Fact-sheet: Industrial greenhouse gases: HFCs, PFCs and SF6

HFCs are used or have been used as refrigerants and for expanding plastic foam. PFCs are refrigerants, and SF6 has primarily been used for sound insulation in windows.

The use of HFCs, PFCs and SF6 is regulated in:

1. Statutory Order on regulations for certain industrial greenhouse gases
2. Regulation on certain fluorinated greenhouse gases

Danish regulations governing fluorinated greenhouse gases

It is generally prohibited to import, sell and use fluorinated greenhouse gases (HFCs (except for HFOs), PFCs and SF6) as well as new products containing these gase

Exemptions from the Danish regulations

There are exceptions for, among others,

• High-voltage systems over a certain size (voltages over 1 kV)
• Heat pumps and cooling systems for heat recovery with a filling of 50 kg or less, which are pre-assembled from the factory in a compact cabinet, primarily assembled by welding or soldering
• Cooling systems, air conditioning systems (comfort cooling), dehumidifiers and other heat pumps with fillings equivalent to 5 tons of CO2 equivalents or less
• Other cooling systems with a filling between 0.15 and 10 kg, which are pre-assembled from the factory in a compact cabinet, primarily assembled by welding or soldering Mobile systems

Servicing of cooling systems, air conditioning systems, heat pumps and dehumidifiers

The industrial use of the stated greenhouse gases is not covered by the regulation, except for protective gas in light metal foundries and the production of flexible foam plastic. Industrial use means the use for the production of a commodity, where the greenhouse gas is not found in the finished product.

Products for export are not covered by the ban. It is permitted to produce, for example, refrigerators and other products with HFC in Denmark, if the products are exported. It is also allowed to import HFC for a product that is to be exported.

Exemptions from the Danish regulations

The Environmental Agency may, in very special cases, allow the rules in the regulation to be deviated from.

It is generally possible to be granted an exemption if:

1. No alternatives exist
2. The alternatives cannot be used
3. There are unreasonable costs associated with using the alternatives
4. Use of the alternatives would lead to greater greenhouse gas emissions

Environmental considerations will always weigh heavily in a decision on dispensation.

An application must be made for a dispensation to use greenhouse gases in new installations such as cooling systems, heat pumps, air conditioning systems and dehumidifiers, which are not covered by the exceptions to the regulation.

The Environmental Agency has developed a guide that can be used by anyone who wishes to apply for a dispensation from the rules.

Guidance for dispensation applications

Normally, the processing time for dispensation applications is a maximum of 4 weeks.

EU regulations governing certain fluorinated greenhouse gases

The European Union has adopted a Regulation governing industrial greenhouse gases. The EU regulations apply to new and existing systems.

The most important EU regulations are:

Systems must be installed and serviced by authorized personnel

To work with systems with less than 2.5 kg of refrigerant fillings, at least a category II authorization is required. The rules are found in implementing regulation (EU) 2015/2067 of November 17, 2015, which sets up special qualification requirements for work with refrigerant fillings under 3 kg. In practice, however, the limit is 2.5 kg, as the rules of the Danish Working Environment Authority require that one is a refrigeration technician when dealing with fillings over 2.5 kg.

Qualification requirements for installing and servicing refrigeration, air conditioning and heat pump equipment  (in danish)

Qualification requirements for servicing air conditioning equipment in cars  (in danish)

Operators must perform regular inspections

Operators are required to ensure that a number of systems are checked for leaks by authorised personnel according to the following schedule:

1. For systems or equipment containing fluorinated greenhouse gases in quantities between 5 and 50 tonnes of CO2 equivalents, at least every 12 months, or if a leak detection system is installed, at least every 24 months

2. For systems or equipment containing fluorinated greenhouse gases in quantities between 50 and 500 tonnes of CO2 equivalents, at least every six months or, if a leak detection system is installed, at least every 12 months

3. For systems or equipment containing fluorinated greenhouse gases in quantities of 500 tonnes of CO2 equivalents or more, at least every three months or, if a leak detection system is installed, at least every six months

Certain types of systems and equipment are exempt from leakage control, including hermetically sealed systems and hermetically sealed equipment, which contain fluorinated greenhouse gases in quantities of less than 10 tonnes of CO2 equivalents and are labeled as hermetically sealed

Operators must establish a detection system

Operators of certain systems or equipment containing fluorinated greenhouse gases in quantities of 500 tonnes of CO2 equivalents or more are obliged to ensure that the system/equipment is equipped with a leak detection system that alerts the operator or the company responsible for servicing the system/equipment if there is a leakage of fluorinated greenhouse gases from the system/equipment. The leak detection system must be checked at least every 12 months for most systems/equipment

Operators must maintain a log book

Operators of certain systems or equipment containing fluorinated greenhouse gases in quantities of 500 tonnes of CO2 equivalents or more are obliged to keep a log with specific information about the system/equipment, including the quantity and type of fluorinated greenhouse gases in the system/equipment, the quantity of recovered gases, maintenance and servicing, etc.

Manufacturers must take precautions

Manufacturers of fluorinated greenhouse gases are obliged to take all necessary precautions to limit the leakage of gases as much as possible during production, transport, and storage. This also applies when fluorinated greenhouse gases are produced as by-products.

Operators must ensure recovery

Operators of certain systems, etc., containing fluorinated greenhouse gases, must ensure that the gases are recovered by authorized persons so that the gases are recycled, regenerated, or destroyed

Reporting

For companies that produce, import, export, destroy, use and market fluorinated greenhouse gases, a number of reporting obligations apply in relation to the EU Commission. Among other things, companies that produce, import or export more than 1 ton of fluorinated greenhouse gases or 100 tons of CO2 equivalents or more, must submit a range of information each year

Products and systems must be labelled

Certain products and systems using fluorinated greenhouse gases may only be marketed if they are labelled. The final labelling requirements have not yet been determined.

Some fluorinated greenhouse gases may not be used

The regulation contains a limitation on the use of certain greenhouse gases for specific purposes.

From January 1, 2020, it is also prohibited to use fluorinated greenhouse gases with a global warming potential of 2500 or more to service or maintain refrigeration systems or equipment with a filling size of 40 tons of CO2 equivalents or more, except for defecse material and systems/equipment intended to be used to cool products to temperatures below -50 °C.

The prohibition does not apply to the following categories of fluorinated greenhouse gases:

1. Regenerated fluorinated greenhouse gases with a global warming potential of 2500 or more, used for the maintenance or servicing of existing refrigeration systems or equipment, provided they are properly labelled.

2. Recycled fluorinated greenhouse gases with a global warming potential of 2500 or more, used for the maintenance or servicing of existing refrigeration systems or equipment, provided they are recovered from such systems or equipment. Such recycled gases may only be used by the company that carried out the recovery as part of maintenance or servicing, or the company for whom the recovery was carried out as part of maintenance or servicing.

Transition period – strictest regulations apply

The Regulation (EU regulation) permits Member States to retain special national regulations. Enterprises are therefore required to comply with both the Danish Statutory Order and the EC-Regulation. If the Regulation and the Statutory Order regulate the same area, the strictest regulation will always apply.

Producers, importers, distributors and users are responsible

Everyone who produces, imports, sells and uses fluorinated greenhouse gases or systems/equipment that contain fluorinated greenhouse gases is responsible for complying with the rules.

Both the seller and buyer of fluorinated greenhouse gases for the purpose of installing, servicing, maintaining or repairing systems or equipment for which authorization or training certificates are required, must ensure that the executing company has the relevant authorizations or training certificates or employs people who have the relevant authorizations or training certificates.

Systems or equipment that are not hermetically sealed and are filled with fluorinated greenhouse gases may only be sold to the end user if it is accompanied by documentation that the installation will be carried out by an authorized company.

Other legislation

Industrial greenhouse gases are also covered by the Danish Act concerning taxes on certain ozone layer depleting substances and industrial greenhouse gases, administered by SKAT (the Danish tax authorities).

The tax act levies a green tax on the import of fluorinated greenhouse gases, to be paid to the Danish Government. The tax on industrial greenhouse gases is differentiated – the gases with the greatest impact on climate are subject to the highest tax level.

The Danish Working Environment Authority also has regulations for the working environment which must be complied with.

Control

The Danish Environmental Protection Agency’s chemical inspectors monitor compliance with the regulations and will ensure that illegal situations are brought into compliance. This may involve withdrawing the product from the Danish market, or making the product legal in some other way. Anyone who breaches the regulations may additionally face a fine or prison sentence of up to two years.