AREA Final Position on Article 10 of the F-gas Regulation

Date: 18 June 2024

Introduction: AREA, the European association of refrigeration, air conditioning, and heat pump (RACHP) contractors, strongly supports a transition to alternatives to F-gases. However, there are significant concerns regarding the current level of training on alternative refrigerants among F-gas certified personnel. Ensuring adequate training and certification is crucial to avoid accidents and ensure the safe handling of these refrigerants, many of which are flammable.

Support for F-gas Certification Scheme Extension: AREA welcomes the extension of the F-gas certification scheme to include alternative refrigerants in the new F-gas Regulation. This addition is necessary to ensure the safe, efficient, and reliable handling of these refrigerants. The certification structure will help mitigate risks and is essential for a successful transition from F-gases to low GWP refrigerants. The definitions and categories of certification in the implementing act provide the needed clarity to align with European climate ambitions and the energy transition.

Certification Structure: AREA supports the new certification structure that includes five categories, as outlined in Article 3 of the draft Implementing Act. The majority of residential heat pumps in the near term will contain either F-gases or hydrocarbons, which share enough technical similarities to be grouped in the same category (A). AREA recommends allowing qualifications for F-gases and flammables only to prevent a shortage of skilled technicians in the sector.

Clarification on Terminology: The terms "flammable" and "hydrocarbons" are used in the Regulation and the Implementing Act. To ensure correct implementation, AREA suggests specifying "Hydrocarbons and other flammables" in the Implementing Act.

Proposed Demarcation for Residential Market: AREA proposes a practical smaller category (A) for the residential heat pump and air conditioning market:

A1: All F-gas or hydrocarbons systems, without charge limitation.
A2: Smaller heat pumps and air conditioning systems: ≤1kg hydrocarbons and ≤3kg F-gas or ≤12 kW rated capacity. The distinction can be based on refrigerant charge or rated capacity.

Separate Categories for CO2 and Ammonia: Refrigeration equipment and heat pumps containing CO2 and ammonia differ significantly from those using F-gases or hydrocarbons. Thus, AREA supports creating separate categories:

B: For CO2
C: For ammonia

Flexibility in Certification: The possibility of combining certificate types offers appropriate flexibility depending on the skills required for technician activities.

Validity of Certificates: AREA suggests clarifying the deadline in Article 10 (a): “Holders of Categories I and II certificates under Article 3(2) of Commission Implementing Regulation (EU) 2015/2067 are only allowed to continue using those certificates after 12 March 2029 if they update their knowledge and skills…”

Comments on Annex 1: AREA members have provided detailed comments on Annex 1, which outlines the minimum requirements for skills and knowledge to be covered by evaluation bodies.

Conclusion: AREA members are confident that the new certification structure will ensure a safe transition to alternative refrigerants, maintaining the required skill levels within the industry.

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