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Make plans on F-Gas – or pay the cost

RAC’s F-Gas Question Time saw a strong consensus that planning needs to start now on moving away from higher-GWP gases such as R404A


Ray Gluckman, Gluckman Consulting

Mike Nankivell, ACRIB F-Gas Implementation Group

Mark Hughes, DuPont Chemours

Patrick Amrhein, Honeywell

Graham Wright, HEVAC

Paul Alway, Marks and Spencer

What we know now and what we need to do next

Ray Gluckman

I am mainly going to concentrate on what the industry needs to do and to ask the question as to whether we are doing it yet and what needs to be done.

F-Gas started taking effect this year, and most of the aspects of the old regulation apply, although most of those features are slightly strengthened in one way or another.

I am going to mainly concentrate on the HFC phasedown aspect – as most of you will know, we have [ultimately] got to make an 80 per cent cut in consumption, we have a quota system and we have some bans.

One of these has kicked in already and that applies to domestic equipment.

Then there is the service ban in 2020 for very high-GWP equipment and that is a very important aspect we will return to later.

We also have some details around the leak checking requirement that are causing many people to scratch their heads, which Mike Nankivell will talk about.

But I want to concentrate on the big challenge, which is around the phasedown. As seen from the slide [see table, right], we start at 100 per cent and step down. Let’s start by remembering that this is all measured in tonnes of CO2 equivalent, so we are not talking about a specific tonnage, it depends wharefrigerant people buy. If we talk about tonnes of R404A for instance, with a GWP of nearly 4000, then there is an awful lot less that we can buy than R32, which has a GWP of 675.

We have a quiet period this year, as we have the same quota we had in 2014, plus whatever everyone has been stockpiling in anticipation.

So one feels that might not be difficult. Next year and the year after, there will be a 7 per cent cut in quota, which is not massive.

But in 2018 we see a massive 37 per cent cut – this is only the headline number, because there is roughly a further 10 per cent cut in sales resulting from  what are known as ‘pre-charge controls’.

This refers to the fact that anyone importing pre-charged equipment will have to take the refrigerant for their pre-charge out of the quota. It is also two years before the service ban is mandated by the regulation in 2020.

The cut in 2021 is also worth thinking about now, because by this time it will be a 55 per cent headline cut, plus the impact from the pre-charged imports.

So the early challenge will be that 2018 cut of well over 40 per cent in historic use and the 2021 cut of well over 60 per cent.

We need to get the message across that this is do-able but only if people need get off their backsides and actually do something about it. So the question is – what do we need to do?

Another point to bear in mind is that we in the UK have no particular right to any proportion of the quota – there is no guarantee that distribution of HFCs across the EU will be fair. Just because the UK has 12 per cent of the population doesn’t guarantee that it will get an equivalent proportion of gas.

There are two sources of competition – other EU countries and other industries, such as plastics and foam.

RAC and heat pumps dominate consumption so RAC will take the lion’s share, but whoever is willing to pay the piper plays the tune.

I have started talking about four core actions that we can take to reduce HFC consumption:

  • We should start using lower-GWP refrigerants for new equipment. That one is a must.
  • In some situations we can use the lower-GWP refrigerants in existing equipment. That mainly applies to the larger systems with R404A – and those are also mainly affected by the service ban in 2020.
  • We can reduce leakage. We mustn’t neglect the objectives from the old regulation – they still apply. Over 50 per cent of the current consumption of gas goes towards topping up leaked systems.
  • So if we could cut leakage by 50 per cent say – which some supermarkets have shown they can do – that makes a massive contribution.
  • Finally, we need to make sure that we have good end-of-life recovery of and that we begin to use the reclaimed gas. This has not been a big market yet in HFCs in the past few years, but by 2020 a lot of equipment will be reaching end of life and reclaim will become more important.

The emphasis of what one does varies according to the various sectors of the industry, but the calculations that people have done show that if supermarkets don’t get to grips with getting rid of R404A from existing estates, we won’t meet the target in 2018.

So we’ve got to look at retrofill in R404A systems and leak prevention in the supermarket sector as a high priority.

That, of course, will be supported by low-GWP new systems, but if you think about a typical 15-year lifecycle of the equipment, you are only replacing a 15th of the estate per year and we won’t achieve that 40 per cent cut by new equipment alone.

You have to replace the R440A – anybody buying brand new 404A in 2015 is completely bonkers – I have said it before, as there are a number of refrigerants to replace it, as we will doubtless hear from our sponsors later.

CO2 refrigeration is of course being used increasingly in supermarkets and that will be a massive step, but will take a relatively long time for that to occur.Small split system air conditioning makes an interesting contrast as the market is growing rapidly, and they don’t tend to leak much, yet there is not a lot of opportunity to retrofit with another refrigerant.

So the first two supermarket options don’t really apply – this market needs to think about new equipment.

Here we are talking about moving away from R410A, which has a GWP of 2088, towards, for example, R32, which has a GWP a third of that; or the new blends being developed such as R446A and R447A.

The average GWP of what we bought in 2013 was 2000, so if we apply the 80 per cent cut required by 2030, we need to get to an average GWP of 400. That is a basket of everything we buy, including gas for maintenance.

It is going to be an interesting journey as the current HFCs have a lot of ticks in the box, but the big cross is a high GWP and so they have to go.

The replacement refrigerants often have one or more disadvantages such as mild flammability or toxicity, but their key advantage is low-GWP.

We have been in the happy land of having lots of non-flammable refrigerants, but now we have to learn to work with a degree of flammability.

Among the various new HFOs and blends, in the ultralow category we have R1234yf and R1234ze, which have similar characteristics to R134a, making them good for certain sectors but not others.

We have nothing in the low band, so we are looking at these moderate-GWP refrigerants which are mainly 2L or mildly flammable.

My own view is that we will not get to the phasedown target without using 2L.

I am not afraid of the 2L banding but we don’t have a lot of operating experience yet. Interestingly ammonia is also a 2L and we have worked for a long time with that, with almost no accidents due to flammability (though there have been some issues over the years due to toxicity).

So we need to push the boundaries, with equipment manufacturers, component suppliers and contractors – and particularly the standards committees – getting used to working with it.

We are not likely to get a new version of the refrigerant standard EN378 till 2016, it looks like, and that will slow down the adoption of 2L refrigerants.

To summarise – the cuts are really challenging, so we need to convince people that they can’t sit back for too long. If by next year we aren’t seeing more activity out in the market, we should get worried.

F-Gas legislation in practice

Mike Nankivell

The F-Gas Implementation group was set up about ten years ago to work with Defra and the EU on the original F-Gas legislation.

The original legislation was seen as effective but didn’t quite meet the carbon reduction targets the EU had set out, so the new F-Gas Regulation was developed to tackle this.

The new law strengthens the existing measures around containment, recovery, certification and sale of F-gases, but introduces a number of new measures such as bans, as Ray has covered, as well as some new requirements on labelling and advertising the gases and the equipment.

There is a new threshold on leak checking, which applied from January 1 this year, but for equipment containing under 3 kg it won’t apply until 2017.

Of course the key difference is that this now requires the thresholds to be calculated in CO2 equivalent not volume. This has caused some confusion butthere is now a lot of advice and apps available to help.

In particular there are major differences to the thresholds for R404A equipment, bringing new systems into scope, so that is something people need to be aware of [see table].

ACRIB has also produced a ready reckoner, which can be downloaded from www.acrib.org.uk.

In training and certification there have been some differences in requirement, but those technicians who have F-Gas certificates will not need to retake them.

However, those that took the CITB J11 route will see new information at the time of their reassessments.

Essentially, the new information will carry updated F-Gas information and greater detail on HFC alternatives.

Since the beginning of the year, we have seen a marked increase in the number of technicians holding individual certificates in the UK – by the end of March we had 33,160 registered to CITB J11 or C&G 2079 level.

And company certifications have also increased – by some 17 per cent to 6274. It is an encouraging set of numbers.

There are restrictions on the supply of F-gases.

They can only be supplied in bulk to undertakings holding the appropriate certification. It doesn’t prevent noncertified companies transporting the refrigerant from the supplier to the end-user.

As I have said before, there doesn’t seem to be the same level of control over supply of pre-charged equipment. It puzzled me as to why the regulations only referred to supplying to the end-user.

All I can say is that Defra has now confirmed that there is no restriction on buying pre-charged equipment without certification if you are not an end-user. People will no doubt see this as a loophole.

There are a lot of companies who don’t carry F-Gas certificates because they are just a subcontractor for the installer. I don’t see this as too much of a problem as there is a voluntary  code among suppliers to carry out the F-Gas checks on anyone, whether they are end-users or not.

Taking my company as an example, if those subcontractors can show proof of certification from the end-user, then they can be supplied.

There is useful information available at the ACRIB website [acrib.org.uk] including a new guide from Epee, which is based on questions from their members, answered by the EU. I recommend it as an easy-to read guide.

Also downloadable is a guide for contractors from European contractors body AREA, and a range of guidance sheets from the EC itself.

Ray Gluckman has also produced a range of guidance for Defra, available from: gluckmanconsulting.com/f-gas-information-sheets.

Since the last Question Time we have had the public consultation from Defra on UK enforcement of penalties. That consultation had responses generally accepting the proposals.

A key part of ACRIB’s response was to strongly recommend a national registration scheme to aid compliance. At the moment, there is no simple means of an end-user verifying a technician’s certification or qualifications.

We have recently had a meeting with Defra and they seemed to accept that it is a good idea but they are concerned about the cost and the industry’s ability to pay for it.

This is also an issue being pursued by AREA on a Europe-wide basis, looking at all the member states that operate a database. Hopefully in the next few months, we will have feedback from the EC on this.

Of course I should say that we already have several registration schemes in the UK – Refcom, Quidos and Bureau Veritas – but they are voluntary and it would seem logical to get a mandatory scheme set up.

There were concerns at the last Question Time about the Environment Agency and how the Regulation was to be policed, so we asked them for some information.

The agency have advised that they are quite active in the enforcement of the regulation – since the beginning of the year they have carried out 66 investigations and issued a number of warnings about DIY systems.

They have also issued information and enforcement notices – the numbers aren’t that great but it does show that something is happening.

They have said that they have ensured that a number of companies have been brought into compliance by becoming certificates, and they have encouraged technicians to attend training courses.

So they are being active, if they haven’t gone down the route of taking people to court.

The other point to note is that the agency has taken on a third member of the team full-time, but that this isn’t the extent of their involvement; they are working with a number of other organisations to implement the Regulation.  

Mark Hughes

I will start with a bit of explanation about the company. I am speaking on behalf of DuPont as a refrigerant manufacturer.

The part of the company for which I work, involved with manufacture of fluorochemicals and other chemicals, is being spun off as a separate company from the first of July.

Quite an exciting time for the company, so you will be hearing more of the name Chemours, but you will be hearing a lot more about the name Opteon XP40.

From a producer’s point of view we see three main pillars around F-Gas, namely the new equipment bans, the service ban and the phase down.

The latter affects us as producers most greatly as it affects what we can put on the market.

I want to re-emphasise the impact of the pre-charge controls on the phasedown quota in 2018.

People may not realise that we can actually authorise that quota now, effectively allowing quota holders to bank enough to enable those importers to bring their equipment in. we are already talking to manufacturers about 2018.

What does that drive? The EU has clearly put the cap and the bans in place to attack the use of the high-GWP refrigerants like R404A and R507, so it will put pressure on the cost of that refrigerant and, we hope, drive people towards lower-GWP options.

As a refrigerant developer, we need to look at this highly technical tool, the Crystal Ball. The balloon graph shows the volume in GWP terms – this is the balloon the EU wants to pop. [See top graph]

If you look at the 2030 graph, you can see that R404A, R507 and R410A are gone, replaced by some new products, like R32, low-GWP blends and the very low gases like CO2 ammonia and pure HFO. Reclaimed gases will also be part of that mix.

In commercial refrigeration, we see don’t see large volume reductions, as things like charge size and leak reduction will be offset with things like the growth in heat pumps – no more than half a per cent a year.

But what will have to reduce greatly is the CO2 equivalent of the gas that goes in those systems – and that is the major challenge.

We are not pulling any punches here – there are large banks of R404A out there and it remains very popular particularly with commercial refrigeration. Whether we like it or not, systems are still being installed today with R404A – it is still the cheap option. The cost is starting to increase as the quota comes in, but it is still very widely used.

It is a good opportunity for us to get the message out there.

Some people are very knowledgeable, but the majority have not put strategies in place.

It is probably the shortest period of time that we have ever had for regulation change – we have two or three years and it will have a massive effect. We have got to try and help people to solve the problem.

So what are the potential solutions?

First, naturals: there are a lot of programmes out there for installs with natural refrigerants but the rate of replacement will not be fast enough to meet the challenge that is coming up.

There is a lot of noise in the market about the naturals – to hear some of the people at the Atmosphere Conference you would think it is already a done deal.

But naturals all have their problems – some of the transcritical systems in Spain are struggling to work in hot temperatures; hydrocarbons have their issues with charge sizes, while ammonia requires a strict safety regime. So low-GWP HFO blends need to be part of the answer.

But energy efficiency is another element we should emphasise – the gas that might leak out only forms a part of the total CO2e impact from a refrigeration system.

If we choose the wrong solution and increase the amount of energy use by just 10 per cent, then we wipe out the benefit from lowering the GWP.

Next there are the low-GWP HFC blends, R407A and R407F, which have been successfully used for some time both as retrofit and new equipment.

But their GWP makes them only a transitional solution in our view.

They will continue to capture part of the market, but we have got new things coming through, which we believe will provide a long-term solution.

The low-GWP HFO blends that we are talking about today offer a GWP that will keep them under the cap in the long-term and they have been formulated to offer that good energy efficiency we talked about, together with an ease of handling that you won’t find with the natural refrigerants.

They do tick a lot of the boxes that Ray talked about, and the key thing about the first lot I will mention is that they have no flammability to worry about.

At the previous F-Gas Question Time there were concerns about availability, but I can say that these Opteon blends I am going to talk about are commercially available to customers today.

I want to talk about the three HFO blends:

XP10 (R513A) is an R134a replacement that I will mention briefly because this one is going to come into its own in the future.

It is an R1234yf and HFC blend and has a GWP of 631, one of the lowest you can get without flammability.

It is an azeotrope, so there are no problems with glide, so is very easy to use. It also has compressor approval, which is also important.

We don’t see the pressure on R134a coming for some time, but we have seen OEMs specifying it, as it is futureproofing their systems.

Trane has introduced it into their EcoWise chillers.

XP10 has been used successfully in hybrid systems with CO2 as a replacement for R134a, or R404A using the CO2 subcritically. It has provided good energy efficiency, too.

XP44 (R452A) is our product for transport refrigeration. It has quite a high GWP of 2000 so will be quite a niche product, but it has been developed to match the discharge temperature of R404A for transport applications.

Thermo-King, for instance, is turning its full production over to XP44. Although there is no ban for R404A in transport, the company has decided that their customers will begin to struggle for R404A – both availability and the cost - as the phasedown kicks in elsewhere in the market.

And now their competition Carrier Transicold has announced it is going to start installing XP44.

So we come to XP40 or R449A. We have proved we can use it to replace R404A in high ambients in Italy and Spain in cascade with CO2. In the Italian example, we achieved an energy improvement of 9 per cent over R404A in the MT.

We also installed XP40 in a Belgian supermarket with thermostatic expansion valves, where an energy reduction of 8 per cent was achieved on the MT system. There were no major adjustments required, but it is important to say we don’t regard the new blends as ‘drop-ins’ as there will always be some minor adjustments because of things like mass flow differences.

We always recommend that contractors refer to our installation guidelines.

Our biggest commercial success to date has been with Dutch supermarket group Ahold, which has retrofitted 200 stores from R407F to XP40. We saw improvements in power consumption over both the original R507 and R407F.

A particular advantage is the lower discharge temperature on LT systems, not requiring additional cooling on the compressors.

The retailer says it is retrofitting with R449A for a range of reasons ranging from the lower GWP to the lower discharge temperature to the fact that it is commercially available, and that it offers 8 per cent lower energy averaged across MT and LT. It gives them security – although we talk about a phasedown of HFCs, for R404A and R507, make no mistakethis legislation is a phase-out.

We now have significant compressor approvals from the major manufacturers and are now undergoing the process with makers of smaller compressors and heat exchangers.

I wanted to end with our mildly flammable XL range – these are lower in GWP and they have to be part of the portfolio to get us down to the 80 per cent phasedown targets.

They are undergoing testing with component suppliers and customers now as these are for the new equipment market and we hope to have them commercially available as soon as next year.

There will be a 150 GWP ban on hermetic systems in 2022 and so I wanted to highlight that there is a product on test XL20, which will be under that.

But we won’t commercialise any of these products until EN378 is in place to cover design and handling.

Question – We have heard that 11 per cent of the HFC consumption was taken out of the quota pot of those incumbents suppliers who submitted their records to the Commission.

So does that mean that we are actually starting with less than 100 per cent on the phasedown?

RG No, the 89 per cent was allocated for the incumbents, those who reported consumption in the EU in the baseline period. Their quota was based on the proportion of their contribution. While there were 79 incumbents from manufacturers to packers, five manufacturers contributed the lion’s share: DuPont, Honeywell, Mexichem, Solvay (now Daikin) and Arkema. The quota covers a three-year period.

Anybody could then apply for a new entrant share of the remaining 11 per cent – there were 334 of them, so they all have an equal share of really, not a lot. They each have a quota of 64,500 t CO2e, which is equivalent to 15 tonnes of R404A or just half an ISO container.

PAM Can I add that the term is ‘placing on the market’ rather than consumption? The reason I say this is there was imported refrigerant which was not reported to the EC, so the actual volume of consumption will be higher than what is reflected in the quota.

RG That is a good point – the baseline is only what was legally reported. If there was a lot of unreported HFC, that will affect the supply and demand.

Q This all sounds like a confusing and perhaps concerning picture. Is the overriding theme to make plans as soon as possible, not wait and see what happens?

MH Yes, and can I add to that? We have been talking to people who are using R134a currently.

Now that has a GWP which shouldn’t really be a concern until further into the phasedown.

But if the R404A issue is not handled correctly, and people try and hang on to it, whatever the price, then that will suck up the quota, and put more pressure on the other gases.

It is such a dynamic situation that we will have to see how the market develops – but it will happen quickly, which is why we are encouraging people to take action sooner rather than later.

The sooner people convert to lower-GWP the better – put the strategy in place, even if you don’t make a massive move today.

Q Do you think it is practically feasible that the industry could finance its own national F-Gas database?

MN I think we have to wait to see what the Commission decides on databases – the hope is that the Commission might provide the funding, as generally speaking there is some money available to assist in setting up new legislation.

RG I think it is without doubt that our government won’t have the money to do this, and probably the EC too – so it is likely to be down to industry. The good news is that it won’t cost a lot of money to have an overarching database, possibly run by ACRIB.

It would mean adding a few pounds onto each registration. But the government won’t be minded to force it, as the legislation doesn’t make it mandatory.

AG Surely it needs to be driven, like other such schemes, by the end-user preventing people coming onto site without a card?

MN Some do, and it would be great if the end-users publicised the fact that you need to be suitably qualified and certified to do the work on their sites.

RG You might be best to try lobbying Defra for something like that; on the basis the cost of doing it is small. But let’s remember that the majority of individual F-Gas qualified people do not come from the big contractors who work with supermarkets but from the many smaller companies who don’t.

Q But if the F-Gas regulation already dictates what refrigerants we have to use, surely creating a mandatory system would be additional work and cost?

RG It is really the checking that we are trying to make simpler – supermarkets may find it easier to check records than say a pub that is having its refrigeration fixed.

Q But should the burden of enforcing the regulations actually sit with the supplier of refrigerant not the customer? We have enough paperwork as customers!

Graham Wright  I work for a company that deals with a lot of AC installs on construction sites. How many of those installers do you think get their certificates checked? Not many.

We as suppliers often have systems in place, but we need to start insisting that those paying for the work are asking for certification.

MN I think the other thing to mention is that of the three registration schemes, only Refcom has a public database, yet some 1,200 companies have opted not to publish their details, citing data protection concerns.

I have had experience on a number of occasions of having to call Refcom to get them to confirm details of an installer. We just think it would be a positive step to have a database that we could all look at.

RG I think the change in rules to cover those purchasing gas has helped the process. I suspect the leap in registrations has been prompted by suppliers cracking down on who they supply to.

Q Will current leak detection systems work with the HFO blends?

MH There is no specific issue – for the simpler detectors, which work on fluorine, it will be the same, since HFCs are still in there. For the high-end systems it will just be a question of contacting your supplier to ensure the new gases are programmed in.

Q I liked the list of core actions that Ray gave us earlier. But I think the one thing that you missed out is the contribution of technology. As a heat exchange supplier we have developed equipment that will save 75 per cent of refrigerant, so I would advocate that people look at a combination of new technology as well as new refrigerant.

Patrick Amrhein

I wanted to begin by mentioning again the upcoming bans, particularly noting the GWP levels applying of 2500 in 2020 and 150 in 2022. But bans are only one of the instruments being used, alongside the phasedown.

We should mention again that the additional demand for pre-charged equipment will create another chunk of demand from 2018 as you can see from our own slide [see table above].

This, together with the difference in demand from unreported refrigerant imports, will create a gap between quota and the actual demand. If you add in the additional stocking, the gap will not apply this year, but from next year, this suggests a shortfall.

The real challenge here is to get the industry to change because of the phasedown.

I want to look at a lesson from history. In the 1980s the main Mobile AC was CFC12, but then the Montreal Protocol sought a ban, and a new refrigerant was developed R134a.

At the beginning, the price of CFC12 was low, but as the phaseout of the refrigerant accelerated, all of a sudden prices started to increase.

It kept rising until it reached a point where CFC12 was too expensive to justify and that was the point where the car manufacturers switched to R134a.

Many will know there is already a transparent system in place for trading carbon in the EU [the Carbon Equivalents Trading Scheme] where the price is based on the carbon emissions.

So my question is: what price is our carbon quota? Will we see people buying and selling the HFC quota, in a similar emissions trading system? Nobody seems to have taken any action on this so far.

What options does Honeywell have for low-GWP?

We have identified three HFO molecules as viable alternatives: 1234yf, ze and zzd.

The yf we see already established in automotive applications as an R134a replacement; ze is finding application in chillers and heat pumps; and zzd is for low pressure centrifugal chillers, already adopted by Trane, for example.

What is clear is that any HFO refrigerant blend that is developed in future will contain one of those molecules.

Another element to emphasise is that if the blend is going to be non-flammable it will be limited to around 400 GWP – any lower will be likely to be mildly flammable. Therefore it is essential that we increase people’s knowledge of working with the A2L mildly flammable category.

We believe the greatest impact on the commercial refrigeration industry will be achieved by retrofitting the high-GWP installations with these low-GWP alternatives, and by installing them in new equipment.

They can provide energy savings and payback times of under two years, while being very engineer-friendly. And the fact that they can be used until 2030 makes them a long-term option.

Then moving further forward we have ultra-low GWP options with GWP under 150.

For chillers and MT refrigeration we have Solstice N13 (R450A) which has a GWP of just less than 600.

This is the non-flammable option, or we have the A2L option of R1234ze, which has a GWP below 1.

For low and medium temperature we have Performax LT (R407F) which has proved popular for retrofit and the new Solstice N40 (R448A) which has a GWP of 1387.

As a development product, we have HDR110, which has a GWP under 150.

For stationary AC, to replace R410A, we have the mildly flammable Solstice L41 (R447A), which has a GWP under 600.

Graham Wright

In my nearly 30-year career, I have seen the move from R22 to 407 to 410 to R32 and it is clear that the goalposts in Europe are going to keep moving.

What always surprises me though is why the industry always waits to the last minute to do anything about it.

As a representative of the manufacturers let me say, if we all wait to the deadline, we are going to be in trouble.

From where I am looking I can easily see the price of R410A going up to ten maybe twenty times what it is now.

I am not trying to scaremonger – it stands to reason that the quicker people move to lower-GWP gases, the less it will cost them.

Andrew kindly mentioned my connection with R32.

I like to think that I am in the vanguard on this refrigerant as my company Daikin has been using R32 quite extensively.

I believe it is the way forward for air conditioning equipment and it could be the way forward for other products, but the reality is, it is one of a suite of refrigerants that we are going to need to use to meet the terms of the phasedown.

Paul Alway From an end-user perspective there is an element of the unknown but I think that there is enough information out there right now to make a decision on what to do.

Looking at my estate, I have 61 per cent R407A, 10 per cent left that is R404A, 25 per cent CO2, so from my point of view I haven’t had trouble putting a strategy together.

The immediate risk is I have to get R404A out of my integral mobile estate and from cascades.

I have a bit of time for getting out of R407A.

In the next two months I will trial XP40 to CO2 and XP10 to CO2 and will have trialled all the different integrals on them.

Then I will do the same with the N range. And then I will watch them for a year, to see what seals go and what happens, then I will know what to use going forward.

If I was in the position of still having 60 per cent R404A, I would be putting R407A or R407F in across much of the estate, because it buys some breathing space.

Those of my colleagues in rival retailers who say the refrigerant suppliers aren’t knocking on their door – I am sorry I don’t believe that, and I have challenged them at a BRA meeting – the information is out there.

We know what is going to happen to prices, we just don’t know what the final number is.

As regards new equipment, I think everyone knows what they have to do. I am pleased to say that today I have received a picture of our first transcritical M&S pack being lifted onto the roof – after two and a half years of telling you I am going to do it.

We know what we have to do. I think we just have to get on and do it.

I have offered many times to share our learnings on R407A with anyone who wants to know, but no one has taken me up on it, so I can only assume they everyone is happy with what they are going to do.

Q  Surely the cost forecasts alone should drive people to change sooner rather than later?

GW I think that this should spell the end of refrigerant as a commodity – we need to look at it as resource to be looked after, because it is going to be costly.

MH We get some criticism that the HFO replacements are more expensive than the gases they are replacing, well that is true, but I think all I can do is point to the embedded carbon price that is in that product.

The reclaim market will become very significant – and it all comes down to the fact that refrigerant now has a value. For the same reason, it will no longer be cheaper to let something leak than to fix it.

Q Will there be charge limits on A2Ls in the same way as there are for hydrocarbons?

GW Although the revision of EN 378 is still being discussed I think we can assume that there will be charge limits. Will they be restrictive? Let’s wait and see how it comes out.

One thing that is clear is that in the UK at the moment, if I want to use an A2L I have to treat it as A2, and that gives me a charge limit of about 12 kilos. That also means we have to do training courses accordingly so that the engineers can deal with it as an A2. We need that revised EN378 out as quickly as we can, so we can deal properly with these as A2Ls.

RG We should say that we can still work with these refrigerants under current codes – 12 kg is a lot bigger than for hydrocarbons.

GW It is not an issue for small splits, but the more complex systems will benefit from that change in regulation.

MH The A2L refrigerants could be required in anything from a beer cooler up to a supermarket system, which is why as a supplier we won’t do anything with until the new E378 comes out.

Q When we met last year, Paul you said you would investigate whether you could meet the automatic leak detection requirements of the legislation by using your existing refrigeration management software. Did you manage to?

PA Unfortunately not. Although our system can tell when the furthest case is low on gas, after digging in to the legislation we realised we needed to install separate leak detection.

Where I did get caught out was in calculating the thresholds on the existing GWP levels at the time, which were then updated by the Commission, which brought more systems into scope than we estimated.

I must admit it is frustrating – how a gas can be judged one day to cause this much global warming, and the next day something different, even though it has got the same stuff in it.

Q How can refrigerant manufacturers justify selling the quota authorisations to equipment importers when they paid nothing to get the quota? It sounds like windfall profits for the refrigerant manufacturers.

MH I don’t think we would agree with the term ‘windfall’, but there is a review of the regulations set for 2017 specifically to see whether the market is being distorted.

Q What is your one-sentence message to the market?

MH There is life after R404A, but we have to get on with getting rid of it, as we haven’t got much time.

PA To the manufacturers, keep doing what you are doing, keep knocking on the door, because we know that with legislation, things are always changing.

MN It was a good point well-made about including technology in the actions to take.

We have to consider product energy-efficiency particularly because it plays a bigger role than leakage in reducing emissions and I think it is a great opportunity to develop products that are more energy-efficient and use less refrigerant.

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