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IRI December 8, 2010 0 Comments

The European Partnership for Energy and the Environment (EPEE) has rejected the call from AREA to ban pre-charged non-monobloc AC equipment. The Director General of EPEE, Andrea Voigt, wrote to the President of AREA, Graham Fox, on 23rd November 2010 and set out the position of EPEE members with regard to AREA’s proposed ban on pre-charged non-monobloc equipment. A copy of his letter is given below.

Founded in September 2000, The European Partnership for Energy and the Environment (EPEE) is composed of 40 companies, national and international associations, producing a/c equipment, components, refrigeration systems, heat pumps and refrigerants. EPEE members employ more than 200,000 people in Europe and their combined turnover exceeds 30 Billion Euro. For more details see www.epeeglobal.org

Brussels, 23 November 2010

Dear Mr Fox,

Thank you very much for your additional explanations on AREA’s position on pre- charged non-monobloc equipment. EPEE asked its air conditioning and heat pump equipment manufacturers for their views about your proposal to ban pre-charging this type of equipment.

Whilst they of course agree with you that the aim of the current review of the F-Gas Regulation is to make it more effective, they warn that an outright ban as proposed by AREA will have environmental and economical consequences that do not justify such a measure.

Indeed, EPEE members strongly support that installation and servicing work on a refrigerant circuit is carried out by professionals only. However, we feel that a ban of pre-charged equipment does not solve the problem of increased emissions due to uncertified installation and service.

The merits of pre-charging are significant for the performance, reliability and tightness of systems.

Products are precharged in a factory environment because each individual unit is undergoing a running test. In a fully controlled environment as it is the case of the manufacturing base, refrigerant charging is more accurate than in the field. This allows optimizing the refrigerant charge and ensuring the tightness of the unit, thus achieving higher reliability and performance.

Manufacturers of equipment have made considerable efforts to reduce refrigerant losses during charging. Such losses have dropped in the past 10 years from 4% to less than 0.2%. Such a result is hardly to be achieved in the field where such precise instruments are not available or affordable for contractors. Also ambient temperatures make precise charging in the field much more difficult compared to charging at factory temperatures.

In case a system is not charged with the correct amount of refrigerant, effects on performance and equipment reliability become prominent. For example, a 10% undercharging of refrigerant may cause 25% additional energy consumption. See for example, BRECSU “Best practice guide N°178” – Enrei study UK. On the other hand, overcharged systems may cause product failures, especially on the compressor.

Refrigerant field charge takes a long time: When equipment is shipped without refrigerant it needs to be filled with nitrogen. This is long to evacuate on site which may result in an economical disadvantage for the installer and end-user. If the vacuum is not applied long enough, the result will be similar to incorrect refrigerant charges

1. A ban on pre-charging would add additional steps in the lifecycle entailing leakage risks and unnecessary refrigerant waste. This would increase the costs of the unit for installers and end-users:

From a manufacturing view point, the AREA proposal means that manufacturers would have to charge the units with refrigerant to test the performance, to then de-charge the units and to then pre-charge them with nitrogen for shipping.

De-charging in the factory to charge again in the field are 2 additional steps in the lifecycle which may cause additional leakages. In addition, CO2 emissions due to refrigerant handling itself will increase. Instead of supplying larger ton tanks to factories, refrigerant suppliers will have to sell such quantities in smaller bottles for the installers. This will increase both direct and indirect emissions (due to additional transport routes for refrigerant).

During de-charging, it is not possible to remove all the gas from a unit as some of it will remain in the compressor. There is a high risk that this would escape into atmosphere at the installers’ site as he releases the Nitrogen/reclaim and vacuums the unit.

2. The reclaimed F-gas due to the performance testing in the factory cannot be used as such again as it will be contaminated with compressor oil or waste.

The reclaimed gas would need to be sent back as waste to the gas suppliers for cleaning and balancing. This would dramatically increase the amount of waste gas in the supply chain: The gas would need to be contained in suitable containers and the potential of leakages would significantly increase.

Highly specialized equipment would be required to reclaim at this volume level – at present it is not readily available and the gas suppliers are NOT set up to manage a full supply chain of reclaimed gas. The operation would therefore not be cost neutral. The installation costs will increase due to higher production costs and longer handling time for contractors. Also refrigerant costs for contractors are higher compared to costs for equipment manufacturers. These additional costs will finally come at the expense of the end-user.

3. The measure would only address the issue of non certified installation work but not the non certified servicing or recovery activities, which are most essential for avoiding emissions during lifetime and at end of life.

There are already other legislative drivers in the EU to guarantee proper installation work. For example for consumer goods, including residential air conditioners and heat pump products at least 2 years warranty has to be given to the endusers. This is a financial driver for contractors to assure that the installation is carried out properly and tight (Directive 1999/44/EC). In addition, in the case of heat pumps, the Directive on the promotion of renewable energy sources stipulates that all member states have to set up a system of qualification for heat pump installers. Therefore, national programs have been set up to improve the skills of heat pump installers.

I very much hope that the above argumentation will be of interest to AREA and that it will help us to jointly agree on an alternative solution for the current situation.

I believe it is essential that we can continue our constructive dialogue to strengthen system control and management in order to exclude unqualified installation and reduce f-gas leakages and emissions.

Andrea Voigt

Director General of EPEE