum technically feasible potential of 62.1 Mt CO2 eq. for 

closed applications. 

In five sectors 100% penetration rate mix is not achieved by 2030. In four sectors, amongst 

them small and large industrial refrigeration, the first year of a full penetration mix331 is 2030. 

As a result, the emission reduction in 2030 is still low for those sectors. In the sectors of 

stationary air conditioning, 2020 is mostly the year when the aggregated penetration rates 

can reach 100%. Because of 10 years lifetime, the emission reduction potential is fully 

utilised by 2030, which explains the high reduction potential of this sector. Split air 

conditioners alone account for 47% of the overall emission reduction potential by 2030 of this 

option. 

 

331 In industrial refrigeration a 95% penetration rate is forecast for 2030; the remaining 5% represent 

exemptions that can be defined. 
Chapter 8 Options for further EU action 265 

Sub-option D-6: Set quantitative limits for placing F-gases on the market in the 

EU-27 

In the previous section, bans of the placing on the market of F-gases in several open 

applications of HFCs and a large number of closed applications in refrigeration, air 

conditioning, and fire protection have been analyzed. The general question was: What is the 

emission reduction potential from not allowing the placing on the market a certain F-Gas 

containing application? 

Sub-option D-6 considers the establishment of quantitative limits for the supply of certain Fgases (HFCs). Demand is assumed to adjust to reduced supply to reach balance, thereby 

reducing emissions. 

The term supply which is used in sub-option D-6 includes not only bulk quantities to serve 

the demand for first fill on domestic manufacturing plus refill into domestically manufactured 

and imported equipment in the use-phase, but also the import of F-gases in pre-charged 

imported systems332. It must be noted that this supply also accounts the quantity of F-gases 

used as first fill in pre-charged systems for export from the EU, although emissions from 

these systems do not take place in the EU (and therefore are not accounted as EU emission 

reductions). The "supply" considered in this option is the second extension (supplyext2), which 

includes Production + Import – Export of bulk substances plus Import in pre-charged 

equipment333. Therefore, supply includes the sales of F-gases to the EU market both in bulk 

quantities and in imported equipment which is pre-charged in a third country. Demand of Fgases (HFCs) for first fill which is served by the supply includes 

(1) products manufactured in the EU for domestic use, 

(2) products manufactured and filled in the EU for export from the EU, and 

(3) products manufactured and filled in third countries and subsequently imported into 

 the EU. 

Although the option for quantitative limits for the supply of HFCs to the market in the EU 

ultimately relies upon the transition of the different F-gas using subsectors to alternative 

technologies like the ban options discussed above (sub options D-4b and D-5), the specific 

characteristics of sub-option D-6 is that it gives more room for manoeuvre to the actors 

involved. Under this option, maximum gradually declining ceilings for the total supply of 

HFCs to the EU market in bulk quantities as well as in products and equipment would be 

established until a final plateau (tail end) is reached. This option could be implemented by 

 

332 A possible exclusion of imported pre-filled equipment or products from sub-option D-6 would 

reduce the effectiveness of the option, especially in stationary air conditioning, which is the sector with 

the largest emissions from 2030 onwards, under the WM scenario. Split and multi split air conditioners 

and small moveable systems are imported with shares of 75%-90% from outside the EU, in particular 

from Asia. Domestic first fill is only carried out for the remaining 10%-25% of systems which are 

domestically manufactured. In 2015, the “first fill” for new installations which include all systems sold to 

the European market, including imported pre-filled equipment will exceed the first fill for domestic 

production and domestic on-site topping-up, by 19,200 kt CO2 eq (see table 8-13). The surplus will 

grow to even 27,200 kt CO2 eq until 2030, if the present ratio between importation and domestic 

production remains the same (data from model AnaFgas).

333 In full, the equation for the second extension of the term supply is: Supply ext2 = Production + Imports

(bulk) – Exports (bulk) – Feedstock – Destruction.+ Imports (pre-charged). See chapter 2.2.4. 
Chapter 8 Options for further EU action 266 

the establishment of a system for allowances to place HFCs on the EU market. This option 

would require to: 

• establish a system that allocates such allowances to the relevant undertakings. This 

system could either be a “grandfathering” system which applies to new equipment only, 

based on the amounts of HFCs that undertakings placed on the market in a recent historic 

year or during several years, or an auctioning system that annually auctions at EU level 

allowances to all undertakings that intend to place HFCs (including in products and 

equipment) on the market. 

• The design of a monitoring and verification system at EU level that monitors the amounts 

of HFCs placed on the market by undertakings in the EU. 

• The design of a compliance system that requires undertakings to submit allowances 

equivalent to their total annual placing on the market for the past year to the Commission 

where it is checked whether the submitted allowances cover the amounts placed on the 

market. The compliance system would include fines and consequences in case of noncompliance with the requirement to submit allowances for the amounts placed on the 

market. 

Use-phase emissions are part of the total emissions but are also covered by supply (sales) 

data since the use-emissions need to be replaced by refill quantities in most cases334. 

Therefore, measures reducing use-phase emissions limit directly the demand and at the 

same time indirectly the supply, and vice versa. 

Regulatory measures according to Articles 3 and 4 as well as 8 and 9 substantially differ in 

the quantitative effect on demand and supply reduction. While Article 4 provisions largely aim 

at minimizing disposal emissions at end-of-life of equipment, which do not affect the F-gas 

demand or supply at all, containment measures of Article 3 can reduce refill quantities and 

hence demand and supply, but not first fill quantities which are independent from leakage 

rates. 

Prohibition measures to closed F-gas applications according to Articles 8 and 9 can stop 

demand and supply for (domestic) first fill of equipment, but do not immediately stop the 

demand and supply for refill because servicing quantities are needed for existing equipment 

containing HFCs. However, the quantity for refills would constantly decrease over time until 

end-of-life of the equipment. Prohibition measures can hence be more effective than 

containment/recovery measures alone since they also avoid first fill and increase of banks. 

It should be noted that prohibition on the placing on the EU market of closed applications 

does not reduce the first fill for products which are manufactured for export to third countries. 

For instance, the ban of HFC-134a in mobile air conditioning of passenger cars applies to 

use within the EU only but not to production for third countries. In this report, it is not 

assumed that the use of HFC-134a is banned outside of the EU so that ca. 25% of the 

annual demand for first fill (current export quota) continues until 2030 and after. The same 

export quota applies to domestic first fill of mobile air conditioning systems of buses and 

trucks, for which we assume in this chapter a phase-out of HFC-134a from 2015 onwards, 

according to the EU sector sheets 28 and 29 in annex V. Such transition was not considered 

 

334 In model AnaFgas, factory-sealed systems containing small charges such as domestic 

refrigerators, commercial stand-alone equipment and factory-sealed air conditioners are not assumed 

to be refilled for their (small) leakage. 
Chapter 8 Options for further EU action 267 

as a sub-option in option D-5 since it could be implemented in the context of a revision of the 

MAC Directive. However, in this option, which includes all applications of HFCs regardless, 

the calculation of the HFC reduction potential of mobile air conditioning of trucks and buses 

becomes important and is therefore included. 

In this context, the quantification of possible supply limits relies on the analysis of the extent 

to which technically possible transitions away from current HFC technology, as described in 

annex VI and presented in chapter 6, could contribute to lower HFC demand and supply in 

EU-27. We ask: 

• In which subsectors transitions to low-GWP technologies can be achieved? 

• On that basis, to which levels can HFC supply be reduced? 

• On that basis, to which extent the direct reduction in HFC supply contributes to 

indirect reduction in emissions? 

The target year in this sub-option D-6 is again 2030, and 2015 has been chosen the first year 

for gradual introduction of available replacement solutions (technically feasible, costeffective, and energetically equivalent). F-gases other than HFCs are not considered in this 

option335. All stationary air conditioning equipment is considered wherever it is filled first. The 

mobile air conditioning sector includes in this option not only rail and ship AC systems but 

also AC systems contained in motor vehicles under the MAC Directive (passenger cars) and 

AC systems of buses and trucks which are currently not covered by the MAC Directive. 

HFC supply in EU-27. WM scenario 

excluding and including imported pre-filled systems 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050

ktCO 2eq

HFCs incl imported prefill HFCs for domestic fill+refill only

Figure 8-2: Supply of HFCs to EU-27 (kt CO2 eq) in the WM scenario (including application of Fgas Regulation and MAC Directive) in the period 2000-2050. The steep increase in 2010 results 

from the accelerated R-22 phase-out which is assumed to be implemented according to the 

Regulation (EC) No 1005/2009. The upper curve includes HFCs in pre-filled equipment from 

imports (supply ext2); the lower curve displays only supply of F-gases in containers, etc. for the 

European market (supply). Source: AnaFgas. 

 

335 The SF6 application sectors of magnesium casting and MV secondary distribution switchgear are 

not included in the discussion of sub-option D-6. 
Chapter 8 Options for further EU action 268 

Figure 8-2 and table 8-12 show the HFC supply from 1995 to 2050, according to AnaFgas, 

under the WM scenario. The WM scenario includes all provisions of the F-gas Regulation 

and the MAC Directive (phase-out of HFC-134a in AC systems in passenger cars). The 

quantitative difference between supply with and without HFCs in pre-filled imported 

equipment is shown in the table and is graphically displayed in the diagram. 

Table 8-12: Supply of HFCs in EU-27 (kt CO2 eq) in the WM scenario (F-gas Regulation and 

MAC Directive) in the period 2010-2050 – with and without pre-filled systems 

Year 2010 2015 2020 2030 2050 

Supply for domestic fill/refill 

(supply) 159,143 146,870 144,766 143,735 147,218 

Supply for HFCs in imported 

pre-filled systems 13,252 19,200 22,820 26,654 27,226 

Total demand incl. pre-filled 

imported systems (supply ext2) 172,395 166,070 167,586 170,389 174,444 

Source: AnaFgas

The supply of HFCs (which follows the demand) steeply rises from 2000 to 2012 driven by 

HCFC substitution. Afterwards containment and recovery provisions of the F-gas Regulation 

(Articles 3 and 4) start showing effects. The HFC supply (demand) would nevertheless 

considerably increase after 2012 without the MAC Directive, but the HFC-134a phase-out 

from passenger cars completely compensates the increase in the other sectors, in particular 

in stationary air conditioning. It must, however, be emphasized that between 2010 and 2050, 

there is no absolute reduction in HFC demand and supply of the EU-27. 

In the WM scenario, HFC demand ext2 totals ca. 170,400 kt CO2 eq in 2030. It can be related 

to eight sectors relying on HFCs: 

a. Closed stationary air conditioning (incl. import): 72,700 kt CO2 eq 

b. Closed stationary refrigeration 49,400 kt CO2 eq 

c. Fire protection 6,600 kt CO2 eq 

d. Open applications (aerosols, foam, solvents): 15,000 kt CO2 eq 

e. Mobile air conditioning of ships and rail vehicles 

and mobile refrigeration on ships and road vehicles 8,300 kt CO2 eq 

f. Mobile air conditioning of passenger cars (first fill for export only) 3,500 kt CO2 eq 

g. Mobile air conditioning of trucks and buses 6,500 kt CO2 eq 

h. Metered dose inhalers (incl. for export): 8,500 kt CO2 eq 

In the assessment of the emission reduction potential under sub-option D-4 and D-5, a ban in 

a sector was assumed feasible as of the year that the penetration mix of alternative 

technologies reached 100%. In contrast, under sub-option D-6 the assumed replacement of 

HFCs follows the gradual growth in the market potential of alternative technical solutions. As 

a consequence, the emission reduction potential by 2030 is higher than under sub-options D4 and D-5 and could potentially match the reduction potential shown in table 8-10 (maximum 

technically feasible reduction potential). 
Chapter 8 Options for further EU action 269 

However, a possible technology transition may not include sectors with extraordinary high 

abatement cost in €/t CO2 eq. As an upper limit for the inclusion in option D-6, a maximum 

threshold of emission abatement cost of €50 is considered. From table 8-10 it emerges that 

two sectors of closed systems with HFCs, rail air conditioning and heat pumps, feature 

abatement cost of €556.6 and €130.2, respectively. According to table 8-9, in one sector of 

open application, PU spray foam, the abatement cost per t CO2 eq is €61.5. Both the 

reduction potential for demand and for emissions of these three sectors is excluded from the 

analysis underlying sub-option D-6. Therefore this limit leads to the exclusion of three HFC 

sectors with a combined technically possible 2030 emission reduction potential of 3,677 kt 

CO2 eq (demand reduction potential 11,077 kt CO2 eq). The reduction potential for HFC 

demand and emissions by abatement options compared to the WM scenario in 2030 is 

shown in table 8-13. 

Table 8-13: Potential for reduction of HFC demand in sectors and sub sectors in 2030 at 

maximum costs of emission abatement at €50/t CO2 eq and resulting emission reductions. 

Sector Sub sector Demand 

reduction 2030 

kt CO2 eq 

Emission

reduction 2030 

kt CO2 eq 

Domestic Refrigeration Refrigerators/Freezers 0 12 

Stand-alone systems 219 149 

Commercial Refrigeration Condensing units 8,949 3,927 

Centralized systems 25,214 14,741 

Small Industrial equipment 2,186 871 Industrial Refrigeration Large Industrial equipment 6,557 2,612 

Refrigerated Vans 516 421 

Transport Refrigeration Refrigerated Trucks 4,325 2,990 

Fishing vessels 539 405 

Cargo ship AC 353 320 

Passenger ship AC 160 125 

Bus AC 1,694336 1,616

Truck AC 4,017 4,170

Mobile Air Conditioning 

Rail AC No reduction considered (>€50/t CO2 eq)

Moveable systems 5,369 2,781 

Split systems 45,428 22,970 

Multi split/VRF systems 6.426 2,827 

Rooftop systems 1,489 573 

Chillers (displacement) 6,851 2,512 

Stat Air Conditioning 

Centrifugal chillers 460 82 

Heat pumps No reduction considered (>€50/t CO2 eq) 

Fire protection 227ea 2,578 440 Fire protection Fire protection 23 2,946 961 

Technical aerosols 3,637 3,637 Aerosols Medical aerosols No reduction considered: technical constraints

XPS-152a 460 460 

XPS-134a 4,092 1,553 

PU other 2,058 587 Foam 

PU spray foam No reduction considered (>€50/t CO2 eq)

Total 136,522 71,742 

 

336 * After full replacement of HFCs for new truck and bus MAC systems (assumed for 2030) domestic 

first fill in new systems for export to third countries continues with a 25% of the WOM/WM first fill. The 

remaining demand in 2030 amounts to 112 kt CO2 eq for buses and 388 kt CO2 eq for trucks. 
Chapter 8 Options for further EU action 270 

Table 8-13 shows a reduction potential for HFC demand and emissions in 25 sub sectors. 

The technical basis of the 2030 reduction potential for demand and emissions of sub-option 

D-6 is the same as under the preceding sub-options: the growth in the market penetration 

rates of replacement technologies in 2015-2030. 

Under the WAM scenario, the maximum reduction potential for the HFC demand which can 

potentially emerge from 25 sectors of closed stationary and mobile applications and open 

applications in 2030 is 136,500 kt CO2 eq. The corresponding emission reduction potential 

amounts to ca. 71,740 kt CO2 eq. 

This reduction could be achieved if the technically feasible replacement potential at emission 

abatement cost below €50 per t CO2 eq would be followed. Related HFC emissions in EU-27 

would be reduced by 71,740 kt CO2 eq as compared to the WM scenario by 2030. This 

equals almost 70% compared to the EU F-gas emissions in the WM scenario of 103,657 kt 

CO2 eq (see table 6-5). 

Under the assumed transitions, the remaining 2030 HFC demand for deliberate use (from a 

total of 170,400 kt CO2 eq under the WM scenario) is 33,900 kt CO2 eq. It is distributed over 

five different demand quantities: 

(1) Unabated HFCs in the 25 reduction sectors (10,600 kt CO2 eq). 

(2) HFCs in the three sectors (heat pumps, spray foam, rail vehicle air conditioning) 

excluded from sub-option D-6 (10,800 kt CO2 eq). 

(3) HFC-134a and -227ea for filling of metered dose inhalers for domestic use and 

exports (8,500 kt CO2 eq). 

(4) First fill of HFC-134a in passenger car MAC systems for export to third countries 

(3,500 kt CO2 eq).337

(5) Other HFCs in small quantities like solvents, HFCs in OCF and novelty propellant gas 

mixtures with GWP < 150, and HFC-236fa for fire extinguishing in military vehicles 

(600 kt CO2 eq). 

The residual F-gas demand after the HFC demand reduction driven by the application of sub 

option D-6 for the years 2015, 2020, 2030, and 2050 can be seen in table 8-14. Please note 

that HFC emissions from halocarbon production, e.g. HFC-23 by-product emissions, are not 

included in the table because the do not represent deliberate demand/supply. Figure 8-3 

graphically illustrates the reduction potential of HFC supply until 2050. 

Table 8-14: Reduction potential of HFC supply in 2015-2050 (WAM) and remaining supply of Fgases under WM in sub-option D-6 (limits for placing on the market of F-gases) by sectors* 

2015 2020 2030 2050 

Total HFC Demand WM 166,100 167,600 170,400 174,500 

WAM reduction in 25 HFC sectors 38,500 95,500 136,500 146,100 

Not reduced in 25 HFC sectors 93,100 49,200 21,300 15,200 

thereof heat pump/spray foam/rail MAC 7,500 8,300 10,800 12,100 

Metered Dose inhalers 8,200 8,200 8,500 8,900 

Passenger Car MAC 25,800 14,200 3,500 3,600 

Other HFCs 0,500 0,500 0,600 0,700 

* HFC supply excludes CHF3 (HFC-23) as etching gas in semiconductor industry, and HFC-134a used 

as SF6 replacement in magnesium die casting. These quantities are comparably small. 

 

337 Remaining demand for first fill in MACs of buses and trucks is included in (1) Unabated HFCs in the 

25 reduction sectors. 
Chapter 8 Options for further EU action 271 

In figure 8-3, the upper curve (WM) reflects the impact of the MAC Directive (passenger cars) 

and the existing F-gas Regulation on the HFC supply. The lower curve displays the reduction 

trend of the HFC supply on the basis of full application of sub-option D-6, which assumes 

that technically feasible abatement technology with emission abatement cost of less than 

50 €/t CO2 eq replaces conventional HFC technology to the maximum extent as outlined in 

chapter 6 and annex V and VI. 

HFC supply in WM scenario and WAM scenario 2014-2030 

(limits for placing on the market)

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

2014 2016 2018 2020 2022 2024 2026 2028 2030

ktCO 2eq

HFC supply WM 

HFC supply WAM

Figure 8-3: HFC supply in EU-27 in the period 2014-2030 (kt CO2 eq) in the WM scenario (which 

includes application of F-gas Regulation and MAC Directive) and the WAM scenario, which 

relies on full establishment of the technically feasible HFC replacement potential at emission 

abatement costs below €50/t CO2 eq from 2015 onwards. The remaining HFC supply is 33,900 kt 

CO2 eq in 2030 (compared to 170,400 kt CO2 eq in the WM scenario). 

If HFCs would be used only in new equipment for which technically feasible alternatives are 

too expensive or not available from 2015 onwards (which includes first fill of passenger car 

MACs for export and also MDI where feasibility of alternatives is subject to further 

investigation), the demand for HFCs only would decrease to 33,900 kt CO2 eq by 2030 which 

is 20% of the total HFC demand of 170,400 kt CO2 eq under the WM scenario. 

Sub-option D-6 could therefore allow such large reductions of HFC demand and thereby 

emissions. It could be used for the implementation of international HFC phase down 

schedules (see chapter 7) in case these are eventually agreed. 

Furthermore, this option could also be implemented independently from international action 

of HFCs. If implemented at EU level without an international HFC agreement in place, 

production caps for HFC manufacturers located in EU-27 should be avoided. Controls should 

focus on HFCs. 

This option could also be complemented by control measures for HFC-23 by-product 

emissions, which is also discussed at international level (chapter 5). 
Chapter 8 Options for further EU action 272 

 Sub-option D-7: Development and dissemination of BAT and BREF notes and 

documents 

Directive 2008/1/EC concerning integrated pollution prevention and control (IPPC Directive) 

established the concept of best available techniques (BAT) (recast in 2010: Directive 

2010/75/EU on industrial emissions (integrated pollution prevention and control) (Recast)338) 

(chapter 3). The decision to issue a permit for a certain industrial or agricultural facility 

contains certain specific requirements including also the monitoring of substances released 

and sets Emission Limit Values (ELVs) for pollutants based on BAT. The Directive does not 

set standards or thresholds for the prevention or control of emissions, or other environmental 

aspects, but leaves this responsibility to the Member States, who must ensure that the ELVs 

were fulfilled. The application of BATs is based on BAT Reference Documents (BREFs) 

developed by the European Commission. 

BREFs are technical documents which contain information leading up to the conclusions of 

what are considered to be “best available techniques” (BAT) in a general sense for the sector 

concerned. BREFs are intended to serve as drivers towards improved environmental 

performance across the European Union but neither to interpret the IPPC Directive nor 

remove the obligations on operators and Member States. They do not prescribe techniques 

or ELVs. For sectors and industry related to F-gases, several BREFs already apply (chapter 

3). 

ELVs refer to polluting substances with the exception of greenhouse gases if the emission 

trading scheme applies. A permit issued in compliance with the IPPC Directive is hence not 

obliged to contain the emission limit values for greenhouse gases if these are subject to an 

emission trading scheme and provided that there is no local pollution problem. 

Hence emissions from aluminium industry could be addressed through BREFs but PFC 

emissions would not be in the focus of the permit as they will be included in EU-ETS from 

2013. 

BREFs are the outcome of an exchange of information carried out with a dedicated Technical 

Working Group constituted for the purpose. The Technical Working Group gathers and 

assesses all information required for BREFs. The European IPPC Bureau acts as neutral 

technically competent secretariat to all Technical Working Groups.339

The decision to start reviewing a BREF is taken by the Commission based on the 

recommendation of the Information Exchange Forum of the European IPPC Bureau on the 

work programme. Within the review of an existing BREF, which takes between 23 and 32 

months340, it is expected that a final draft for the reviewed BREF based on substantial data 

input from industry and the competent authorities in the Member States will be completed 

within two years and will include three plenary meetings of the Technical Working Group and 

the preparation of one intermediate draft BREF. 

 

338 OJ L334, 17.10.2010, p. 17. 339 European IPPC Bureau: IPPC BREF Outline and Guide, updated December 2005. 

ftp://ftp.jrc.es/users/eippcb/public/doc/BREF_outline_and_guide_2005.pdf 

340 European Commission: Updated Generic Schedule for the review of BREFs, May 2009. 
Chapter 8 Options for further EU action 273 

In case of the establishment of a totally new BREF, it is expected that a final draft will be 

completed within about two or three years from the start of the work. The procedure to create 

the final draft will normally include two plenary meetings of the Technical Working Group. 

BREFs constitute a rather soft instrument for environmental protection in general as they 

provide technical information rather than legally binding standards. Particular sectors where 

BREFs could be used for emission reductions include e.g. HFC-23 emissions from the 

production of halocarbons, F-gas emissions from photovoltaics industry. 

The actual implementation of BATs based on BREFs is likely to vary between sectors and 

Member States and follows the lifetime of industry facilities. F-gas emission reductions 

caused by the implementation of BATs are difficult to quantify and project and cannot be 

expected to reduce emissions in the short term. Therefore, this option is not assessed further 

in the context of this study. 
Chapter 8 Options for further EU action 274 

Sub-option D-8: Obligation to destroy HFC-23 emissions from halocarbon 

production 

In Europe, HFC-23 by-product emissions formed during manufacture of HCFC-22 and HFC32 are currently not addressed by legislation. Abatement systems have been installed by 

most chemical companies voluntarily and resulted in significant reductions of HFC-23 

emissions since 1995 (see chapter 5.4). These emissions should be destroyed to the extent 

technically possible due to the high global warming potential of HFC-23 (GWP 14,800). 

Under the Montreal Protocol, control measures to destroy HFC-23 as by-product of the 

production of HCFC-22 are being discussed341. If such measures are eventually agreed, 

HFC-23 destruction hence would need to be regulated in EU although most facilities are 

equipped with destruction technology already. 

An obligation for the installation of HFC-23 abatement technology is hence suggested as a 

regulatory measure at EU level and should refer to production of all kinds of halocarbons (i.e. 

HCFC-22, HFC-32, new substances). 

 

341 UNEP 2010: Report of the Twenty-Second Meeting of the Parties to the Montreal Protocol on 

Substances that Deplete the Ozone Layer, November 2010. 

http://ozone.unep.org/Meeting_Documents/mop/22mop/MOP-22-9E.pdf 
Chapter 8 Options for further EU action 275 

8.1.5 Option E: Marked-based approaches

Sub-option E-1: Include additional activities under the EU-ETS 

The scope for inclusion of fluorinated gases under the EU-ETS Directive is rather limited. 

The Directive applies either to industrial installations that directly emit greenhouse gases or 

to aircraft operators but not to household or industrial appliances that mostly contribute to 

emissions via leakages, at the end of the lifetime or through the use of a product. PFCs from 

aluminium production are already covered under the Directive. 

There are only few remaining sources of fluorinated gases that are directly emitted from 

industrial installations. One potential application is the use of SF6 in magnesium die casting. 

However, most installations already phased out SF6 and further installations are addressed 

by option D-4a. 

Sub-option E-2: Tax schemes 

Financial incentives, in particular taxes, have been mentioned by many experts as important 

instruments to reduce demand and supply and improve recovery of F-gases. 

A recent study on behalf of the EU Commission342 (2010) assessed taxes on virgin 

refrigerant sales and rebates on the return of used refrigerants for destruction as a policy 

option for promoting the recovery and destruction of ODS/HFCs from banks. It is suggested 

to promote reclamation for reuse in certain cases instead of strict destruction since it was 

often more cost effective and less energy-intensive to reclaim used refrigerant than to 

produce virgin refrigerant. Moreover, if the reclamation of used refrigerant could displace the 

production of new refrigerant in EU or abroad, this was an important benefit that should not 

be overlooked. 

The lack of economic incentives, in particular for smaller companies, has been identified as 

the main influencing factor in a recent study for the European Commission343 for recovery of 

F-gases from products and equipment at end of life. “Currently the only compelling driver for 

recovery at end of life is compliance with EU and national regulations”. This finding has also 

been confirmed by stakeholders contacted within this project. In addition, reclamation of Fgases is a complex technical process which leads to high costs for reclaimed substances 

compared to virgin gases. 

Therefore, tax schemes should include not only production and import of virgin substances 

but also provide: 

 

342 ICF International: Identifying and Assessing Policy Options for Promoting the Recovery and 

Destruction of Ozone Depleting Substances (ODS) and Certain Fluorinated Greenhouse Gases (Fgases) Banked in Products and Equipment; Final Report prepared for the European Commission, May 

2010; p. 57. 

343 ICF International: Identifying and Assessing Policy Options for Promoting the Recovery and 

Destruction of Ozone Depleting Substances (ODS) and Certain Fluorinated Greenhouse Gases (Fgases) Banked in Products and Equipment; Final Report prepared for the European Commission, May 

2010; p. 54. Other barriers perceived by stakeholders include legal issues arising from waste shipment 

legislation (Regulation (EC) No 1013/2006) and unclear roles and responsibilities for recovery of Fgases from large equipment in some Member States. 
Chapter 8 Options for further EU action 276 

- Incentives for recovery and recycling of F-gases during service and at end of life: 

Reuse of recovered quantities can limit total F-gas demand and supply as tax applies 

to virgin substances only. 

- Incentives for reclamation and destruction in appropriate facilities by tax refund at 

delivery of used F-gas quantities to specialized facilities. 

If linked to the climate impact of the specific substance (GWP), taxes might promote the use 

of low or zero GWP alternatives. 

Taxes on virgin sales of bulk F-gases would not address the fluorinated gases in imported 

products. Furthermore they would increase the price for domestically manufactured products 

with F-gases and could render these products less competitive. As a considerable share of 

F-gases emitted in the EU derives from F-gases from imported products, this option would 

therefore potentially not reduce F-gas emissions from banks substantially, but would render 

EU manufacturers of appliances using F-gases less competitive. 

On the other hand a tax on F-gases in manufactured products could also address the 

emissions from imported appliances. As the analysis of this study has shown, there are many 

cost-efficient alternative options already available in many sectors. Despite negative costs 

the alternatives are currently not implemented. An increase in costs of HFCs induced by the 

tax would further improve the cost efficiency of the alternatives and could therefore lead to 

enhanced use of such alternatives. However, the effect will strongly depend on the tax level 

chosen and on the development of prices for HFCs and other fluorinated gases. As many 

patents for HFC production recently expired, production in Asia is strongly increasing and 

HFC producers may react with price decreases for HFCs to counterbalance the effects of 

new taxes introduced in order to keep HFC production competitive relative to alternative 

substances. It is rather difficult to assess price elasticity for F-gases in the context of the 

future development of global markets with significant growth projections of production levels 

in Asian countries. In this situation, it is rather uncertain, which would be the appropriate tax 

level. The uncertainties around the future development of prices for F-gases with an 

uncertain level of production growth in emerging countries are a feature which is clearly 

distinct from other environmental taxes on products with more stable prices. Once 

established, a specific tax level would stay implemented for a while and is unlikely to be 

changed quickly after the introduction. Therefore tax schemes that due to the uncertainty of 

information would set tax levels that are too low, would not result in emission reductions and 

it is unlikely that the lack of effectiveness can quickly be corrected. 

The tax systems in place in Member States provide for substantial exemptions which render 

the instrument less effective in terms of emission reductions. A “Study on Environmental 

Taxes and Charges in the EU” (ECOTEC et al. 2001) concluded that “practice with 

[environmental] taxes show that most were set at low rates (with the exception of some user 

charges), and ramped up over time. While many express concern at this ‘ratcheting effect’, it 

is often the case that the rates do not increase that significantly (in real terms over time), as 

increased get blocked by government concern for the supposed fragility of specific industry 

sectors and lobbying by interest groups. This does not necessarily mean that the tax in 

principle is ineffective, but rather that the current form, level and associated exemptions can 

make the tax less effective.” Given the considerable amount of country-specific applications 

with F-gases, it is not unlikely that an EU tax system would also include substantial 
Chapter 8 Options for further EU action 277 

exemptions. A tax scheme complementing the lack of timely implementation of the current Fgas regulation is therefore likely to further postpone cost-effective emission reductions in the 

F-gas sector. 

Furthermore, substantial administrative effort to establish, operate and control such tax 

scheme for fluorinated gases at EU level would be needed over several years, in particular 

for a tax that is imposed on F-gases in manufactured products due to the wide range of such 

products on the market charged with different F-gases. 

In the past, it was difficult to agree on harmonized taxation schemes in the EU (proposals to 

implement a CO2 tax failed in the past, minimum energy taxation remains at a rather low 

level, environmental tax schemes for pesticides, NOx, landfills, wastewater are only 

implemented at Member State level, not at EU level), because Member States have different 

national preferences in this area and some government have strong reservations against tax 

increases or new taxes or levies. ECOTEC et al. also conclude that “the approach has 

generally been for countries to adopt levies unilaterally rather than implementing them in coordination with other countries.” From a political point of view a taxation scheme at EU level 

may therefore be politically more challenging than other options proposed in this section. 

Experiences from Denmark and Norway have been presented in chapter 3.2. The following 

important aspects should be considered when implementing tax schemes: 

- Set up of the scheme (including infrastructure), administration and control as well as 

related costs should be covered. 

- As the scheme intends to enhance reclamation and destruction in specialized 

facilities as opposed to venting of used gases, sums needed for tax rebates are likely 

to increase over time. Attention should be given to imports of used F-gases from 

other Member States and/or countries from outside of EU-27 which might not have 

been placed on the national market and were hence not subject to taxation before. 

- Exemptions from tax should be chosen carefully. 

- The level of taxes needs to be determined nationally and should allow regular 

adjustments to the economic situation. 

- The introduction of a maximum tax per kg in a scheme which is linked to the GWP of 

gases might advantage producers and importers of substances with high GWP since 

no additional efforts would be made to reduce the quantity used or the choice of 

alternatives with lower GWP to substances with very high GWP. 
Chapter 8 Options for further EU action 278 

Sub-option E-3: Deposit and refund schemes 

Financial incentives can efficiently reduce demand and supply and foster responsible use of 

F-gases, enhance recovery, recycling and reclamation, and support the use of low or zero 

GWP substances if linked to the GWP of specific substances. 

The level of the financial incentives needs to be determined on Member State level and 

should take into account the following aspects in addition to national socio-economic 

circumstances in order to constitute a cost-effective tool to limit F-gas emissions: 

- reclamation costs of recovered refrigerants (including costs for transport to 

reclamation facilities), 

- initial costs for set up of the scheme (including infrastructure) and current costs of 

administration and control, 

- costs for refunds or rebates. 

Furthermore, the scheme should allow regular adjustments to the economic situation. 

Generally, financial incentives at a certain level can be effective tools to avoid both, usephase emissions through recovery and containment and the increase of potential emissions 

banked in equipment, in a comprehensive manner. 

Nevertheless, the following particularities of financial incentive schemes should be noted: 

- The time period required until F-gas emissions reach a stable level takes several 

years. 

- Enforcement and control of compliance with the scheme is needed in order to ensure 

effectiveness and stable markets. 

- If financial incentive schemes are introduced in few Member States only, market 

imbalances and implications on employment are likely, in particular if alternative 

technologies to current applications of F-gases are not available at equal cost. 

- Deposit and refund schemes need to reflect the structure of supply of F-gases, which 

are likely to vary substantially from one use to another and from one Member State to 

another. Therefore, no generic scheme seems to be universally applicable in EU-27. 

- The introduction of deposit-refund schemes might depend highly on political 

circumstances at national level. 

Existing experiences on the establishment of financial incentive schemes should be taken 

into account by Member States when establishing national schemes. 
Chapter 8 Options for further EU action 279 

8.2 Screening and ranking of options 

The policy options presented in the previous section were assessed against the following 

criteria: 

• Effectiveness: The effectiveness criterion addresses the expected contribution of 

specific policy options to the EU emission reductions until 2030 (2030 was chosen as 

time horizon for the modelling work). An expected emission reduction of 1,000 kt CO2

eq (1 million t CO2 eq) or more was used as a threshold to qualify specific policy 

options. 1,000 kt CO2 eq is equivalent to 1% of current EU-27 emissions of fluorinated 

gases (as reported in GHG inventories 2008) or 0.02% of total EU-27 GHG emissions 

without LULUCF). Policies with an emission reduction potential below 1,000 kt CO2 eq 

for the EU-27 would contribute to a very limited extent to the overall necessary 

emissions reduction. Yet, this threshold is used in a soft way and in combination with 

other qualitative criteria (see below). 

• Efficiency: A public intervention could be considered as ‘efficient’ or ‘cost effective’ if 

its set objectives are achieved at least cost, or if its desired impact is maximized at a 

given level of resources. In deciding on the climate and energy package in 2008 it 

was found that a marginal cost of 30 €/t CO2 eq was required for reaching a 20% 

reduction in GHG emissions in 2020 compared to 1990 for the GHG emissions under 

the ETS Directive and the Effort Sharing Decision. The time horizon used in this study 

is longer and extends until 2030; therefore a slightly higher threshold of 50 €/ t CO2 eq 

of mitigation costs in 2030 was used in this assessment. The 50 €/t CO2 eq is based 

on GHG emission reductions in the EU in 2030 that are consistent with meeting a 2 

degree Celsius target and derived from the analytical work underlying the roadmap 

for a competitive low carbon economy.344 Where mitigation costs of a specific policy 

were estimated to be higher than 50 €/t CO2 eq, the option was discarded. 

• Technical constraints: Some policy options face technical constraints, in particular 

related to the replacement of current HFC technology by abatement options. In 

specific applications technical requirements do not allow a full replacement in all 

types of applications or across the whole of the EU. In some cases technical 

constraints can potentially be addressed via exceptions from legal provisions. 

However, there are cases where such exceptions would not be applicable in an equal 

way in all Member States or where the definition of such exceptions would be difficult. 

• Other qualitative criteria were used, such as the implementation of a coherent and 

consistent policy approach at EU level or experiences with the implementation of a 

policy approach. The additional qualitative criteria were mostly used in cases where 

additional reasons are relevant against the promotion of a policy option. 

 

344 A roadmap for moving to a competitive low carbon economy in 2050 (COM(2011)112 final. See i.e. 

Summary of the impact assessment (SEC(2011)289 final (page 8) that mentions a price of €50 to 

€60/tonne CO2 eq in 2030. http://ec.europa.eu/clima/documentation/roadmap/docs/sec_2011_289_en.pdf 
Chapter 8 Options for further EU action 280 

C-1 Environmental agreements and self-regulation 

The screening of the sub-options for voluntary agreements (VA) is summarized in table 8-15. 

Table 8-15: Options to address F-gas emissions in EU-27 through voluntary agreements. 

Add. em. 

red. 

2030 

Abate

ment

costs 

2030 

Effective

ness 

Effic 

iency 

Technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

Self-regulation or 

co-regulation

kt CO2 eq €/ t 

CO2

eq 

Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

VA with industry to 

phase-out/down 

HFCs in centralized 

systems, commercial 

hermetics, 

condensing units 

18,818 -0.8 to 

23.7 ++ ++ 

alternatives 

available, 

penetration 

rate 100% in 

2020 

Include 

New VA with 

photovoltaic industry 

to replace SF6 and 

NF3

100 n.a. - + 

alternatives 

available, 

penetration 

rate 100% in 

2015 

Photovoltaics 

industry likely to 

be willing to 

engage 

Include 

Update international 

VA with 

semiconductor 

industry for PFCs, 

NF3, HFC-23 and 

SF6

reduction 

potential 

n.e. 

n.a. - + VA expired in 

2010 

Include 

New VA for 

XPS foams 

(HFC-134a) 

1,553 1.0 + + 

penetration 

rate 100% in 

2015 

 

Include 

New VA for domestic 

refrigeration 12 1.0 - + penetration 

rate 100% 

Very small 

number of units 

containing Fgases remaining 

exclude 

New VA for HFC-23 

in fire protection 961 3.1 +/- + penetration rate 100% 

Very high GWP. 

No use in >20 

MS, alternatives 

available 

Include 

New VA for HFC-23 

by-product emissions 370 <2 - + 

destruction 

technology is 

available 

HFC-23 

destruction 

technology 

installed by most 

producers, only 1 

production facility 

without 

Include 

Total 21,702* 

* without semiconductor and photovoltaic industry, and domestic refrigeration; n.a.: not applicable; n.e.: not 

estimated. 

With regard to emission reduction potentials, the most attractive option among the voluntary 

agreements with industry to phase-out of HFCs is in centralized systems, commercial 

hermetic systems and condensing units because of a high effectiveness with a potential 

additional emission reduction of 18.8 Mt CO2 eq by 2030 and a high efficiency due to low 
Chapter 8 Options for further EU action 281 

abatement costs ranging from -0.8 €/t CO2 to 23.7 €/t CO2 eq. No technical constraints were 

identified in the detailed technical analysis and alternatives are available to achieve a 

replacement of high-GWP-HFCs by 2020. The refrigeration industry already announced a 

voluntary commitment which needs some further specification of objectives and monitoring 

and reporting procedures to turn it into a functioning environmental agreement. 

The second attractive option among the proposed voluntary agreements is a new voluntary 

agreement for XPS foams where presently HFC-134a is used. Such agreement could 

potentially achieve a high effectiveness with a potential additional emission reduction of 

almost 1.6 Mt CO2 eq by 2030 and a high efficiency with mitigation costs of 1 €/t CO2 eq. 

The option ranking third among the voluntary agreement options is a new voluntary 

agreement for HFC-23 in fire protection. Such agreement could potentially achieve a 

moderate effectiveness with a potential additional emission reduction of 0.96 Mt CO2 eq by 

2030 and a high efficiency with mitigation costs of 3.1 €/t CO2 eq. There are no technical 

constraints for the replacement of HFC-23 with a very high GWP by e.g. the fluorinated 

ketone FK 5-1-12. Currently, HFC-23 is used as fire extinguishing agent in only 6 remaining 

Member States (in particular in Spain with >95% of European use). Due to this uneven use in 

Member States it may be preferable if the respective Member States take domestic 

measures and enter voluntary agreements for HFC-23 in fire protection. 

The remaining options considered for voluntary agreements show a rather low effectiveness 

and emission reduction potentials of less than 1 Mt CO2 eq by 2030, but a high efficiency with 

very low abatement costs. Despite the limited effectiveness, it seems useful to explore the 

willingness of industry to adopt further voluntary agreements for the applications with 

negative mitigation costs and no technical constraints. 

However, as also voluntary agreements require monitoring and reporting provisions as well 

as administrative work to prepare the agreement, it seems uncertain whether the emission 

reductions for these options justify the administrative burden for the implementation. 

The limited emission reduction potential of the option “voluntary agreements” is highlighted in 

figure 8-4 in comparison to total F-gas emissions in the periods 2015-2050 in the WM 

scenario. 

Under the assumption that the reduction potential of VAs follows the penetration rates, i.e. 

that all technically feasible replacement solutions for new equipment are annually installed 

according to the penetration mix (chapter 6), maximum emission reduction potentials of ca. 

21.7 Mt CO2 eq until 2030 and ca. 24.7 Mt CO2 eq until 2050 can be achieved. This would 

from 2015 onwards significantly reduce the projected F-gas emissions (WM) to a minimum of 

82.0 Mt CO2 eq (WAM) in 2030 and to an only slightly higher quantity of 86.6 Mt CO2 eq in 

2050. 
Chapter 8 Options for further EU action 282 

Option Voluntary Agreements F-gas Emission Reduction 

Reduction in emissions 2015-2050 (WAM vs. WM)

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2015 2020 2025 2030 2035 2040 2045 2050

ktCO 2eq

WM F-gas emissions

WAM F-gas emissions

Figure 8-4: Maximum F-gas emission reduction potential (WAM) of the option “voluntary 

agreements”, compared to F-gas emissions in the WM scenario in the period 2015-2050. 

D-1: Include F-gases currently not included in Annex I of the F-gas regulation 

This option is not expected to contribute to significant F-gas emission reductions but could be 

pursued in combination with other options as part of a wider revision of the F-gas Regulation. 

This option is not analysed further in this report. 

D-2: Enhance application and monitoring of the Regulation 

The effectiveness of the three sub-options (D-2a,b,c) under this policy option cannot be 

quantitatively assessed. They are not expected to achieve significant emission reductions on 

their own but could be pursued in combination with other options as part of a wider revision 

of the F-gas Regulation. This option is not analysed further in this report. 
Chapter 8 Options for further EU action 283 

D-3 Improve containment and recovery in certain sectors 

The screening of this option is presented in table 8-15. 

The only option in this area that passed the assessment criteria is the inclusion of trucks and 

trailers in transport refrigeration under the scope of Articles 3 and 4 of the F-gas Regulation 

as also recommended by an earlier study for the EU Commission on this matter345. The 

inclusion of trucks and trailers shows an additional emission reduction of 1.5 Mt CO2 eq by 

2030 and an acceptable efficiency of 46 €/t CO2 eq. 

The inclusion of refrigeration in fishing vessels and air conditioning in maritime transport 

under the scope of the F-gas Regulation shows high efficiency, but very limited 

effectiveness. It is not recommended to include this sector in the F-gas Regulation, because 

the Regulation does not seem to be the most appropriate instrument to address F-gas 

emissions from this particular sector: 

The Commission is currently considering general policy options to reduce GHG emissions 

from the maritime sector and it seems preferable to tackle fluorinated gases within such 

general coherent policy approach and not in a separate instrument. In the maritime sector 

specific circumstances apply. At the moment fluorinated gases from international maritime 

transport are not estimated and reported at all in GHG inventories and it would be necessary 

to establish new monitoring requirements at EU level for the maritime sector in order to be 

able to monitor emissions. For a policy instrument in the maritime sector, it is also necessary 

to deal with the problem of accounting of emissions from maritime transport, this means to 

define a particular way to allocate these international emissions to individual Member States 

or operators which are subsequently responsible for the emission reductions and the 

implementation of monitoring and reporting requirements. In the maritime sector specific 

international legal rules apply. The jurisdiction of countries with regard to internationally 

travelling vessels is based on the international law of the sea (UNCLOS 1982), which grants 

the International Maritime Organization (IMO) the right to establish provisions on setting 

Construction, Design, Equipment and Manning standards for ships. Within port states 

jurisdiction UNCLOS provides for the possibility for states to adopt requirements as a 

condition for the entry of vessels into their ports. Internal waters and ports for jurisdictional 

purpose are assimilated to land territory and as such a port state jurisdiction can adopt 

stricter standards as condition of entry of vessels including construction, design, equipment, 

and manning. These specific problems related to monitoring and reporting, to accounting and 

to the legal situation can be resolved, but they can be better addressed within a coherent EU 

policy instrument for all greenhouse gases from the international maritime sector than as part 

of the inclusion of the international maritime sector in the revision of the F-gas Regulation. 

The option of lowering the applicable threshold for F-gas charges of certain equipment 

already covered by Article 4(1) is not analyzed further due to low effectiveness and very low 

efficiency. Options for all types of appliances show mitigation costs of >1,000 €/t CO2 eq. 

This indicates that the cost-efficient options are already covered by Article 4(1) and that an 

extension cannot be justified. 

 

345 BIPRO 2008: Study on the potential application of Art 3 and 4 of Regulation (EC) no 842/2006 to 

air conditioning and refrigeration systems contained in different transport modes. Final Report on 

behalf of the EU Commission. 
Chapter 8 Options for further EU action 284 

Some policy options in this area could not be quantified and they are therefore assessed 

based on qualitative criteria. The establishment of maximum leakage rates pursuant to 

Article 10(2e) of the F-gas Regulation for air conditioning and refrigeration equipment could 

not be quantified because better and more detailed data on actual leakage rates and 

compliance with legislation in place would be necessary. The establishment of additional 

maximum leakage rates as part of the F-gas Regulation for air conditioning and refrigeration 

equipment is not recommended because of the following reasons: 

- Technical problems in accurately determining low leakage rates by common leak 

detection systems and devices. 

- Maximum leakage rates do not encourage the use of equipment with low charges of 

F-gases or equipment with low-GWP alternatives, although high losses of a 

substance with high GWP causes higher global warming emissions than leakage of a 

refrigerant with low GWP. 

- Maximum leakage rates apply during normal operation of equipment and do not 

include losses of refrigerant during accidents and other damage. Thus, significant 

emissions can still occur during equipment damage or at end of life and the 

establishment of large banks of HFCs continues. 

- It would be very difficult to define appropriate maximum leakage rates for all Member 

States at EU level taken into account the differences in operation and maintenance 

practices. 

- Such policy is likely to affect small and medium enterprises more significantly than 

large enterprises. Small companies operating refrigeration and air conditioning 

equipment would be less compliant with maximum leakage rates than large 

companies. 

- The control of compliance with maximum leakage rates is extremely difficult and 

cooperative approaches in assisting companies in decreasing leakage seem more 

effective than the setting of limits. 

The introduction of an obligation for producers and suppliers of F-Gases to take back 

recovered F-Gases for reclamation and destruction could also not be assessed quantitatively 

in the report. Industry experts contacted within the project pointed out that reclamation of 

used F-gases was rarely possible for technical reasons and linked to high costs of the 

reclamation process. This conclusion differs from a previous study on behalf of the 

Commission346 that claimed low costs for this option. 

 

346 ICF International: Identifying and Assessing Policy Options for Promoting the Recovery and 

Destruction of Ozone Depleting Substances (ODS) and Certain Fluorinated Greenhouse Gases (Fgases) Banked in Products and Equipment; Final Report prepared for the European Commission, May 

2010. 
Chapter 8 Options for further EU action 285 

Table 8-15: Options to address F-gas emissions through improvement of containment and 

recovery in certain sectors 

Add. em. 

red. 

2030 

Abate. 

costs 

2030 

Effective

ness 

Effic 

iency 

Other qualitative 

criteria 

Final 

evaluation 

Improve 

containment and 

recovery in 

certain sectors 

kt CO2 eq €/t CO2

eq 

Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

Improve containment and recovery

Inclusion in the 

scope of 

Articles 4 (1): 

Refrigerated road 

transport - vans

11 291 - -- 

Difficult 

implementation and 

verification due to high 

number of operators 

 exclude 

Inclusion in the 

scope of 

Articles 3 and 4: 

Refrigerated road 

transport – trucks 

and trailers

1,430 46 + + 

include 

Inclusion in the 

scope of 

Articles 3 and 4: 

Rail transport

16 340 - -- 

80% of operators 

already fulfil service 

requirements 

exclude 

Inclusion in the 

scope of 

Articles 3 and 4: 

Refrigerated 

maritime transport 

– cargo ships

273 10.5 - + 

Inclusion in the 

scope of 

Articles 3 and 4: 

Refrigerated 

maritime transport 

– passenger ships

405 8.5 - + 

Inclusion in the 

scope of 

Articles 3 and 4: 

Refrigerated 

maritime transport 

– fishing vessels

360 0.5 - + 

F-Gas Regulation not 

the most appropriate 

instrument to address 

this sector: The 

Commission is 

currently considering 

options to reduce GHG 

emissions from the 

maritime sector, taking 

into account its 

international nature 

and unique 

characteristics. It 

would be appropriate 

to also consider 

addressing F-gases in 

such coherent 

approach. 

exclude 

Lowering the applicable charge threshold of certain equipment containing F-gases already 

covered by Article 4(1) 

Domestic 

refrigeration 1 324,722 - --- 

Commercial 

hermetics 13 29,575 - --- 

Moveable air 

conditioners 644 3,707 - --- 

Split air 

conditioners 6,057 2,204 + --- 

Heat pumps 740 1,756 - --- 

exclude 
Chapter 8 Options for further EU action 286 

Add. em. 

reduction 

2030 

Abate. 

costs 

2030 

Effective

ness 

Effic 

iency 

Other qualitative 

criteria 

Final 

evaluation 

Improve 

containment 

and recovery in 

certain sectors 

(cont.) kt CO2 eq Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

Extending the training and certification requirements to personnel undertaking activities 

currently not covered under Article 5

Not 

quantifi 

able 

Not 

quantifi 

able 

 Effectiveness likely to 

be very low. 

exclude 

Introducing maximum leakage rates for certain systems and equipment containing F-gases 

Not 

available 

Not 

available 

Does not include 

accidents; problems 

related to 

measurability of 

leakage rates; 

effectiveness likely to 

be low 

exclude 

Introducing obligation for producers and suppliers of F-Gases to take back recovered F-gases 

for reclamation and destruction 

Not 

available 

Not 

available 

Include as an area for 

coordination and 

exchange of best 

practice as specific 

measures may vary 

across Member 

States. 

exclude 

From the sub-options considered, only the sub option “Inclusion in the scope of Articles 3 

and 4: Refrigerated road transport – trucks and trailers” meets the screening criteria. The 

emission reduction potential of 1,430 kt CO2 eq is sufficiently high and the abatement costs 

of 46 €/t CO2 eq are below the screening threshold. 

This option provides benefits as it could be implemented immediately (e.g. in 2015). It can be 

assumed that after some years (general estimate in this work: 5 years) use-phase emissions 

in this sector, can be reduced by 40% and disposal emissions by 33% as compared to the 

WM scenario. 

However, emission reductions that can be achieved by application of Articles 3 and 4(1) to 

refrigerated trucks and trailers are rather small and amount to only 1.4% of projected total Fgas emissions of 103.7 Mt CO2 eq (2030) and 1.3% of projected 110.8 Mt CO2 eq (2050) 

(figure 8-5). 
Chapter 8 Options for further EU action 287 

Option Application of Art3+4 to Refrigerated Trucks 

Reduction of F-gas emissions 2015-2050 (WAM vs. WM)

90,000

100,000

110,000

120,000

130,000

2015 2020 2025 2030 2035 2040 2045 2050

ktCO 2eq

WM F-gas emissions

WAM F-gas emissions

Figure 8-5: F-gas emission reduction potential (WAM) of the option “Inclusion in the scope of 

Articles 3 and 4: Refrigerated road transport – trucks and trailers” compared to total F-gas 

emissions in the WM scenario in 2015-2050. Please note that the Y-axis does not start from 0 

but from 90,000 kt CO2eq in order to better illustrate the difference between WM and WAM 

scenario. The reduction is 1,800 kt CO2 eq (1.3%) in 2050 at the maximum. 

In combination with other measures, this option can increase in the short term the overall 

emission reduction potential, as it becomes effective already in 2015. 

As an example, the following figure 8-6 illustrates the additional reduction potential that can 

be achieved through the combination of the option “Inclusion in the scope of Articles 3 and 4: 

Refrigerated road transport – trucks and trailers” and the option “Ban the POM of closed 

applications containing F-gases: Refrigerated trucks and trailers” (start of the ban in 2030). In 

the period 2015-2030, the reduction potential is determined only by containment and 

recovery measures for this sector and amounts to 1,075 kt CO2 eq (2015) and 1,430 kt CO2

eq (2030). 

The option “ban” becomes fully effective from 2030 and reduces the dominating impact of 

containment and recovery measures on emission reductions gradually until 2050. In the 

period 2015-2040, additional emission reductions can be achieved through containment and 

recovery measures, which however decrease from 2030 onwards as replacement of HFC 

equipment proceeds. 

In figure 8-6, the combined emission reduction potential in the period 2015-2040 is indicated. 

Please note that this combination of options serves as example and is not the only possible 

combination. 
Chapter 8 Options for further EU action 288 

Combined emission reduction from Art3+4 (2015) and use ban for 

new equipment (2030) vs. WM F-gas emissions, 2015-2040

100,000

105,000

110,000

115,000

120,000

2015 2020 2025 2030 2035 2040

ktCO 2eq

WM emiss

WM minus Art 3+4 reduction

WM minus ban reduction

WM minus combined reduction

Figure 8-6: Combined F-gas mission reduction potential from application of the option 

“Inclusion in the scope of Articles 3 and 4: Refrigerated road transport – trucks and trailers” 

and the option “Ban the POM of closed applications containing F-gases: Refrigerated trucks 

and trailers” (start of the ban in 2030). From 2015 to 2030 the application of Articles 3+4 (blue 

line: WM minus Art3+4 reduction) causes emission reductions of 1,430 kt CO2 eq in 2030. From 

2030 onwards the reduction from the ban (red line: WM minus ban reduction) starts and from 

2033 onwards, it is higher than that from the application of Articles 3+4 which decreases with 

the number of vehicles not yet replaced. The combined emission reduction potential is 

indicated by the bottom red line (WM minus combined reduction). Please note that the X-axis 

starts at 100,000 kt CO2 eq. 

It should be noted here that the option “Inclusion in the scope of Articles 3 and 4: 

Refrigerated road transport – trucks and trailers” is not included in the WAM scenario of the 

model AnaFgas. This is because the additional emission reduction effect is not considered 

high enough to substantially increase the overall reduction potential by the option “Set 

quantitative limits to placing on the market” which does not start from 2030 but from 2015, 

like the application of Art 3 and 4. 
Chapter 8 Options for further EU action 289 

D-4 Bans of the placing on the market or use of open applications 

a) SF6 in magnesium industry

Operators have already started replacing SF6 and seem to be ready to phase-out SF6 in this 

application. Mitigation costs are low at <1 €/t CO2 eq. Larger installations mostly phased out 

SF6 while smaller installations and recyclers continue using SF6; with a ban a consistent 

implementation would be achieved. Despite a rather low emission reduction potential of 0.25 

Mt CO2 eq it is nevertheless recommended to include the use of SF6 in magnesium die 

casting and recycling of die casting alloys under the scope of Article 8 (table 8-16). 

Table 8-16: Options to address SF6 emissions from open applications in EU-27 through use bans 

Add. em. 

red. 

2030 

Abate

ment 

costs 

2030 

Effective

ness 

Effic 

iency 

technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

Ban the use of 

SF6 in open 

applications 

kt CO2 eq €/ t CO2

eq 

Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

Inclusion of magnesium die casting <850 kg/ y and recycling of die casting alloys in the scope 

of Article 8 

250 0.4 - + 100% in 

2015 

Operators have 

started replacing 

SF6, are ready to 

phase-out. Costs 

are low, smaller 

installations 

could be treated 

in the same way 

as larger ones 

(consistency). 

include 

b) HFCs in open applications

The maximum emission reduction potential had been discussed in chapter 8.1 and was 

presented in table 8-9 (open applications). 

The screening of the sub-options for bans of use in open applications is presented in table 8-

17. Open applications of F-gases result in 100% emissions during use and/or at end of life 

and are therefore considered separately from closed applications. 

The most attractive option among the bans of use in different open applications is the ban of 

HFCs in technical aerosols because of a high effectiveness with a potential additional 

emission reduction of 3.6 Mt CO2 eq by 2030 and a high efficiency due to low abatement 

costs ranging of about 10 €/t CO2 eq. No technical constraints were identified in the detailed 

technical analysis (annex VI). 

Bans of use would also be feasible for HFC-134a in XPS foams with an effectiveness of 1.5 

Mt CO2 eq by 2030 and an efficiency of 1.0 €/t CO2 eq. 

Other policy options that are proposed to be discarded from further analysis are 

- a ban of HFC-365mfc or HFC-245fa in PU spray foam 

- a ban of HFC-152a in XPS foam blowing, and 
Chapter 8 Options for further EU action 290 

- a ban of HFC in other PU foam applications. 

This is due to low efficiency in case of spray foam and due to the limited effectiveness in 

XPS with HFC-152a and in other PU foam which does not seem to qualify for a strong 

regulatory measure such as a ban. For bans in other PU foam blowing applications, technical 

constraints apply and exemptions are considered to be difficult to define, in particular 

because the sector is very heterogeneous, comprising many sub sectors with only small 

extent of HFC application. 

Table 8-17: Options to address HFC emissions from open applications in EU-27 through 

placing on the market or use bans 

Add. em. 

red. 

2030 

Abate

ment 

costs 

2030 

Effective

ness 

Effic 

iency 

technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

Ban the POM of 

open F-gas 

applications

kt CO2 eq €/t CO2

eq 

Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

Inclusion of open applications of technical aerosols and XPS and PU foam in the scope of 

Article 9 

Ban of HFCs in 

technical 

aerosols 

3,637 10 + + 95% in 2020 Exemptions 

need to be 

defined 

include 

Ban of HFC-152a 

in XPS foam 

blowing in 2015 

460 -1.60 

- ++ 

100% in 

2015 

GWP of 152a is 

much lower 

(124) than 

GWP of 134a 

(1,430). Could 

possibly be 

considered 

combined with 

HFC-134a. 

exclude 

Ban of HFC-134a 

in XPS foam 

blowing in 2015 

1,553 1.0 

+ ++ 

100% in 

2015 

Very few 

companies in 

EU 

include 

Ban of HFC in 

PU spray foam 

blowing 

1,369 61.6 + +/- 100% in 

2015 

Relevant 

mainly in Spain 

and Portugal 

exclude 

Ban of HFC in 

other PU foam 

blowing 

587 3.5 - + up to 95% in 

2015 

Exemptions 

need to be 

defined. 

exclude 

Total 5,190* 

* only the sub-options included for further analysis 
Chapter 8 Options for further EU action 291 

Figure 8-7 illustrates the emission reduction potential from bans of the POM of two open 

applications (HFCs) to be included in further analysis, technical aerosols and XPS-foam with 

HFC-134a. The total emission reduction potential of a placing on the market ban in these two 

applications amounts to 5.2 Mt CO2 eq (2030; 5%) and 5.5 Mt CO2 eq (2050; 5%) as 

compared to the total F-gas emissions of 103.7 Mt CO2 eq. (2030) and 110.8 Mt CO2 eq. in 

the WM scenario. 

Compared to total F-Gas emissions in the WM scenario, the emission reduction potential of 

this option is limited if this option is considered separately and not in combination with other 

policy options. 

Option Ban on open HFC applications: Reduction in F-gas 

emissions 2015-2050 (WAM vs. WM)

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2015 2020 2025 2030 2035 2040 2045 2050

ktCO 2eq

WM emissions

WAM emissions

Figure 8-7: Emission reduction potential (WAM) of the option “ban of use of HFCs for open 

applications” compared to total F-gas emissions of the WM scenario in the period 2015-2050. 
Chapter 8 Options for further EU action 292 

D-5 Ban of placing on the market of certain closed applications containing 

F-gases 

A large number of closed applications were considered for a potential ban of their placing on 

the market in chapter 8.1 and are listed in table 8-11. The screening is shown in table 8-18. 

Table 8-18: Options to address F-gas emissions from closed applications in EU-27 by placing 

on the market bans 

Add. 

em. red. 

2030 

Abatem

ent 

costs 

2030 

Effective

ness 

Efficiency technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

Ban the placing 

on the market of 

certain closed 

F-gas 

applications 

kt CO2 eq €/t CO2

eq 

Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

Domestic 

refrigeration 

12 1.0 - + 2015 

exclude 

Commercial 

hermetic systems 

147 -0.8 -- ++ 2020 

include 

Condensing units 2,849 1.2 + + 2020 

include 

Centralized 

systems 

12,055 23.7 ++ + 2020 

include 

Small industrial 

refrigeration 

67 -0.9 +/- ++ 95% in 2030

Exemptions 

need to be 

defined for 

small systems, 

e.g. <50 kg 

(similar to 

Sweden). 

include 

Large industrial 

refrigeration 

202 -21.6 + ++ 95% in 2030

Exemptions 

need to be 

defined. 

Combination of 

small + large 

ref. possible 

(threshold 50 kg)

include 

Moveable AC 2,781 8.9 + + 2020 

include 

Single split AC 22,970 19.0 ++ + 2020 

include 
Chapter 8 Options for further EU action 293 

Add. em. 

red. 

2030 

Abate. 

costs 

2030 

Effective

ness 

Efficiency 

technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

Ban placing on 

the market of 

certain closed 

F-gas 

applications 

(cont.) 

kt CO2 eq €/t CO2

eq 

Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

Multi split AC 2,172 13.1 + ++ 2020 

include 

Rooftop AC 

systems 

573 8.2 - ++ 2020 

include 

Displacement 

chillers 

1,989 5.9 + ++ 2020 

include 

Centrifugal 

chillers 

9 7.5 - ++ 2030 

exclude 

Refrigerated 

vans 

421 45.1 - +/- 2020 

exclude 

Heat pumps 1,356 130.2 - 2020 

exclude 

Fishing vessels 27 3.4 - + 

penetration 

rate not 

100% 

Cargo ship AC 232 16.7 - + 2020 

Passenger ship 

AC 

97 35,0 - + 

penetration 

rate not 

100% 

F-gas Reg. is not 

the most 

appropriate 

instrument to 

address this 

sector: The 

Commission is 

currently 

considering 

options to reduce 

GHG emissions 

from the maritime 

sector, taking into 

account its 

international 

nature and 

unique 

characteristics. It 

would be 

appropriate to 

also consider 

addressing Fgases in such 

coherent 

approach. 

exclude 
Chapter 8 Options for further EU action 294 

Add. em. 

red. 

2030 

Abate. 

costs 

2030 

Effective

ness 

Efficiency technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

Ban the placing 

on the market of 

certain closed 

F-gas 

applications 

(cont.) kt CO2 eq €/t CO2

eq 

Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

Refrigerated 

trucks and 

trailers 

322 2.6 - + 2030 

include 

Rail vehicle AC 16 555.6 -- - 

penetration 

rate not 

100% 

exclude 

HFC-23 in fire 

protection 961 3.1 +/- + 2015 

Very high GWP. 

No use in 21 MS, 

alternatives 

available 

include 

HFC-227ea in 

fire protection 167 22.3 - + 

penetration 

rate not 

100% 

exclude 

Medium Voltage 

secondary 

switchgear 

61 347.7 - - 

penetration 

rate not 

100% 

exclude 

Total 47,089* 16.9* 

* only sub-options included for further analysis

By far most effective sub-option among the bans of the placing on the market is the one on 

single split room air conditioners with a potential additional emission reduction of 22,970 kt 

CO2 eq by 2030 at a moderate efficiency due to low abatement costs of €19.0. No technical 

constraints were identified in the detailed technical analysis for this option. The aggregated 

penetration mix of three low-GWP refrigerant-options is expected to reach 100% in 2020. 

Because of the lifetime of 10 years, the full emission reduction potential can be achieved by 

2030. 

With regard to further stationary air conditioning applications, moveable AC systems, multi 

split AC systems, rooftop systems as well as displacement chillers could possibly be 

considered in a ban from 2020, when the penetration rate mix has reached 100%. Rooftop 

systems feature abatement cost of 8.2 €/t CO2 eq but an emission reduction potential of less 

than 1,000 kt CO2 eq, with 573 kt CO2 eq. Nevertheless they could be grouped together with 

multisplit systems and/or small displacement chillers systems for a wider potential ban on 

stationary AC systems of medium size. 

The most attractive option among the bans of placing on the market in stationary refrigeration 

is the ban of HFCs in centralized refrigeration systems because of a high effectiveness with a 

potential additional emission reduction of 12.1 Mt CO2 eq by 2030 and a moderate efficiency 
Chapter 8 Options for further EU action 295 

due to low abatement costs ranging of 23.7 €/t CO2 eq. No technical constraints were 

identified in the detailed technical analysis for this option. 

Another highly attractive option is a ban of HFCs in condensing units with an effectiveness of 

about 2.9 Mt CO2 eq by 2030 and low mitigation costs of 1.2 €/t CO2 eq. in 2030. These 

options were also addressed as part of the most attractive options for voluntary agreements. 

A ban may be considered in particular if a strong voluntary agreement with detailed targets, 

timelines and monitoring and reporting requirements cannot be realized. 

Commercial stand-alone (hermetic) systems show low (even negative) abatement cost, and 

can be replaced 100% from 2020 onwards. The low emission reduction potential of 147 kt 

CO2 eq would exclude them from a specific ban under a threshold of 1,000 kt CO2 eq. 

However, as part of the sector of commercial refrigeration they could be included into a wider 

HFC ban for closed systems. 

Refrigerated trucks and trailers which could also be addressed by improved containment and 

recovery measures could be considered for a placing on the market ban from 2030 at high 

efficiency. The emission reduction potential, which is still low in 2030, will increase to more 

than 3,000 kt CO2 eq by 2040. 

As already discussed under voluntary agreements (option C-1g), HFC-23 in fire protection 

could be considered for a ban as of 2015 because very few uses in few Member States 

remain and most Member States already use more sustainable alternatives. There are no 

technical constraints for the replacement of HFC-23 (GWP 14,800) by e.g. the fluorinated 

ketone FK 5-1-12. Currently, HFC-23 it is no longer used as fire extinguishing agent in 21 

Member States, but only in 6 remaining Member States (in particular in Spain). 

Domestic refrigeration has been identified as a sector with rather low mitigation costs of 

1.0 €/t CO2 eq by 2030 if HFC-134a would be completely phased out. However, the 

achievable emission reduction is limited to about 12 kt CO2 eq until 2030 as only very few 

units containing F-gases are imported from outside Europe. 

A ban of HFCs in industrial refrigeration would not be feasible before 2030. The emission 

reduction potential in the same year is rather low at 67 and 202 kt CO2 eq in large and small 

systems respectively, it will however significantly grow after 2030 to > 8,000 kt CO2 eq 

because of the delay due to very long equipment lifetime of 30 years. Therefore, this suboption is not discarded. As the penetration mix reaches only 95% by 2030, exemptions need 

to be identified. 

The qualifying bans to be included for further analysis, in total would achieve an additional 

emission reduction potential of about 47.1 Mt CO2 eq by 2030. 

Apart from the recommended bans described above, bans are not recommended for the 

following applications and reasons: 

• because of low effectiveness for refrigerated vans, domestic refrigeration, rail and 

maritime transport, centrifugal chillers, and medium voltage secondary 

switchgear. A strict regulatory instrument such as a ban would need to be justified 

with a substantial contribution to the EU’s emission reduction targets. This is 

unlikely, given the limited potential of these options; 

• because of low efficiency and high mitigation costs for rail transport, MV 

secondary switchgear and heat pumps; 
Chapter 8 Options for further EU action 296 

• due to limited availability of alternatives for HFC- 227ea in fire protection, by 2030. 

Figure 8-8 illustrates the high emission reduction potential of the option „ban of the POM of 

closed applications containing HFCs“ compared to total F-gas emissions in the WM scenario 

in 2015-2050. 

Option Ban of placing on the market of certain closed F-gas 

applications: Reduction in F-gas emissions 2015-2050 (WAM vs. WM)

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2015 2020 2025 2030 2035 2040 2045 2050

ktCO2eq

WM emissions

WAM emissions

Figure 8-8: Emission reduction potential (WAM) of the option “ban of the POM of certain closed 

applications containing HFCs” compared to total F-gas emissions of the WM scenario in the 

period 2015-2050. The emission reduction potential in 2030 amounts to 47.1 Mt CO2 eq, which 

is 45% of the total F-gas emissions of 103.7 Mt CO2 eq in 2030. 

In the option “voluntary agreements” it was assumed that the reduction potential of 

replacement solutions follows the penetration rates of alternative technologies, i.e. that every 

year all available replacement solutions for new equipment are installed according to the 

penetration mix. In this option, however, a ban can be established only when the penetration 

mix is at 100% (or less provided that specific exemptions can clearly be identified). This 

leads to a delay of emission reductions compared to the option “voluntary agreements” in 

sectors where both options are feasible. 

However, the option „ban of the POM of certain closed applications containing HFCs“ 

includes a larger number of sectors which results in a high emission reduction potential of 

47.1 Mt CO2 eq in 2030 and 67.5 Mt CO2 eq in 2050 (ban effective in all sectors not subject 

to exemptions). The share of the emission reduction potential in the total F-gas emissions 

amounts to 45% (2030) and 61% (2050). 
Chapter 8 Options for further EU action 297 

D-6 Quantitative limits for the placing on the market of F-gases in the EU 

In sub-option D-6 establishing quantitative limits for placing on the market of certain F-gases 

in the EU was discussed and the reduction potential for supply and thereby demand and 

emissions of HFCs was presented in table 8-14 by sectors. This option addresses supply 

(supplyext2) of HFCs to all applications. Therefore the SF6 applications are not relevant in this 

option. 

As explained in chapter 8.1.4, for setting the aggregate supply limits under this option, 

potential reductions in three sectors of HFC applications with extraordinary high abatement 

cost in €/t CO2 eq are not counted: rail air conditioning and heat pumps with abatement cost 

per t CO2 eq of €556.6 and €130.2, respectively, and PU spray foam with abatement cost per 

t CO2 eq of €61.5. Furthermore reductions to MDIs were also not considered as they 

represent a use which requires special investigation by experts from the medical and 

pharmaceutical industry. On the other hand, reductions from a potential technology transition 

in mobile air conditioning of trucks and buses (abatement cost <€ 50/t CO2 eq) are 

considered. 

Therefore the option D-6, while relates to all sectors relying on HFCs, relies upon technology 

transitions in 25 individual sectors of HFC application. 

The main parameters of option D-6 are presented in table 8-19. 

Table 8-19: Option to address F-gas supply in EU-27 through quantitative limits for the placing 

on the market of F-gases. WAM vs. WM scenario. Reference year 2030. 

Add. 

emission 

reduction 

2030 

Averge 

emission 

abatement 

costs 2030 

Effective

ness 

Efficiency Technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

Set quantitative 

limits for the 

placing on the 

market of HFCs

kt CO2 eq €/t CO2 eq Threshold: 

1,000 kt 

CO2 eq. 

Threshold: 

50€/tCO2

eq 

 

Maximum supply 

reductions in all 

sectors relying on 

HFCs : 

136,500 kt CO2 eq

71,740 16.2 +++ ++ 

See annex 

VI and 

chapter 6 

High 

flexibility 

include 

In principle, this option is suitable to implement a potential international HFC phase-down 

agreement under the Montreal Protocol. However, the term “supply” (supplyext2) which is 

controlled under this option is wider than the term “consumption” under the Montreal 

Protocol, and to which the proposed amendments (NA, FSM) refer (see chapter 7). This is 

because this supply includes quantities of HFCs contained in imported equipment which is 

pre-charged outside the EU (see chapter 2.2.4 on the “second extension” of the terms supply 

and demand). Whilst these supply steps are derived from a bottom-up approach by 

considering technically feasible and cost-effective reductions to the demand on a sub-sector 

basis, this option would only establish the framework of the overall supply reduction and 

would leave the choice of technology and the timeline for replacement of HFCs in specific 

applications up to industry. Member States could still implement specific measures such as 

taxes, containment and recovery measures in order to reduce HFC supply. This option, 
Chapter 8 Options for further EU action 298 

which is considered to drive transitions to low-GWP options, could also be implemented in 

parallel with certain bans at EU level. 

As previously explained, the underlying assessment aggregates the emission reduction 

potentials across different HFC applications. The potential emissions reductions that can be 

achieved by 2030 with quantitative limits for the placing of the market can reach 71.7 Mt CO2 

eq if all relevant sectors with marginal emission abatement cost below 50 €/t CO2 eq make 

the assumed transitions to low-GWP options, and would achieve the largest emission 

reduction effect from all policy options considered at estimated average emission abatement 

cost of 16.2 €/t CO2 eq. Thus the option taken as a whole is efficient and highly effective. 

Technical constraints should not apply because the aggregate limits are derived on the basis 

of uninterrupted use in those areas where abatement technologies do not yet exist or where 

they are considerably more expensive than conventional HFC technologies. 

Compared to total F-gas emissions in 2015-2050 in the WM scenario, this option shows a 

particularly high emission reduction potential (figure 8-9). In contrast to the option for placing 

on the market bans, this option assumes that the emission reduction potential follows the 

gradual growth of the penetration rates of alternative technologies, i.e. that each year all 

technically feasible replacement solutions for new equipment are exploited according to the 

penetration mix even though the full market penetration potential might not have been 

achieved yet. 

Option Limits of Placing on the Market (POM)

Reduction in F-gas emissions 2015-2050 (WAM vs. WM)

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2015 2020 2025 2030 2035 2040 2045 2050

ktCO 2eq

WM Emissions

WAM Emissions

Figure 8-9: F-gas emission reduction potential (WAM) of the option “Limits of Placing on the 

Market of HFCs” compared to total F-gas emissions in all sectors in the WM scenario. 

The emission reduction potential in 2030 is significantly higher than in the option “bans of 

use” and amounts to 71.7 Mt CO2 eq representing almost 70% of total F-gas emissions in the 

WM scenario (103.7 Mt CO2 eq). In 2050, it reaches at 87.6 Mt CO2 eq (79% of total HFC 

emissions of 110.8 Mt CO2 eq in the WM scenario in 2050). 
Chapter 8 Options for further EU action 299 

This option relies on the limitation and gradual reduction of supply of HFCs. The HFC supply, 

which is assumed to be identical to HFC demand in a certain year, is closely connected to 

the emissions from the existing conventional HFC technologies in that year. The supply 

serves not only the demand for first fill of equipment but also for the refill which compensates 

for use-emissions. First fill means also the charge in pre-charged equipment which is 

imported to the EU, and the charge in equipment which is pre-charged in the EU for export 

from the EU to third countries. 

As a consequence, the reduction in supply which follows the reduction in the demand during 

the development of the penetration rates of alternative technologies, leads at the same time 

to a reduction in the corresponding emissions from conventional technologies. This 

assumption is illustrated in figure 8-10. Please note that reference is not the total of F-gases 

but of HFCs only. 

Policy option Limits of Placing on the Market 

Reduction of emissions and supply of HFCs, 2015-2030 (WAM)

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2015 2020 2025 2030

ktCO 2eq

HFC WM Emissions

HFC WAM Emissions

HFC WAM supply

Figure 8-10: Technically feasible and cost-effective reduction of HFC supply (WAM) for 

implementation of the option “Limits of Placing on the Market of F-gases” and corresponding 

reduction of HFC emissions (WAM) compared to total emissions in the WM scenario in all 

sectors of deliberate HFC application in the period 2015-2030. The supply curve starts in 2015 

at a higher level than the emission curve. From 2018 onwards it runs below the emission curve, 

because the MAC Directive shows effect and the HFC supply for first fills of equipment in the 

other sectors can be reduced comparably fast so that supply is increasingly limited to 

servicing of existing HFC technology. 

The gradual limitation of the HFC supply, which leads indirectly to reduction in HFC 

emissions, follows the gradual development of the penetration rates of alternative 

technologies. However, the intervals between two reduction steps may be longer. If, merely 

as an example, policy makers would decide for three years intervals, the supply limits could 

look as displayed in figure 8-11. 
Chapter 8 Options for further EU action 300 

Policy option Limits of Placing on the Market: Possible Reduction steps 

for HFC supply to ensure WAM HFC emission reduction 2015-2030 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2015 2018 2021 2024 2027 2030

ktCO 2eq

HFC WAM Emissions

Reduction steps

Figure 8-11: Possible reduction steps for HFC supply to achieve the HFC emission reductions 

according to the policy option “Limits of Placing on the Market”.
Chapter 8 Options for further EU action 301 

D-8 Obligation to destroy HFC-23 emissions from halocarbon production 

This sub-option considers the introduction of an obligation for destruction of inadvertent byproduct emissions from halocarbon production. While the emission reduction potential of this 

option is comparably low, the very high GWP of HFC-23 and the fact that the formation of 

these emissions is not a deliberate application but an industrial process underline the need 

for a separate policy option here. Furthermore, such option may potentially be needed for 

implementation of international commitments under the Montreal Protocol, if such control 

measures currently proposed by Parties are agreed. 

 

The screening of this option is presented in table 8-20. 

Table 8-20: Options to address inadvertent HFC-23 emissions in EU-27 through the obligation 

for destruction of these emissions. 

Add. em. 

red. 

2030 

Abatement 

costs 2030 

Effective

ness 

Efficiency Technical 

feasibility / 

penetration 

rates 

Other 

qualitative 

criteria 

Final 

evaluat

ion 

HFC.23 

emissions from 

halocarbon 

production 

kt CO2 eq €/t CO2 eq Threshold: 

1,000 kt 

CO2 eq 

Threshold: 

50€/tCO2

eq 

 

Destruction of 

HFC-23 emissions 

from halocarbon 

production to the 

extent technically 

feasible 

370 <2 + +++ 100% 

Industrial 

process 

emiss.; 

very high 

GWP; 

internatio

nal 

commitm

ents 

include 
Chapter 8 Options for further EU action 302 

E-1 to E-3 Market-based instruments 

As already explained in section 8.1.5 there are rather few remaining sources of fluorinated 

gases that are directly emitted from industrial installations. The ETS Directive does not cover 

industrial appliances that mostly contribute to emissions via leakages, at the end of the 

lifetime or through the use of a product. 

One potential application is the use of SF6 in magnesium die casting, however most 

installations already phased out SF6 and the remaining use can be better addressed by a 

ban as proposed above. In addition the revision of the ETS Directive was completed after a 

long stakeholder consultation process and the inclusion of sectors is defined until 2020, 

therefore there is currently no scope to increase the coverage of the EU-ETS. 

A general tax schemes for the use of HFCs at EU level seems to be a strong policy 

intervention. Taxes on sales of virgin refrigerants would address the same appliances that 

are currently already regulated under the F-gas Regulation. As the analysis of this study has 

shown, there are many cost-effective alternatives options already available in many sectors. 

Despite negative abatement costs the alternatives are currently not implemented to a large 

scale, and a small increase in costs of HFCs would further improve the cost efficiency of the 

alternatives. However, this may still not be sufficient to implement alternatives at a larger 

scale in the EU. 

In the past, it has been difficult to agree on harmonized taxation schemes in the EU because 

Member States have different national preferences in this area. Furthermore, substantial 

administrative effort to establish, operate and control such scheme at EU level might be 

needed over several years. 

Nevertheless, tax schemes can be used as additional policy instruments at national level in 

the Member States and complement EU policies. In this way, the particular situation of 

certain sectors in each Member State could be taken into account, e.g. through exemptions 

from tax or the level of taxes. 

Deposit and refund schemes are implemented in some Member States and require a 

considerable amount of administrative and financial detail and will depend on Member States 

infrastructure. As the general framework for reclamation and reuse is already set by the Fgas Regulation, deposit and refund schemes seem to be options for Member States to 

implement the regulation, similar to tax schemes, which might also take into account the 

recovery, reclamation and destruction of F-gases. A detailed scheme at EU level may not be 

necessary. 
Chapter 8 Options for further EU action 303 

Overall ranking of policy options 

Table 8-21 summarizes the screening of policy options presented in this section. The setting 

of quantitative limits for the placing on the market of HFCs results in the policy options with 

the largest emission reduction effect of about 71.7 Mt CO2 eq by 2030. 

The emission reductions presented in this table are not cumulative, since they cover at least 

partially the same applications. 

Table 8-21: Summary of potential emission reductions (kt CO2 eq) resulting from the key policy 

options in 2030 

Proposed policy option Additional emission reduction 

potential in 2030 (kt CO2 eq) 

C-1 Voluntary agreements 21,700 

D-1 Include F-gases currently not included in the Regulation Low. Not quantified 

D-2 Enhance application and monitoring of the Regulation] Low. Not quantified 

D-3 Improve containment and recovery under F-gas 

Regulation: Refrigerated trucks and trailers 

1,430 

D-4 Ban the POM of certain open applications containing 

HFCs 

5,190 

D-4 Ban the use of SF6 in open applications 250 

D-5 Ban the POM of certain closed applications containing 

F-Gases 

47,100 

D-6 Set quantitative limits for the placing on the market of Fgases in EU 71,740 

D-8 Obligation for destruction of HFC-23 emissions from 

halocarbon production 

370 
Chapter 8 Options for further EU action 304 

Potential combinations of options and implications 

The overview table 8-22 presents the correlation of the key policy options per sectors. 

Table 8-22: Key policy options per sectors 

Sectors F-gas Policy options considered 

Domestic 

refrigeration HFCs Set quantitative limits for the placing on the market of HFCs in EU 

Voluntary agreement to phase out/down the use of HFCs 

Ban the POM of certain closed applications containing HFCs 

Commercial 

refrigeration HFCs 

Set quantitative limits for the placing on the market of HFCs in EU 

Industrial 

refrigeration HFCs Set quantitative limits for the placing on the market of HFCs in EU 

Improve containment and recovery under F-gas Regulation: 

Refrigerated trucks and trailers 

Ban the POM of certain closed applications containing HFCs 

Transport 

refrigeration HFCs 

Set quantitative limits for the placing on the market of HFCs in EU 

Stationary air Ban the POM of certain closed applications containing HFCs 

conditioning HFCs Set quantitative limits for the placing on the market of HFCs in EU 

Mobile AC ship/rail HFCs Set quantitative limits for the placing on the market of HFCs in EU 

Voluntary agreement to phase out/down the use of HFCs 

Ban the POM of certain open applications containing HFCs 

Foam 

HFCs 

Set quantitative limits for the placing on the market of HFCs in EU 

Voluntary agreement to phase out the use of HFC-23 

Ban the POM of HFC-23 fire protection 

Fire protection 

HFCs 

Set quantitative limits for the placing on the market of HFCs in EU 

Aerosols Ban the POM of certain open applications containing HFCs HFCs Set quantitative limits for the placing on the market of HFCs in EU 

Magnesium 

industry SF6 Ban the use of SF6 in certain open applications 

Semiconductor 

industry 

PFCs, NF3, 

SF6, HFC-23 

Renew voluntary agreement to reduce PFC, SF6, NF3, HFC-23 

emissions 

Photovoltaics 

industry SF6, NF3 Voluntary agreement to phase out the use of NF3 and SF6

Voluntary agreement for HFC-23 destruction to the extent 

technically possible 

Halocarbon 

production HFC-23 

Obligation for HFC-23 destruction to the extent technically possible 

All of these options could be supplemented by the approaches listed under options D-1, 

which suggests including F-gases currently not covered by the F-gas Regulation, and D-2 

aiming at enhanced application and monitoring of the existing legislation (chapter 8.1.4). 

Although emission reduction potentials and related costs of such measures are not estimated 

in this report, they could contribute to improved F-gas bank management and monitoring. 

The policy options “VAs”, “Placing on the market bans for certain open applications (HFCs)”, 

“Placing on the market bans for closed applications” and “Limits for the placing on the market 

of HFCs” address several sectors while the policy options “Containment and recovery” and 

“HFC-23 destruction” relate to one particular sector each. Certain sectors are addressed by 
Chapter 8 Options for further EU action 305 

one policy option only, such as semiconductor and photovoltaic industries (voluntary 

agreements) and magnesium industry (use ban for open applications). 

Voluntary agreements 

- This option can cover several sectors. 

- The existing regulation remains in place. 

- Additional measures are agreed upon by means of voluntary commitments by 

industry and should include comprehensive monitoring and reporting requirements as 

well as quantitative targets for F-gas emission reductions and a defined timeline. 

- The implementation of this option depends on a high number of players which vary 

between sectors. 

- Individual VAs could be implemented both separately and in addition to regulatory 

options. 

This option could be combined with other options: 

• A phase-down of HFCs could be combined with VAs in certain sectors. 

Containment and recovery in transport refrigeration (trucks and trailers)

- This option refers to one sector only. 

- This option would be in line with the concept applied by the F-gas Regulation, which 

could be amended by additional requirements for containment and recovery of Fgases in refrigerated road transport (trucks and trailers). 

- Requirements would cover existing and new road transport refrigeration equipment 

containing F-gases. 

This option could be combined with other regulatory options: 

• A ban of the POM of transport refrigeration containing HFCs from 2030. 

Implications: Emissions from existing equipment would be lowered by improved 

containment and recovery while the equipment would continue to be produced, 

placed on the market and used until the ban enters into force. Bans for other sectors 

could be established in addition. 

• Limits for placing on the market of HFCs. 

Implications: Emissions from existing equipment would be lowered by improved 

containment and recovery while use of low GWP options in new transport 

refrigeration would be driven by the HFC phase down. 

• Destruction of HFC-23 emissions from halocarbon production. 

Implications: No overlap between these measures. 

Bans for the POM of certain open applications (HFCs)

- This option relates to the use of HFCs as propellants in technical aerosols and the 

use of HFCs as foam blowing agents in the foam sectors (XPS foam, PU spray foam, 

other PU foam). 
Chapter 8 Options for further EU action 306 

- The option relies upon changes of the production lines and production processes. 

- The bans would need to start at defined dates per sector/application, which vary 

between 2015 and 2020. 

- Sub-options could be implemented separately. 

- This option would be in line with the concept already applied by the F-gas Regulation, 

which could be amended to include bans for the open applications (e.g. Art 9; novelty 

aerosols, one-component-foam etc.). 

This option could be combined with other regulatory and voluntary options: 

• VAs addressing other sectors: Semiconductor industry, photovoltaic industry, 

halocarbon production. 

• Requirements for containment and recovery of F-gases in transport refrigeration 

(trucks and trailers). 

Implications: No overlap between these measures. 

• Bans for the use of F-gases in open applications (SF6). 

Implications: No overlap between these measures. 

• Bans for the POM of certain closed applications containing F-gases. 

Implications: No overlap between these measures. 

• Limits for placing on the market of HFCs. 

Implications: HFC supply in foam and aerosol sectors no longer necessary. 

• Destruction of HFC-23 emissions from halocarbon production 

Implications: No overlap between these measures. 

Bans for the use of F-gases in open applications (SF6)

- This option relates to the use of SF6 in magnesium die casting (industrial process). 

- The option relies upon changes of the production processes in small Mg die casting 

facilities (<850 kg) and recycling of alloys. 

- This option would be in line with the concept already applied by the F-gas Regulation, 

which could be amended to include bans these open applications (e.g. Article 8 

“Control of use”). 

This option could be combined with other regulatory and voluntary options: 

• All VAs suggested. 

• Requirements for containment and recovery of F-gases in transport refrigeration 

(trucks and trailers). 

Implications: No overlap between these measures. 

• Bans for the use of F-gases in open applications (SF6). 

Implications: No overlap between these measures. 

• Bans for the POM of closed applications containing F-gases. 
Chapter 8 Options for further EU action 307 

Implications: No overlap between these measures. 

• Limits for placing on the market of HFCs. 

Implications: No overlap between these measures. 

• Destruction of HFC-23 emissions from halocarbon production. 

Implications: No overlap between these measures. 

Bans for the POM of certain closed applications containing F-gases

- This option relates to several sectors and applications. 

- The option covers new equipment only. 

- Bans would need to start at defined dates per sector/application, which vary between 

2015 and 2030. 

- Sub-options could be implemented separately. 

- Current requirements of the F-gas Regulation should continue for existing equipment 

containing F-gases. 

This option could be complemented by other regulatory and voluntary options: 

• VAs addressing other sectors: Semiconductor industry, photovoltaic industry, 

halocarbon production. 

• Requirements for containment and recovery of F-gases in transport refrigeration 

(trucks and trailers). 

Implications: Total emission reductions from the transport refrigeration sector would 

increase through a combination of containment/recovery measures for existing 

equipment and a ban for the POM of new transport refrigeration equipment (see 

option D-3, figure 8-6). 

• Bans for the POM of open applications (HFCs). 

Implications: No overlap between these measures. 

• Bans for the use of F-gases in open applications (SF6). 

Implications: No overlap between these measures. 

• Limits for placing on the market of HFCs. 

Implications: Particular bans could potentially facilitate the option “Limits for placing 

on the market of HFCs” as they could eliminate some of the demand that will be 

served by the limited supply instead of living all sectors to adjust to the limited supply 

on their own. 

• Destruction of HFC-23 emissions from halocarbon production. 

Implications: No overlap between these measures. 

Limits for POM of HFCs

- This option would address all sectors using HFCs. 

- This option could be applied in two scenarios: 
Chapter 8 Options for further EU action 308 

a) Independently from an international agreement on HFC phase down, to contribute 

to GHG emission reductions and the EU's related targets. 

b) To implement a potential international agreement on HFC phase down. 

- High flexibility would be provided to industry and industrial planning schedules could 

be respected due to the long time span of several decades. 

This option could be complemented by other regulatory and voluntary options: 

• All VAs suggested. 

Implications: No overlap between these measures. 

• Containment and recovery in transport refrigeration (trucks and trailers) could 

precede limits for placing on the market of HFCs used in transport refrigeration. 

Implications: Emissions from existing equipment would be lowered by improved 

containment and recovery. This would possibly lower the demand in this sector. 

• Ban of the POM of certain open applications containing F-gases. 

Implications: Bans could help the management of the option “Limits for placing on the 

market of HFCs” as they would set priorities for sectors subject to HFC phase out. 

• Ban of the use of F-gases in open applications (SF6). 

Implications: No overlap between these measures. 

• Ban the POM of closed applications containing F-gases. 

Implications: Bans could help the management of the option “Limits for placing on the 

market of HFCs” as they would set priorities for sectors subject to HFC phase out. 

• Destruction of HFC-23 emissions from halocarbon production. 

Implications: No overlap between these measures. 

Destruction of HFC-23 emissions from halocarbons production 

- This option refers to one sector only and could start very soon. 

- This option relies upon installation of destruction technology in few installations, 

monitoring and reporting. 

- This option may be needed for implementation of international commitments, 

currently proposed under the Montreal Protocol. 

This option could be complemented by other regulatory and voluntary options: 

• VAs addressing other gases: All other VAs. 

Implications: No overlap between these measures. 

• Requirements for containment and recovery of F-gases in transport refrigeration 

(trucks and trailers). 

Implications: No overlap between these measures. 

• Bans for the POM of F-gases open applications (HFCs). 

Implications: No overlap between these measures. 
Chapter 8 Options for further EU action 309 

• Bans for the use of F-gases in open applications (SF6). 

Implications: No overlap between these measures. 

• Bans for the POM of closed applications containing F-gases. 

Implications: No overlap between these measures. 

• Limits for POM of HFCs. 

Implications: No overlap between these measures. 

The maximum emission reduction potential in the reference year 2030 could be achieved by 

the package of options presented in table 8-23. 2015 has been determined as the start year 

although some options could technically be implemented earlier than 2015. 

Table 8-23: Combination of options which would lead to the maximum additional emission 

reduction potential in 2030347 

Proposed policy option Sectors concerned Suggested 

start 

Additional emission 

reduction potential 

in 2030 (kt CO2 eq) 

Limits for POM of HFCs HFC applications 2015 71,740 

Ban the use of F-gases in 

magnesium die casting <850 

kg/yr and recycling of alloys 

Magnesium industry 

2015 250 

Destruction of HFC-23 

emissions from halocarbon 

production 

Chemical industry 

2015 370 

Certain VAs Semiconductor industry, 

photovoltaic industry 2015 Ca. 120 

TOTAL Ca. 72,500 

 

347 The option on containment/recovery in the transport refrigeration sector has not been included in 

the maximum additional emission reduction potential because the emission reductions that could be 

achieved through this type of measure at comparably high cost are small compared to the reductions 

that could be gained through the option of limiting the POM of HFCs in the same sector. 
Chapter 8 Options for further EU action 310 

8.3. Key impacts and comparison of policy options 

In chapter 8.1 a number of policy options have been presented, and in chapter 8.2 these 

options were subject to screening. In addition to the detailed assessment of the impact of 

those measures on supply/demand and emissions of F-gases presented in previous 

chapters, annex VII also considers other key environmental, economical and social impacts, 

likely to occur as a result of the remaining options considered .The largest emission 

reductions can be achieved with policy option D-6, quantitative limits for the placing on the 

market of fluorinated gases, which can lead to an emission reduction of 71,740 kt CO2 eq of 

direct emissions and potentially up to a further reduction of 1,580 kt CO2 eq of indirect 

emissions in 2030. Policy option D-5, the ban of the POM of closed applications containing 

F-gases, could also achieve a very substantial emission reduction of about 47,100 kt CO2 eq 

of direct F-gas emissions and up to 715 kt CO2 eq of indirect emissions in 2030. The third 

largest direct emission reduction of 21,700 kt CO2 eq of F-gas emissions and 510 kt CO2 eq 

of indirect emissions could be achieved via policy option C-1, the voluntary agreements. 

These three policy options address mainly the same subsectors and therefore their emission 

reductions cannot be aggregated under a combination of the individual options. The different 

level emission reduction effects of these three policy options are due to the different scope of 

subsectors of the options. For example, for voluntary agreements (C-1) it was assumed that 

only sectors with very low marginal abatement costs for alternative substances would commit 

to voluntary agreements. Therefore the analysis for key impacts of voluntary agreements 

includes a smaller number of subsectors than for the bans of application (D-5) or the 

quantitative limits for placing on the market (D-6). The scope of subsectors for the 

quantitative limits for placing on the market (D-6) is larger than for the ban in closed 

applications as a result of the increased flexibility that the policy option of the quantitative 

limits for placing on the market offers. Furthermore, the option D-6 also considers a 

technology transition of mobile air conditioning of buses and trucks. On the other hand a ban 

in this sub-sector would be more appropriate as part of the review of the MAC Directive 

rather than of the F-Gas Regulation (option D-5). The emission reductions that are 

achievable by the other policy options are rather low compared to these three options and 

also compared with the total magnitude of EU emissions from fluorinated gases. 

The estimated abatement costs for the three main policy options with high emission 

reduction effects are at comparable level (14 - 17 €/ t CO2 eq) and clearly fall in the range of 

cost-efficient abatement costs that have been selected as a threshold for the implementation 

of policies and measures in moving the EU to a competitive low-carbon economy in 2050. 

The direct net costs for the sectors affected are highest at estimated 1,500 M€/year for policy 

option D-6, the quantitative limits for the placing on the market, due to the large number of 

sectors affected by individual measures, followed by policy option D-5, the ban of the POM of 

closed applications containing F-gases, with 1,055 M€/year. 

The same ranking appears for the equipment investment costs which are the highest for 

policy option D-6, the quantitative limits for the placing on the market, with 5,613 M€/year in 

2030 and for policy options D-5, the ban of the POM of closed applications containing Fgases, with 2,860 M€/year. Due to the fact that these options release the largest new 

investments in the affected subsectors, they will also have the highest positive effects on the 

creation of additional jobs at equipment suppliers. However, the replacement of fluorinated 
Chapter 8 Options for further EU action 311 

gases by alternatives with low GWPs will decrease the costs for maintenance and service 

required under the current F-gas Regulation in the long-term and will therefore negatively 

affect the number of jobs in the areas of maintenance and service. However, the positive job 

effects due to the additional investments will be considerable larger. 

Tables 8-24 and 8-25 provide a summary of these findings as a basis for comparison of the 

key policy options and for their further consideration. 
Chapter 8 Options for further EU action 312

Table 8-24: Overview of key environmental, economic and social impacts in 2030 

Environmental impacts Economic impacts Social impacts 

Subsectors affected 

Number of 

units in 2030 

(replaced, 

serviced) 

Reduction of 

direct F-gas 

emissions in 

2030 

Reduction of 

indirect 

energy-rel. 

CO2 emiss. 

Marginal 

emission 

abatement 

cost 

Direct net 

costs to 

sector 

Direct 

cost per 

operator 

Equipment 

investment cost / 

sales of 

equipment 

suppliersc

Loss (-) / Gains 

(+) from service 

Art 3+4 or new 

service for 

NH3+CO2 M€/y 

Employment 

(equipment 

+ service) 

No. kt CO2 eq kt CO2 eq €/tCO2 eq M€/year € /year M€/year M€/year 

Option C-1 Voluntary agreementsCommercial hermetics 5,737,309 150 79 -0.8 -0.12 -0.02 81.3 -14.3 ++ Condensing units 3,020,046 3,930 202 1.2 105.0 2.9 752.7 -185.9 +++ Centralized systems 144,901 14,740 234 23.7 418.8 2,283 773.9 -86.3 +++ Fire protection HFC-23 24,455 960 n.a. 3.1 3.18 130 0.0 -2.2 0dXPS-134a 13 (production lines) 1,550 n.a. 1.0 1.2 98,000 2.5 + Photovoltaic industry to replace SF6 and NF3 n.e. 80 (SF6) 20 (NF3) n.a. ~ 0 ~ 0 ~ 0 ~ 0 0 Semiconductor industry n.e. n.e. n.e. n.e. n.e. n.e. n.e. n.e. HFC-23 by-product emissions 

1 destruction 

plant 370 n.e. < 2 0.55 0.55 0.3 + 

Total voluntary agreements 8,926,711 21,700a 515 16.8b 528.6a - 1,610.7a -288.9 +++ 
Chapter 8 Options for further EU action 313 

Environmental impacts Economic impacts Social impacts 

Subsectors affected 

Number of 

units in 2030 

(replaced, 

serviced) 

Reduction of 

direct F-gas 

emissions in 

2030 

Reduction of 

indirect 

energy-rel. 

CO2 emiss. 

Marginal 

emission 

abatement 

cost 

Direct net 

costs to 

sector 

Direct 

cost per 

operator 

Equipment 

investment cost / 

sales of 

equipment 

suppliersc

Loss (-) / Gains 

(+) from service 

Art 3+4 or new 

service for 

NH3+CO2 M€/y 

Employment 

(equipment 

+ service) 

No. kt CO2 eq kt CO2 eq €/tCO2 eq M€/year € /year M€/year M€/year 

Option D-3 Improved containment and recoveryTrucks and trailers 631,000 1,430 n.a. 46 66.4 105.2 n.a. +71.3 ++ Sub option D-4a Ban the use of F-gases in open applications (SF6) SF6 in Mg die casting 

and recycling of die casting alloys 

20 plants 250 0 0.4 0.01 500 0.1 n.a. 0 

Sub option D-4b Ban the POM of certain open applications containing F-gasesAerosols 9,082,589 cans 3,640 0 10 36.3 n. e. 0 n.a. 0dXPS-134a 13 prod. lines 1,550 0 1 1.2 98,000 2.5 n.a. + Total ban open appl. 5,190 0 7 37.5 3.2 2.5b n.a. + Option D-5 Ban the POM of certain closed applications containing F-gasesCommercial hermetics 5,307,011 150 73 -0.8 -4.64 -0.02 70.7 -13.3 ++ Condensing units 2,421,320 2,850 162 1.2 82.44 2.9 602.2 -157.1 +++ Centralized systems 134,032 12,060 220 23.7 380.1 2,283 714.1 -80.0 +++ Industrial Ref small 462 70 6 -0.9 -0.07 -153 5.2 +0.5 + Industrial Ref large 225 200 52 -21.6 -5.10 -22,642 38.6 +0.3 +++ Refrigerated Trucks 63,185 320 12 2.6 0.96 15.2 16.5 +0.04 + Moveable AC systems 

34,283,827 2,780 

n.e. 

8.9 18.76 0.5 74.4 -85.7 

0 
Chapter 8 Options for further EU action 314 

Environmental impacts Economic impacts Social impacts 

Subsectors affected 

Number of 

units in 2030 

(replaced, 

serviced) 

Reduction of 

direct F-gas 

emissions in 

2030 

Reduction of 

indirect 

energy-rel. 

CO2 emiss. 

Marginal 

emission 

abatement 

cost 

Direct net 

costs to 

sector 

Direct 

cost per 

operator 

Equipment 

investment cost / 

sales of 

equipment 

suppliersc

Loss (-) / Gains 

(+) from service 

Art 3+4 or new 

service for 

NH3+CO2 M€/y 

Employment 

(equipment 

+ service) 

No. kt CO2 eq kt CO2 eq €/tCO2 eq M€/year € /year M€/year M€/year 

Split AC systems 96,697,511 22,970 n.e. 19.0 488.72 5.1 630.4 -483.5 +++ Multi split AC systems 1,376,202 2,170 n.e. 13.1 45.74 26.4 278.4 -228.4 ++ Rooftop AC systems 522,524 570 n.e. 8.2 11.78 9.0 99.2 -85.3 + Chillers 714,570 1,989 191 5.9 33.05 25.2 330.5 -134.1 +++ Fire protection 23 24,455 960 n.e. 3.1 3.18 130.1 0 -2.2 0dTotal ban closed appl. 141,545,325 47,089 716.6 16.9 1,055,0 - 2,860.2 -1,270.2 +++ Option D-6 Quantitative limits for the placing on the market of HFCsDomestic Refrigeration 2,783,424 12 1.8 1.0 0.01 0.004 2.0 -0.3 + Commercial hermetics 5,737,309 149 79 -0.8 -0.12 -0.02 81.3 -14.3 ++ Condensing units 3,020,046 3,927 202 1,2 105.0 2.9 752.7 -185.9 +++ Centralized systems 144,901 14,741 234 23.7 418.8 2,283 773.9 -86.3 +++ Industrial Ref small 5,968 871 75 -0.9 -0.92 -153 67.3 -6.5 ++ Industrial Ref large 2,909 2,612 668 -21.6 -65.9 -22,642 498.7 -3.6 +++ Refrigerated Vans 601,764 421 7 45.1 20.9 31.8 17.8 +1.5 + Refrigerated Trucks 532,335 2,990 100 2.6 16.8 15.2 141.7 +3.7 ++ Fishing vessels 365 405 9 3.4 1.96 5,368 6.3 +0.7 + Cargo ship AC 3,715 320 1 16.7 5.60 1,504 4.1 +0.01 + Passenger ship AC 469 125 35.0 2.90 6,190 0.7 +0.0 0 Bus AC 609,411 1,616 48.5 107.1 158 1,011.4 +++ Truck AC 19,520,29 4,170 43.1 227.9 11.7 724.2 +++ Moveable AC systems 34,283,82 2,781 8.9 18.7 0.55 74.4 -85.7 0 Split AC systems 96,697,51 22,970 19,0 488.7 5.1 630.4 -483.5 +++ Multi split AC systems 1,570,583 2,827 13.1 53.5 26.4 316.6 -256.0 ++ Rooftop AC systems 

522,524 573 207 8.2 11.8 9.0 99.2 -85.3 + 
Chapter 8 Options for further EU action 315 

Environmental impacts Economic impacts Social impacts 

Subsectors affected 

Number of 

units in 2030 

(replaced, 

serviced) 

Reduction of 

direct F-gas 

emissions in 

2030 

Reduction of 

indirect 

energy-rel. 

CO2 emiss. 

Marginal 

emission 

abatement 

cost 

Direct net 

costs to 

sector 

Direct 

cost per 

operator 

Equipment 

investment cost / 

sales of 

equipment 

suppliersc

Loss (-) / Gains 

(+) from service 

Art 3+4 or new 

service for 

NH3+CO2 M€/y 

Employment 

(equipment 

+ service) 

No. kt CO2 eq kt CO2 eq €/tCO2 eq M€/year € /year M€/year M€/year 

Chillers 771,866 2,512 5.9 36.3 25.2 357.0 -143.7 +++ Centrifugal chillers 3,799 82 11.1 1.51 318 3.0 -3.1 0 Fire protection 227ea 48,550 440 22,3 10.9 225 5.4 -4.4 0dFire protection 23 24,455 961 3.1 3.18 130 0.0 -2.2 0dAerosols 9,082,589 cans 3,637 10.0 36.3 4.0 0 0dXPS-152a 13 prod. lines 460 -1.6 -0.7 -56,400 2.5 + XPS-134a 13 prod. lines 1,553 1.0 1.2 98,000 2.5 + PU other 77 prod. lines 587 3.5 0.32 4,130 3.3 + Total limits placing on market 166,886,028e 71,740 1,583 16.2 1,500.0 - 5,612.8 -1,355.7 +++ Option D-8 Mandatory destruction of HFC-23 emissions from halocarbon productionDestruction of HFC-23 emissions to the extent possible

1 plant 370 n.a. <2 0.55 n.a. 0.3 n.a. 0 

n.e. = not estimated n.a. = not applicable a Without semiconductor and photovoltaic industries. b Without photovoltaic and semiconductor industry, and without HFC-23 by-product emissions. c Equipment without first fill of substance. d Employment effect on suppliers of low-GWP substances (propellant gas or fire extinguishing agents) is not considered. 
Chapter 8 Options for further EU action 316 

Table 8-25: Summary of environmental, economic and social key impacts in 2030 Impacts Unit Option 

C-1 

Option 

D-3 

Option 

D-4a 

Option 

D-4b 

Option 

D-5 

Option 

D-6 

Option 

D-8 

Environmental impacts Reduction of direct F-gas emissions in 2030 kt CO2 eq 21,700 1,430 250 5,190 47,090 71,740 370 Reduction of indirect energy-related emissions in 2030 kt CO2 eq 514 n.a. 0 n.a. 716 1,583 n.a. Economic impacts Marginal emission abatement costs €/t CO2 eq 17 46 0.4 7 17 16 < 2 Direct net costs to sectors M€/year 528.6 66.4 0.01 37.5 1,055.0 1,500.0 0.55 Direct cost per operator €/year - 105.2 500 3.2 - - n.a. Social impactsEquipment investment cost M€/year 1,610.7 n.a. 0.1 2.5 2,860.2 5,612.8 0.3 Losses (-) from ceased service under Art 3+4 M€/year -289 71.3 n.a. n.a. -1,270.2 -1,355.7 n.a. Employment +++ ++ 0 + +++ +++ 0 
Annexes 317

ANNEXES 

Separate annex documents include: 

• Annex I: Questionnaires to authorities and industry 

• Annex II: Cost data 

• Annex III: Description of the model AnaFgas 

• Annex IV: Global Data Input Sheets 

• Annex V: EU Sector Sheets 

• Annex VI: Abatement technologies by sectors 

• Annex VII: Analysis of key impacts 
Abbreviations 318 

ABBREVIATIONS 

AC Air conditioning 

ACRIB Air Conditioning and Refrigeration Industry Board 

ADEME French Agency for the Environment and Energy Management 

AFBEL Spanish Association of high-voltage switchgear industry 

AFCE Alliance Froid Climatisation Environnement (France) 

AFEAS Alternative Fluorocarbons Environmental Acceptability Study (industry 

organisation) 

AHRI Air Conditioning, Heating and Refrigeration Institute (USA) 

AnaFgas Analysis of Fluorinated greenhouse gases in the EU-27 (model) 

ANIE Federazione Nazionale Imprese Elettrotecniche ed Elettroniche (Italy) 

AO Abatement Option 

AR Assessment Report 

AREA Air conditioning and Refrigeration European Association 

ASSURE European Association for Responsible Use of HFCs in Fire Fighting 

ATF/Italy Associazione dei Tecnici (Italy) 

BAT Best Available Techniques 

BAU Business as usual 

BREF BAT Reference Document 

BSRIA Building Services Research and Information Association 

BWP Bundesverband Wärmepumpe 

CAA Clean Air Act 

CAPIEL Coordinating Committee for the Associations of Manufacturers of Industrial 

Electrical Switchgear and Control 

Cat. Category 

CDM Clean Development Mechanism under the Kyoto Protocol 

CECED European Committee of Domestic Equipment Manufacturers 

CEFIC European Chemical Industry Council 

CEI Central European Initiative 

CFCs Chlorofluorocarbons 

CFF PU Sandwich panels with flexible facings, boardstock 

ChemKlimSchVO Chemikalien-Klimaschutz-Verordnung 

CIBSE Chartered Institution of Building Services Engineers 

CME PU sandwich panels with metal facings, continuous 

COP Conference of the Parties 

COR PU insulation for commercial refrigeration 

CRF Common Reporting Format 

CSS Carbon Capture and Storage 

DEC Department of Energy and Climate Change (UK) 

DEFRA Department for Environment, Food and Rural Affairs (UK) 

DIP PU Sandwich panels with metal facings, discontinuous 

DIS Data Input Sheets 

DKK Danish krone 

DKV Deutscher Kälte- und Klimatechnischer Verein (Germany) 

DNV Det Norske Veritas a classification society with the objective of "Safeguarding 

life, property, and the environment" 

DOR PU insulation for domestic refrigeration 

DPI Dry Powder Inhaler 
Abbreviations 319 

DTI Deutsches Tiefkühlinstitut (Germany) 

EC European Commission 

ECA Enhanced Capital Allowance 

ECCP European Climate Change Programme 

ECHA European Chemicals Agency 

ECSLA European Cold Storage and Logistics Association 

ECCA European Electronic Component Manufacturers Association 

EERC Estonian Environmental Research Centre 

EFCTC European Fluorocarbons Technical Committee 

EHPA European Heat Pump Association 

EIA Environmental Investigation Agency (non-governmental organization) 

ELV End of Life Vehicles 

ELV Emission Limit Value 

EMAS Eco-Management and Audit Scheme 

EMEA European Medicines Agency 

EN European norm 

EPA Environmental Protection Agency 

EPB Directive Energy Performance of Buildings Directive 

EPEE European Partnership for Energy and Environment 

ESIA European Semiconductor Industry Association 

ESO European Standardization Organizations 

EU-15 Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, 

Luxembourg, Netherlands, Portugal, Spain, Sweden, United Kingdom. 

EU-27 EU-15 plus Bulgaria, Cyprus, Czech Republic, Estonia, Hungary, Latvia, 

Lithuania, Malta, Poland, Romania, Slovakia and Slovenia. 

EU-ETS European Emissions Trading System 

EuP Directive Energy using Products Directive 

EURELECTRIC Union of the Electricity Industry 

EUROFEU The European Committee of the Manufacturers of Fire Protection Equipment 

and Fire Fighting Vehicles 

EUROSTAT Eurostatistics 

EVA European Vending Association 

ExCOM Executive Committee (of the Multilateral Funds) 

EXIBA European Extruded Polystyrene Insulation Board Association 

Exp. Expenses 

FAO Food and Agriculture Organization of the United Nations 

FEA European Aerosol Federation (Fédération Européenne des Aérosols) 

FPS Fire Protection System 

FSM Federated States of Micronesia 

GDP Gross Domestic Product 

GEF Green European Foundation 

GESTIS database on international limit values 

GGAP Greenhouse Gas Abatement Program 

GHG Greenhouse gas 

GINA Global Initiative for Asthma 

GSHP ground source heat pump 

GTP Global Temperature Potential 

GWP Global Warming Potential 

HARMONAC Harmonizing Air Conditioning Inspection and Audit Procedures in Tertiary 

Building Sector 

HBFCs Hydrobromofluorocarbons 
Abbreviations 320 

HC Hydrocarbon 

HCFCs Hydrochlorofluorocarbons 

HFCs Hydrofluorocarbons 

HEEP HFC Emissions Estimating Programme 

HVAC Heating, Ventilating, and Air Conditioning 

HV High Voltage 

HVS High Voltage Switchgear 

IEA International Energy Agency 

IEC International Electrotechnical Commission 

IED Industrial Emissions Directive 

IET International Emissions Trading 

IMPEL Implementation and Enforcement of Environmental Law 

IMS Health Intercontinental Medical Statistics Health 

INV Inventaires des émissions des fluides frigorigènes et de leurs émissions 

INT Integral foams for automotive and furniture sectors 

IPCC Intergovernmental Panel on Climate Change 

IPPC Integrated Pollution Prevention and Control 

ISO International Standard 

ISOPA European Diisocyanate and Polyol Producers Association 

JI Joint Implementation Mechanism under the Kyoto Protocol 

JRAIA Japanese Refrigeration and Air conditioning Industry Association 

KFCh National Refrigeration Forum (NRF) (Poland) 

KMO Danish Refrigerant Installers (organisation) 

LCD Liquid Crystal Displays 

LT Low Temperature 

MAC Mobile Air Conditioning 

MACC Marginal Abatement Cost Curve 

MEAs Multilateral Environmental Agreements 

MDI Metered-dose Inhalers 

MLF Multilateral Funds of the Montreal Protocol 

MOP Meeting of the Parties (to the Montreal Protocol) 

MS Member State 

MT Medium Temperature 

MV Medium Voltage 

NA North American 

NAMA National Appropriate Mitigation Action 

NERA National Economic Research Associates 

NGO Non-governmental organisation 

NIR National Inventory Report 

NMBC National Monitoring and Certification Body (Hungary) 

OCF One-Component Foam 

ODP Ozone Depletion Potential 

ODS Ozone Depleting Substances 

OEM Original Equipment Manufacturer 

OFN Oxygen Free Nitrogen 

ORC Organic Rankine Cycle 

PED Pressure Equipment Directive 

PFCs Perfluorocarbons 

ppm parts per million 
Abbreviations 321 

PRTR Pollutant Release and Transfer Register 

PU Polyurethane 

QPS Quarantine and Preshipment 

RAC refrigeration and air conditioning 

REACH Registration, Evaluation, Authorisation and Restriction of Chemicals 

RED (scenario) Reduction scenario 

RED10 (scenario) Reduction scenario incl. abatement at cost <10 €/t CO2 eq 

RRRD Recovery, recycling, reclamation, destruction 

RTRU PU insulation for refrigerated trucks and reefer containers (RTRU) 

SERCOBE Asociación Española de Fabricantes de Bienes de Equipo (Spain) 

SF6 Sulfur hexafluoride 

SIRAPA Portuguese Environment Protection Agency 

SKM Enviros Eco-Efficiency Study of Supermarket Refrigeration 

SNEFCCA French Association of companies active in the refrigerant sector 

SPVD Single Pressure Vessels Directive 

SRAC/HP stationary refrigeration, air conditioning and heat pumps 

SROC Special Report on Safeguarding the Ozone Layer and the Global Climate 

System by UNEP TEAP/IPCC (2005) 

SSA substances stable in air 

SWEDAC Swedish Board for Accreditation and Conformity Assessment 

SYKE Finnish Environment Institute 

T&D Europe European Association of the Electricity Transmission and Distribution 

Equipment and Services Industry 

TEAP Technology and Economic Assessment Panel 

TEWI Total Equivalent Warming Impact 

TFA Trifluoroacetic acid 

TOC Technical Options Committee 

TPED Transportable Pressure Equipment Directive 

uHFC Unsaturated HFCs 

UNECE United Nations Economic Commission for Europe 

UNEP United Nations Environment Programme 

UNESA Asociación Española de la Industria Eléctrica 

UNFCCC United Nations Framework Convention on Climate Change 

US EPA U.S. Environmental Protection Agency 

VAT Value added tax 

VDE Association for Electrical, Electronic and Information Technologies (Germany) 

VDKF-LEC Verband Deutscher Kälte-Klima-Fachbetriebe - Leakage and Energy Control 

VDKL Verband Deutscher Kühlhäuser und Kühllogistikunternehmen e.V (Germany) 

VDMA Verband Deutscher Maschinen- und Anlagenbau e.V. 

VdS 

Schadenverhütung 

Verband der Sachversicherer Schadenverhütung GmbH 

VOC Volatile Organic Compound 

VRF Variable Refrigerant Flow 

WAM (scenario) With Additional Measures (scenario) 

WEEE Waste Electrical and Electronic Equipment 

WM (scenario) With Measures (scenario) 

WOM (scenario) Without Measures (scenario) 

XPS Extruded polystyrene foam (insulation foam boards) 

ZVEI Zentralverband Elektrotechnik- und Elektronikindustrie e.V. (Germany)