New GB Air Conditioning and Refrigeration Industry F-gas and ODS Reporting and Quota System

In a previous article written in December 2020, we talked about Brexit and its effects on the air conditioning and refrigeration industry with respect to fluorinated greenhouse gases (F-gas) and ozone-depleting substances (ODS) recording and reporting from 1 January 2021. With our departure from the European Union (EU) the UK will now take over its own regulation of F-gas like hydrofluorocarbons (HFCs), chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), carbon tetrachloride and methyl bromide and ODS like CFCs and HCFCs.

Continued Phase Out of Harmful Greenhouse Gases

The UK government has been clear that despite leaving the EU their commitment to the existing environmental regulations remains steadfast. They will continue in their resolve to reduce and minimise emissions of ozone depleting and fluorinated greenhouse gases as “the continued phase out of harmful greenhouse gases is critical to the global fight against climate change.”

This was emphasised by the Department for Environment, Food & Rural Affairs (DEFRA) when they stated: “The implementation of the F-Gas Regulations will continue exactly as it is at present after the UK leaves the EU. All existing certification will remain valid and the UK intends to continue recognising certificates issued in other EU member states prior to the leave date.”

F-gas and ODS Legislation

Great Britain (GB) F-gas and ODS legislation will now be governed by DEFRA. The legislation will effectively transfer the requirements of the current EU regulations into GB legislation law for regulating ODS and F-gas in GB. This includes the principle ODS and F-gas Regulations (Regulation (EC) No 1005/2009) that lays down rules on the production, import, export, placing on the market, use, recovery, recycling, reclama­tion and destruction of substances that deplete the ozone layer, on the reporting of information related to those substances and on the import, export, placing on the market and use of products and equipment containing or relying on those substances that deplete the ozone layer (the ODS Regulation) and Regulation (EU) No 517/2014 on fluorinated greenhouse gases (the F-gas Regulation) and related implementing legislation. Secondary legislation will address EU law that was copied into GB law to ensure its operability in Great Britain.

The UK will continue to restrict the use of ODS and maintain the phase-down schedule for F-gas, reducing F-gas on the market by 79% by 2030 relative to a 2009 to 2012 baseline. That means UK F-gas quotas will follow the same phase down steps as the EU and be limited to 63% of the baseline in 2019 and 2020, reducing to 45% of the baseline in 2021. Most of the rules for F-gas and ODS will not change. However, you will need to use new UK IT systems to manage quotas and report on use.

F-gas and ODS Obligations and Responsibilities

As with regulations and legislation the obligations and responsibilities that have been required in the past with respect to recording refrigerant usage, maintaining and monitoring systems for leaks will continue after 1 January 2021. These are:

• To prevent intentional release of F gases
• To prevent the unintentional release of F gases during production and use
• To minimise and repair leakages
• To check leaks and keep records
• To use leakage detection systems
• To provide evidence that trifluoromethane produced during the production of F gases has been destroyed
• To recover F gases from equipment for recycling, reclamation or destruction
• On placing certain products and equipment on the market
• On sales of F gases to businesses which do not hold the relevant certificates or attestations
• For correct product and equipment labelling
• On the use of certain F gases for magnesium die-casting, vehicle tyres or servicing certain refrigeration equipment.

UK requirements will also remain the same when it comes to individual qualifications and company certification and registration relating to any person or company you need to install, service, maintain, repair, decommission or check for leaks in refrigeration, air conditioning and heat pump equipment (SRACHP) and any refrigerant charging or recovery works.

In the case of ODS responsibilities will continue:

• To maintain equipment
• Control leaks.

Recording and Reporting F-gas

Any companies or individuals who produce or import F-gas must keep records along with any F-gas that is destroyed, the technologies used to destroy the gases and the quantity of each of the gases in stock at the end of the year that are waiting to be destroyed.

Any F-gas produced, imported or exported must be reported depending on certain limits as explained in the report F-gas section of the record and report F gas and equipment you produce, import or export page. HFCs equivalent to 10,000 tonnes of CO2 in the previous calendar year must be reported and an independent verifier must verify your report.

All reports must be made by 31 March of the year after the reporting year. EU (including GB) F-gas activity between 1 January and 31 December 2020 should be reported on the EU system by 31 March 2021. GB F gas activity between 1 January and 31 December 2021 should go on the GB reporting system by 31 March 2022. To get an organisation ID for the GB reporting system you need to register for a GB F-gas account. Verification report must be submitted by 30 June each year for data on the previous calendar year.

F-Gas Quotas

Where a company produces, imports or exports HFCs or products containing HFCs they need to apply for a UK quota to place them on the GB market and an EU quota to place them on the EU and Northern Ireland market by registering for a fluorinated gas (F gas) account. Full details on F-Gas quotas can be found at “Fluorinated gas (F gas): guidance for users, producers and traders”.

Further Changes

It’s reported that later in the year F-gas regulation will go out for consultation for amendments in 2023. With this consolation further changes to F-gas and ODS may result. Watch this space.

Synecore For Air Conditioning and Refrigeration Compliance

Synecore have the in-house expertise to ensure your business remains F-gas complaint and to ensure your air conditioning or refrigeration system continues to work at peak efficiency. Based in Detling in Kent, we work with businesses throughout Kent, London and the UK, providing commercial and industrial clients with the very best in air conditioning maintenance and refrigeration maintenance. Contact Synecore via our contact form or on 01795 509 509. Our team will book an appointment for one of our engineers to visit your site and discuss your options.