The European Commission (EC) has found that an ambitious proposed revision of the EU F-gas Regulation would be in line with the objectives of the REPowerEU plan, which includes doubling the rate of deployment of heat pumps to reduce fossil fuels usage.

The EC published alongside the revised proposal a detailed economic explanation, which contains a dedicated section showing how a stricter EU F-gas Regulation would be consistent with REPowerEU.

In its analysis, the EC says that proposed f-gas prohibitions reflect market reality and the status of alternative technology. The proposed f-gas bans in 2027 for split-system heat pumps, it adds, grant sufficient time to let manufacturers scale up the production of climate-aligned natural refrigerant equipment.

The Cool Technologies database, hosted by NGOs Environmental Investigation Agency (EIA) and Greenpeace, lists over 100 different natural refrigerants-based heat pump models available today. In addition, international standards have been revised to support the uptake of larger charges of flammable refrigerants like propane (R290), up to 998g (0.2lbs). These deliver higher system capacities. Training institutions are also providing update courses targeting hydrocarbon-based split air-conditioning.

Haier new R290 split air-to-air system to be marketed in the European market in 2023

ATMOsphere, publisher of, undertook research in the domestic heat pump sector, finding that market operators are ready to scale up production and deliver on the REPowerEU plan.

ATMOsphere, Accelerating the EU’s shift towards natural refrigerant domestic heat pumps

Will there be enough HFCs?

Various Brussels-based, industry-led organizations have called for a more conservative approach in the revision of the EU F-gas Regulation, especially with regard to bans and quotas, claiming that the proposed phase down is really a “phase out.”

However, the EC analyzed the compatibility of higher ambition in the HFC phase down with the needs to accelerate the deployment of heat pumps, finding no misalignment.

For example, says the EC:

  • A swifter uptake of heat pumps in line with REPowerEU would require a small number of f-gas quotas in relation to the availability in the market in the period from 2024 to 2026. The EC reports that, for instance, “to deploy 9.5 million hydronic heat pumps and 4.9 million single split heat pumps in the 2024–2026 period would increase annual demand for quotas by approximately 3.1 MtCO2e in 2024, 2.7 MtCO2e in 2025 and 1.5 MtCO2e in 2026.” These annual quotas, however, are a small amount in comparison with the 41.7 Mt CO2e of total quotas available during the same period, according to the proposed phase-down schedule, accounting for about 17%.
  • Up to 70 MtCO2e of unused f-gas quota authorizations have been banked by market operators, an amount estimated to be able to satisfy the market for up to seven years.
European Commission analysis of banked RACHP HFCs quotas
  • In the event of a market disruption, the EC is empowered to exclude sectors, such as that of heat pumps, from the phase-down schedule, according to Article 16(4).

Both the F-gas Regulation and REPowerEU are further supported by the fact that in refrigeration, air-conditioning and heat pump sectors there is a clear trend towards using refrigerants with lower GWP, reducing the need for f-gases.

Coupling training with market needs

Adequate training of technicians on the installation and upkeep of hydrocarbon equipment is also needed to ensure a smooth transition to products containing flammable refrigerants, noted Stephen Benton, Director of Cool Concerns, a U.K.-based training consultancy.

He encourages coupling training on flammability with actual market needs, educating technicians ahead of time when end users will need installation services and equipment maintenance.

In addition, he reported that flammability update courses for technicians already qualified to operate with fluorinated gases can last less than two days, with both theoretical and practical knowledge provided.

“The courses raise awareness of the properties of flammable refrigerants, focusing technicians on aspects that differ from handling non flammable refrigerants, such as flammable zones, sources of ignition, risk mitigation and differences with service equipment,” explained Benton. “The training is not a problem, it is already established for these substances and we have delivered it successfully since the late 90s.”

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