AREA – the Airconditioning and Refrigeration European Association published a position paper on 25th October 2010 calling for a ban on pre-charging of non-monobloc AC equipment with flourinated gases. The text of the position paper is set out below in full. It should be read in conjunction with the AREA general position paper on the Review of the FGas Regulations published in amended form on the same day (see seperate news item).
INTRODUCTION AND BACKGROUND
As designers of refrigeration, air conditioning and heat pump systems (RACHP), RACHP contractors have a thorough expertise in the properties and manipulations of fluorinated gases. For this reason, AREA was deeply involved in the discussion and adoption of the F-Gas Regulation in 2006. AREA is now closely contributing to the ongoing review of the Regulation. Whereas a general position paper was adopted on 13th July 2010 and updated on 25th October 2010, AREA wishes to provide more detailed comments on the specific issue of pre-charged non-monobloc air conditioning equipment.
Regulation 303/2008 describes installation as “joining two or more pieces of equipment or circuits containing or designed to contain fluorinated greenhouse gas refrigerants, with a view to assembling a system in the location where it will be operated, including the action by which refrigerant conductors of a system are joined together to complete a refrigerant circuit irrespective of the need to charge the system after assembly”.
Pre-charged non-monobloc air conditioning systems consist of an indoor unit and an outdoor unit connected by refrigerant pipes. They are used in domestic or light commercial applications. According to the above definition, these systems should in principle be installed by certified companies regardless of the refrigerant charge. Indeed, putting this kind of equipment into service requires intervention on the refrigerant circuit.
Pre-charged non-monobloc air conditioning systems are widely found in retail outlets, DIY shops and supermarkets. Despite the legal requirement for professional installation by certified companies, the vast majority of this equipment is not put into service by certified installers. Many AREA members report regular requests for repair as a consequence of non-professional installation, which has resulted in a complete loss of the refrigerant charge.
There are various reasons for this situation: lack of information provided to the buyer, voluntary ignorance of the legal requirement in order to save installation costs, lack of controls. On the latter, one must admit that the current framework makes it difficult for competent authorities to perform controls. Indeed, once an individual acquires such equipment, the only efficient control would consist in requesting evidence from each and every buyer, individually, that the installation was done by a certified professional. Needless to say, such control is hardly performed.
The consequences of the practical breach of the F-Gas legislation are substantial:
Pre-charged non-monobloc air conditioning systems already account for a sizeable part of the quantities of fluorinated gases present in the European Union. The sales of this equipment are predicted to grow, all the more with the rapid development of split heat pumps, which have been recognised as a renewable energy source. AREA therefore believes that the ongoing review of the F-Gas Regulation should address this problem. Several solutions are described and commented on below.
1. Complementary measures
Several complementary measures could be implemented to ensure that buyers of pre-charged non-monobloc air-conditioning systems are fully aware of the legal requirement to use a certified installer. These measures include, amongst others:
Although these awareness-raising measures would be welcome, they would most likely have little effect on the rate of professional installation. Indeed, none of them addresses the difficulty of performing efficient controls, as described above. Yet the effective and efficient controls are essential to ensure compliance.
2. Alignment with the regime applicable to refrigerants in container
The F-Gas Regulation (Article 5, paragraph 4) provides that only certified installers can take delivery of fluorinated gases in containers. It could therefore be envisaged to extend this provision to fluorinated gases contained in pre-charged non-monobloc air conditioning equipment. In order to reinforce the certainty that only certified companies manipulate fluorinated gases, Article 5, paragraph 4 of the Regulation could also be amended to highlight that wholesalers/distributors can only sell fluorinated greenhouse gases to certified companies. This would ensure that the certification of the installer is verified before delivery of the refrigerant, as is currently the case in France, for instance.
In order not to unduly disturb or limit supply channels, one could envisage a system whereby once the equipment is acquired, physical delivery is taken by a certified installer designated by the buyer. Some may however argue that such a system would be somewhat cumbersome to put in place and run in practice.
3. Ban on pre-charge with fluorinated gases
The third solution could consist in banning pre-charging of fluorinated gases in non-monobloc air conditioning equipment. Instead, the equipment would hold a nitrogen charge in order to protect the oil in the system and avoid moisture in the pipes. Since the F-Gas Regulation provides that only certified installers can take delivery of fluorinated gases in containers, banning pre-charging in fluorinated gases would de facto guarantee installation by a certified professional. In order to ensure full efficiency of the proposal, the latter should be accompanied with a modification of Article 5, paragraph 4 of the F-Gas Regulation, as indicated above.
In addition to ensuring compliance with the F-Gas Regulation, this solution has many benefits:
The lack of compliance on installation of pre-charged non-monobloc air conditioning equipment by certified professionals is widely acknowledged. In addition to the mere breach of the F-Gas legislation, this undoubtedly results in additional leaks of fluorinated gases in the atmosphere, which goes precisely against the spirit and objectives of the Regulation. The need to address this issue is therefore undisputable.
With this position, AREA has tried to present and assess the various possibilities offered to the legislator. The analysis shows that banning pre-charging with fluorinated gases would appear as the most appropriate and cost-effective solution, coupled with a modification of Article 5, paragraph 4 of the F-Gas Regulation. AREA therefore calls on European decision-makers to give due consideration to this possibility in order to ensure full compliance with the F-Gas legislation and further reduce emissions of greenhouse refrigerants. Our association wishes to make its structure and expertise available to further discuss the option.
Visit the AREA website at www.area-eur.be for a copy of the original paper.