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There are imminent changes to the Refrigerant F-Gas regulations from the 1st Jan 2015 and we have detailed below what that could mean to you.

The biggest change applies to leak checking and the requirement for refrigerant leak detection, which was based on the kgsof refrigerant in the systems, to now be a measure of the carbon dioxide equivalent (CO2e) of the entrained charge of HFC.  Basically it’s going to mean that the majority of refrigeration systems with HFC refrigerants, especially the high Global Warming Potential (GWP) ones like R404A, are going to need more leak checks and potentially require fixed refrigerant leak detection equipment where it wasn’t required under the outgoing regulation.

If you think of all the (HFC) refrigerants in your estate in (R134A, R404A, R410A, R407, etc):

Chillers, AC system / Fan Coil Units, Restaurants and food courts. As well as:

  1. stationary refrigeration equipment; 
  2. stationary air-conditioning equipment; 
  3. stationary heat pumps; 
  4. stationary fire protection equipment; 
  5. electrical switchgear; applicable from 1 January 2017 
  6. organic Rankine cycles ; applicable from 1 January 2017 

There is a substantial quantity of equipment to be evaluated in order to ensure compliance.

We would be happy to provide some guidance or alternatively you can add up your entrained charge in each refrigerant system (in kgs) and multiple by the GWP figure (see attached ACRIB sheet) and then divide by 1000 you will get tonnes ofCO2e.  If that number is equal or greater than 500 then you will need fixed leak detection and more leak checking.  Remember this is per system and not the total of all the refrigerant on site. 

Finally, some notes below extracted from the attached proposed FGas changes FYI:

1. Leak Checking

Previously the number of leak checks required each year was determined by the refrigerant system charge (in kgs) of the HFC refrigerant. This will change and the frequency of leak checks will be determined by the carbon equivalent (CO2e) of the entrained charge of refrigerant. The tables below compare the current and new categorisation. 

a. Current leak checking requirements, based on kg charge 

Applications with greater than 3kg but less than 30kg

Shall be checked for leakage at least once every 12 months

Applications with greater than 30kg but less than 300kgs

Shall be checked for leakage at least once every six months

Applications with greater than 300kgs

Shall be checked for leakage every three months


 b. Proposed leak checking requirements from 1st January 2015, based on CO2e 

Applications with greater than 5 tonnes of CO2e but less than 50 tonnes CO2e

Shall be checked for leakage at least once every 12 months

Applications with greater than 50 tonnes of CO2e but less than 500 tonnes CO2e

Shall be checked for leakage at least once every six months

Applications with greater than 500 tonnes of CO2e

Shall be checked for leakage every three months


The CO2e conversion factor for R404A is 3,920 (this is the global warming potential as listed in the Kyoto Protocol, based on a 100yr life. We refer to it as GWP). This means 1kg of R404A = 3,920kg CO2e.

The new method will effectively half the limits of the categories for R404A, which means you could potentially be doubling the number of leak checks required. This will be different for other HFC’s.

E.g: An application with 128kgs of R404A would previously require a leakage check every six months, it will now require checking every 3 months as it has over 500 tonnes of CO2e. 

2. Leak Detection

The same benefits still apply for those who fit a leakage detection system. The use of this type of system will half the number of yearly leak checks required, and in the smallest category (5 to 50 tonnes CO2e), the leak checking will extend to every 24 months. 

Previously, any operator of a system with greater than 300kgs of HFC were required to implement a refrigerant leak detection system. With the change to categorisation by CO2e, the legislation states that any application with greater than 500 tonnes of CO2e shall have refrigerant leak detection installed.

This means that the previous maximum charge before leak detection was required on a R404A has been more than halved from 300kgs to 127kgs. This change will come into force from 1st January 2015.

3. Control of Use

Looking to the future, the use of F-gases with a global warming potential (GWP) of greater than 2500 (R404A is 3920), to service or maintain an application with a charge greater than 40 tonnes of CO2e (12.3kgs R404A), shall be prohibited from 1st January 2020. 

There is an exclusion that allows recycled or reclaimed gas to be used until 2030, but the supply volume and price may be volatile dependent upon demand.