Companies in the European chemical industry allege that proposals to ban certain refrigerants as PFAS substances under the European REACH regulations could compromise EU Green Deal and REPowerEU goals.
“The European REACH restriction proposal, which is expected to be published this month, could see bans being suggested for a number of widely used refrigerants including the low GWP HFOs R1234yf – which is now the standard refrigerant for car air conditioning systems – and R1234ze. Both are widely used as components in a number of lower GWP blends, as well as being solus gases in a number of applications, including some of the latest chillers”.
Five EU member states, Germany, the Netherlands, Norway, Sweden and Denmark have been promoting the ban as PFAS substances are known to be persistent in the environment, contaminating groundwater, surface water and soil, and causing serious health effects. Exactly which refrigerants might be included is still unknown. The EFCTC (European Fluoro Carbons Technical Committee) says it expects the new proposal is likely to include most F-gases.
In a socio-economic analysis report compiled on behalf of the EFCTC, the engineering and environmental consultancy Ricardo plc has looked at 10 F-gases that are expected to be covered by the PFAS definition. These are: HFC125, HFC134a, HFC143a, HFC227ea, HFC-245fa, HFC-365mzz, HFO-1234yf, HFO-1234ze, HFO-1336mzz, and HCFO-1233zd.
A number of these gases are low-GWP refrigerant alternatives to other substances that are being phased down under the F-gas regulations. The EFCTC claims that their inclusion could cause unavailability of refrigerants, thus potentially compromising the EU Green Deal and REPowerEU decarbonisation goals.
The Ricardo study found that “the proposed restriction would generate increased costs and reduced efficiency, both in the performance of the product applications and in their energy consumption, leading to an increased burden on consumers, possibly limiting their choices and reducing incentives of technological change from the current equipment containing F-gases. In turn, this could also increase the illicit trade in non-compliant products”, it argues.
In arguments over which refrigerants can be considered PFAS products, it is accepted that some HFCs and H(C)FOs can degrade into trifluoroacetic acid (TFA), which can persist in the environment and has the potential to harm the environment, marine life and humans. Arguments persist as to the extent of any effect that these refrigerants in the environment might have.
The Ricardo study maintains that the F-gases in scope have very low toxicity to both terrestrial plants and aquatic organisms such as algae, invertebrates, and fish, as well as to humans, and display no observable evidence to suggest genetic, reproductive, developmental, or carcinogenic toxicity in humans. Environmental groups disagree.
