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EU Policies: MAC Directive & F-Gas Regulation<br />

Mobile Air Conditioning (MAC) Directive<br />

Adopted in 2006, the MAC Directive (Directive 2006/40/<br />

EC relating to emissions from air-conditioning systems in<br />

motor vehicles) bans MAC systems working with fluorinated<br />

GHGs with a Global Warming Potential (GWP)<br />

higher than 150 from 2011 for new types of vehicles, and<br />

for all new vehicles as of 2017. The ban therefore covers<br />

the most commonly used refrigerant, HFC134a (GWP =<br />

1,430).<br />

The mechanism to implement the Directive is the type<br />

approval procedure at national level, by which car manufacturers<br />

need to homologate their vehicles before they<br />

can be put on the market. With the automotive sector<br />

seeking a global solution for their MACs, EU manufacturers<br />

have announced that they will be using a next generation<br />

chemical refrigerant with low-GWP to meet the<br />

requirements of the Directive. These included German<br />

carmakers, which had initially committed to using natural<br />

refrigerant CO 2<br />

.<br />

Nonetheless, new MACs with low-GWP refrigerant are<br />

still to make their debut on the EU market due to lack<br />

of availability of the new chemical substance, with one<br />

carmaker already reported to have acquired compliance<br />

exemption by a national type approval authority – a development<br />

that might contaminate overall effectiveness<br />

of the Directive.<br />

Looking at the future, with the ban in place, and flammability<br />

as a property of refrigerants gaining increasing<br />

acceptance, hydrocarbon natural refrigerant which<br />

are widely used worldwide in the MAC servicing sector,<br />

could also be one of the future solutions selected for new<br />

MACs by carmakers. Natural refrigerant CO 2<br />

is also seen<br />

as a good candidate to cover both heating and cooling<br />

needs for electric vehicles, which are to gain market<br />

share in the EU and worldwide.<br />

Overall, the Directive has had a positive impact on natural<br />

refrigerants, by enabling development of CO 2<br />

technology<br />

and components not only for passenger vehicles<br />

but also for other applications currently not in the scope<br />

of the Directive, including buses and trains. It has also<br />

benefited the know-how in natural refrigerant CO 2<br />

for<br />

stationary applications.<br />

The MAC Directive has set a precedent in restricting the<br />

GWP allowable for refrigerants in a specific application.<br />

The impact of the Directive spans wider than the EU,<br />

with US authorities also considering a ban on the use<br />

of high GWP HFC134a in motor vehicle air conditioning<br />

systems. California is also proposing to incentivise the<br />

use of low-GWP refrigerants in Mobile Air Conditioning<br />

(MAC) systems of new vehicles.<br />

F-Gas Regulation<br />

To address the issue of emissions related to the use of<br />

HFCs, the European Union has adopted the F-Gas Regulation<br />

(Regulation No 842/2006 on certain fluorinated<br />

greenhouse gases). In place since June 2006 in the EU,<br />

the overall objective of the F-Gas Regulation is to prevent<br />

and thereby reduce leakages of high-global warming<br />

f-gases such as hydrofluorocarbons (HFCs). The regulation’s<br />

main impact is on systems containing 3 kg or more<br />

refrigerant, to which regular leakage checks and record<br />

keeping apply, in addition to end-of-life and repair requirements.<br />

Owners and operators of such systems bear<br />

additional costs to meet the various requirements, while<br />

on the other hand natural refrigerant equipment is out<br />

of the scope of the Regulation and its requirements.<br />

“The application and enforcement of this Regulation<br />

should spur technological innovation by encouraging<br />

continued development of alternative technologies and<br />

transition to already existing technologies that are more<br />

environmentally friendly”, reads the text of the Regulation.<br />

Although not placing any use bans on the HVAC&R<br />

sector, the Regulation is seen as an indication of stricter<br />

requirements in the future, with several manufacturers<br />

of stationary equipment carrying out R&D and investing<br />

in natural refrigerants to insure against future strengthening<br />

of the Regulation and potential use and marketing<br />

restrictions. The Regulation has also inspired natural<br />

refrigerant training initiatives that are being developed<br />

in parallel to f-gas training courses, together with private<br />

initiatives to phase out high GWP gases by supermarket<br />

chains (see UK and Switzerland) and global consumer<br />

goods end users (CGF 1 , Refrigerants Naturally!).<br />

Future developments with this Regulation is crucial for<br />

the natural refrigerant industry, with the EU executive<br />

body, the European Commission, currently considering<br />

a revision that is likely to result in strengthened requirements.<br />

A first report assessing the effectiveness of<br />

the Regulation suggests that more action is required in<br />

addressing HFC emissions, if the EU is to meet its longterm<br />

emissions reduction targets (European Commission,<br />

2011). The same report considers different options<br />

for achieving additional reductions of f-gas emissions<br />

in the EU, including use and marketing prohibitions for<br />

new equipment and products, voluntary environmental<br />

agreements at Community level, a tax on sales of HFCs<br />

and pre-charged equipment, stricter containment and<br />

recovery measures etc. Although currently too early to<br />

assess what could be the preferred approach for achieving<br />

additional HFC emissions reductions in Europe, it<br />

may be expected that requirements be tightened, further<br />

bridging the capital cost gap between traditional<br />

and natural refrigerant technologies.<br />

1 Consumer Goods Forum<br />

47

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