EU F-gas Regulation (EU)517/2014 and proposed Road Map for Turkey

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1 EU F-gas Regulation (EU)517/2014 and proposed Road Map for Turkey Janusz Kozakiewicz TECHNICAL ASSISTANCE FOR INCREASED CAPACITY FOR Policy Makers Workshop, Ankara, 30th November 2017

2 Introductory remarks (1) Kyoto basket of greenhouse gases F-gas GWP100 (4 th IPCC AR) CO 2 1 CH 4 25 N 2 O 298 HFCs PFCs SF } F-gases Some other fluorinated substances, e.g. HFOs not listed under Kyoto Protocol, but reporting obligations in EU F-gas legislation

3 Introductory remarks (2) F-gases Main areas of application RAC&HP Foams Fire protection Electrical switchgear Solvents Aerosols

4 Introductory remarks (3) HFCs and HCFCs global consumption trends, tonnes HCFC HCFC HFC HFC Developed countries, including EU Developing countries, including Turkey Immediate action needed EU revised F-gas Regulation (2014) Kigali Amendment (2016)

5 Introductory remarks (4) EU revised F-gas Regulation (EU)517/2014 was applied from 1 January 2015 and is mandatory for all legal entities and natural persons in the EU replaced Regulation (EC)842/2006 on which the Turkish draft F-gas Regulation was based may be revised based on the report by the Commission on the availability of alternative technologies due by 1 January 2020 has been supplemented so far with 12 Commission Implementing Regulations, 5 of which remained the same as issued for the purpose of implementing the previous Regulation (EC)842/2006

6 Introductory remarks (5) TECHNICAL ASSISTANCE FOR INCREASED CAPACITY FOR Measure Production controls Import/export controls Placing on the market /use controls Kigali Amendm ent Regulation 842/2006 Regulation 517/2014 Turkish draft F- gas Regulation V - V - V - V - - V V V Labeling - V V V Emission controls (V) V V V Registration and records keeping - V V V Reporting V V V V Training and certification - V V V

7 Introductory remarks (6) Regulation (EU)517/2014 Why is it effective? HFC phase-down Record keeping and reporting Placing on the market and use controls Avoiding F-gas emissions

8 Important provisions in 517/2014 HFC phase-down (1) HFC phase-down

9 Important provisions in 517/2014 HFC phase-down (2) HFC phase down schedule (much stricter than Kigali Amendment) quantities allowed to be placed on the EU market each year are expressed in tonnes of CO 2 equivalents (CO 2 eq) calculated by multiplying metric tonnes by GWP of the substance or mixture E.g. 1 tonne of HFC-134a (GWP = 1430) = 1430 tonnes CO 2 eq

10 Comparison of HFC phase down schedules % %

11 Important provisions in 517/2014 HFC phase-down (3) Quota allocation system HFC quotas (calculated in tonnes of CO 2 eq) are allocated each year to old HFC producers and importers in the EU (called incumbents ) and only 11% is left for new importers (called new entrants ) HFC quantities imported in pre-charged RAC&HP equipment and in pre-blended polyols are also within quota (pre-blended polyols containing HFCs are treated as mixtures containing HFCs) If <100 tonnes CO 2 eq of HFCs placed on the market in a given year no quotas are required Transfer of quotas is possible between importers Authorization of quotas is needed if 100 tonnes of CO 2 eq or more of HFCs are imported in pre-charged RAC&HP equipment

12 Important provisions in 517/2014 HFC phase-down (4) Quota authorization system HFC quota holders may authorize importers of RAC&HP equipment pre-charged with HFCs to use their quota for equipment imports and equipment importers are obliged to present before customs clearance the Declaration of Conformity Declaration of Conformity statement signed by equipment manufacturer or importer that HFCs contained in equipment have been placed on the EU market before or are subject to quota authorization

13 Important provisions in 517/2014 POM and use controls (1) Placing on the market and use controls

14 Important provisions in 517/2014 POM and use controls (2) Placing on the market (POM) bans inter alia cover : RAC&HP equipment containing or relying on high GWP F-gases Foams and technical aerosols containing high GWP F-gases General exemption Military equipment Possible exemption on request of the Member State if it is demonstrated that: - no technically or economically feasible alternatives exist or - the alternative cannot be used for technical or safety reason or - the use of alternative would entail disproportionate cost

15 Important provisions in 517/2014 POM and use controls (3) Placing on the market ban : Non-refillable containers for F-gases banned from 4 July 2007

16 Important provisions in 517/2014 POM and use controls (4) Placing on the market ban : Domestic refrigerators and freezers That contain HFCs with GWP of 150 or more banned from 1 Jan 2015

17 Important provisions in 517/2014 POM and use controls (5) Placing on the market ban : Refrigerators and freezers for commercial use (hermetically sealed equipment) That contain HFCs with GWP of 2500 or more banned from 1 Jan 2020 That contain HFCs with GWP of 150 or more banned from 1 Jan 2022

18 Important provisions in 517/2014 POM and use controls (6) Placing on the market ban : Stationary refrigeration equipment That contains or whose functioning relies upon HFCs with GWP of 2500 or more banned from 1 Jan 2020 Except for equipment intended for application designed to cool products to temperatures below 50 C

19 Important provisions in 517/ POM and use controls (7) Placing on the market ban : Multipack centralised refrigeration systems for commercial use with a rated capacity of 40 kw or more That contain or whose functioning relies upon F-gases with GWP of 150 or more banned from 1 Jan 2022 Except in the primary refrigerant circuit of cascade systems where F- gases with GWP of less than 1500 may be used Exemption based on ecodesign advantage over equivalent equipment is possible if F-gas is not HFC

20 Important provisions in 517/2014 POM and use controls (8) Placing on the market ban : Single split air-conditioning systems containing <3 kg of F-gas That contain or their functioning relies upon, F-gases with GWP of 750 or more banned from 1 Jan 2025

21 Important provisions in 517/2014 POM and use controls (9) Placing on the market ban : Movable room air-conditioning equipment (hermetically sealed equipment which is movable between rooms by the end user) That contain HFCs with GWP of 150 or more banned from 1 Jan 2020

22 Important provisions in 517/2014 POM and use controls (10) Placing on the market ban : Foams That contain HFCs with GWP of 150 or more except when required to meet national safety standards Extruded polystyrene (XPS) banned from 1 Jan 2022 Other foams banned from 1 Jan 2023

23 Important provisions in 517/2014 POM and use controls (11) Placing on the market ban : One component foams (OCF) That contain F-gases with GWP of 150 or more except when required to meet national safety standards banned from 4 July 2008

24 Important provisions in 517/2014 POM and use controls (12) Placing on the market ban : Technical aerosols That contain HFCs with GWP of 150 or more except when required to meet national safety standards or when used for medical applications banned from 1 Jan 2018

25 Important provisions in 517/2014 POM and use controls (13) F-gas use ban maintenance or servicing of refrigeration equipment (40 t CO 2 eq or more) containing virgin F-gases with GWP of 2500 or more starting from 1 Jan 2020 or or military equipment or equipment designed to cool products below -50 o C exempted reclaimed or recycled F-gases allowed till 1 January 2030 with certain restrictions on recycled gases

26 Important provisions in 517/2014 POM and use controls (14) Labeling requirements (example)

27 Imporant provisions in 517/2014 POM and use controls (15) Placing on the market and use controls how to implement such measures in Turkey? Which bans to implement and what the starting dates could be? How to set up labeling requirements? - Consultations with the relevant industry sectors are needed - Project Activity 4 may help in that respect

28 Important provisions in 517/2014 Avoiding F-gas emissions (1) Avoiding F-gas emissions

29 Important provisions in 517/2014 Avoiding F-gas emissions (2) F-gas emission controls how to stop emissions? Leakage checking of equipment Certified service technicians and service companies Recovery/recycling/reclamation/destruction obligations Other special measures

30 Important provisions in 517/2014 Avoiding F-gas emissions (3) Leakage checking obligations Operators of stationary RAC&HP and fire protection systems, refrigeration equipment on trucks and trailers, electrical switchgear equipment and organic Rankine cycles containing 5 tonnes of CO 2 eq of F-gases or more obliged to ensure that: Equipment is checked for leakage periodically using prescribed procedures Leakage is repaired ASAP Effectiveness of repair is checked within 1 month Special exemptions apply for hermetically sealed RAC&HP equipment and switchgear equipment

31 Important provisions in 517/2014 Avoiding F-gas emissions (4) Leakage checking obligations Operators of stationary RAC&HP, fire protection systems, electrical switchgear and organic Rankine cycles containing 500 tonnes of CO 2 eq of F-gases or more obliged to ensure that: Leakage detection systems that alert equipment operator on any F-gas leakage are installed and checked periodically

32 Important provisions in 517/2014 Avoiding F-gas emissions (5) Leakage checking obligations how to implement them in Turkey? Starting with pilot leakage checking scheme in a selected region (Activity 5 of the Project) Monitoring leakage checks through mandatory equipment logbooks contained in an electronic database (Activity 8 of the Project)

33 Important provisions in 517/2014 Avoiding F-gas emissions (6) Certification (natural persons and in specified situations also companies) Stationary RAC&HP equipment + refrigerated trucks and trailers Stationary fire protection equipment Electrical switchgear equipment (except for leakage checking) F-gas solvent-based equipment (F-gas recovery only) Attestation (natural persons only) - F-gas recovery only - Concerns MAC (covered by Directive 2006/40)

34 Important provisions in 517/2014 Avoiding F-gas emissions (7) Personal certificates Examination must be passed Training is not compulsory Company certificates Procedures must be implemented Certified persons must be employed Training attestations Training must be completed

35 Important provisions in 517/2014 Avoiding F-gas emissions (8) Certification/attestation requirements how to implement them in Turkey? One certification body (RAC&HP, fire protection, electrical switchgear, F- gas solvents) or several certification bodies? One evaluation body or several evaluation bodies? One training body or several training bodies? One attestation body (MAC) or several attestation bodies? What conditions such bodies would have to meet to be approved?

36 Important provisions in 517/2014 Avoiding F-gas emissions (9) Certification requirements how to implement them in Turkey? What should the minimum requirements be for training/examination programmes in each sector should they be copied from the relevant EU legislation? Should any training/certification system cover both F-gases and ODS or F-gases only?

37 Important provisions in 517/2014 Avoiding F-gas emissions (10) Recovery/recycling/reclamation/destruction Mandatory recovery of F-gases from equipment by certified persons for recycling, reclamation or destruction Mandatory recovery of F-gases from F-gas container at the end of its life No specific requirements regarding recycling/reclamation/destruction, but Waste Directive applies

38 Important provisions in 517/2014 Avoiding F-gas emissions (11) Recovery/recycling/reclamation/destruction requirements how to implement them in Turkey? Establishing a system of collection and processing of used F-gases Activity A 7 of the Project may help

39 Important provisions in 517/2014 Record keeping and reporting (1) Record keeping and reporting

40 Important provisions in 517/2014 Record keeping and reporting (2) Record keeping requirements Equipment operators shall keep records of activities conducted on installed stationary RAC&HP, fire protection and electric switchgear equipment as well as on refrigeration equipment installed on trucks and trailers, containing 5 tonnes of CO 2 eq or more of F-gases E.g. for R-404A 5 tonnes of CO 2 eq = only 1.3 kg

41 Important provisions in 517/2014 Record keeping and reporting (3) Record keeping requirements - Sellers of F-gases shall keep records of purchasers - Service companies shall keep records of activities conducted for operators - Sellers of non-hermetically sealed RAC&HP equipment shall keep records of purchasers (evidence must be presented that equipment will be installed by a certified person/company)

42 Important provisions in 517/2014 Record keeping and reporting (4) Record keeping requirements How to implement them in Turkey? Central Register of Equipment Operators (CREO) an electronic database planned to be established in MoEU in Project Activity 8 may cover only F-gases or F-gases and ODS CREO would contain data on operators and their equipment as well as on any activities conducted on equipment MoEU would be able to monitor those activities, specifically leakage checks MoEU would be able to receive reports from CREO on number of operators as well as on type of equipment and type and quantity of F- gas in equipment

43 Important provisions in 517/2014 Record keeping and reporting (5) Reporting requirements Data to be reported for previous calendar year include inter alia : - imported/exported quantities of F-gases and of other fluorinated substances (also in products and equipment) - stocks of F-gases and other fluorinated substances on 1 January and 31 December of the reporting year No reporting obligation if <100 tonnes of CO 2 eq or <1 metric tonne per year (500 tonnes of CO 2 eq per year if in prod/equip) Independent audit if tonnes of CO 2 eq per year

44 Important provisions in517/2014 Record keeping and reporting (6) Reporting requirements How to implement them in Turkey? Database of Business Reports (DBR) an electronic database planned to be established in MoEU under Project Activity 8 may cover only F-gases and other fluorinated substances or also ODS (integration with the existing ODS Monitoring Software) Importers/exporters/users of F-gases and other fluorinated gases (and ODS?) would submit annual reports to DBR on-line Manufacturers/importers/exporters of products and equipment containing F-gases and other fluorinated gases (and ODS?) as well as entities who recycle/reclaim/destroy F-gases would also submit reports MoEU would be able to monitor and collect data contained in the reports

45 Possible Road Map for Turkey to comply with Regulation 517/2014 No. Proposed activity 1 MoEU to accelerate final approval and publishing of the current Turkish draft F-gas Regulation. 2 MoEU to accelerate approval and publishing of the important circulars based on that Regulation, and especially the circular dealing with certification and training system 3 MoEU (and possibly also other Turkish policy makers) to review the detailed LGA Table contained in Annex I to LGA report, which shows the gaps between provisions contained in Turkish draft F-gas Regulation and Regulation 517/2014, and the conclusions from that legislative gap analysis and to develop the preliminary position for the discussion at stakeholders and policy makers workshops that are planned to be organised under Activity 2 of the Project. 4 Industry stakeholders of the sectors covered by Regulation 517/2014 (RAC&HP, MAC, fire protection, electrical switchgear and F-gas solvents) and policy makers to provide their views on the scope of the revision of Turkish F- gas legislation and develop recommendations during the consultative workshops referred to above. 5 The MoEU in consultation with the Project Team to take decision on the final scope and format of electronic databases which are planned to be developed under Activity 8 of the Project and which are supposed to facilitate the implementation of F-gas legislation on the basis of Regulation 517/2014 in Turkey. 6 The Project Team in consultation with the MoEU to take into account recommendations developed at the workshops in planning the next activities in the Project. Identify specific views of the stakeholders regarding the possibility of implementation in Turkey of the provisions contained in Regulation 517/2014

46 Possible Road Map for Turkey to comply with Regulation 517/2014 No. Proposed activity 7 MoEU to collect recommendations from the workshops organised under Activity 2 and also further recommendations developed under other activities of the Project and take the final decision on the extent those recommendations should be included in the revised Turkish draft F-gas Regulation that is planned to be developed under Activity 9 of the Project. MoEU should also decide in consultation with the Project Team which of the legislative provisions should be included in the regulation itself and which should rather be published in the form of circulars. 8 MoEU to review the Turkish draft F-gas Regulation developed under Activity 9 of the Project and decide about the final version of that Regulation to be presented for the internal consultations and approval process. 9 MoEU to accelerate the process of approval and publishing of the revised Turkish F-gas Regulation. 10 MoEU to develop final versions of any circulars to the revised F-gas Regulation based on the drafts produced under Activity 9 of the Project, in particular the revised circular dealing with certification scheme. 11 MoEU to accelerate the process of approval and publishing of any circulars to be issued based on the revised Turkish F-gas Regulation.

47 Conclusions Several important provisions including HFC phase-down schedule as well as F-gas use bans, placing on the market bans and various obligations for undertakings are contained in the revised EU F-gas Regulation (EU)517/2014 It will be a great challenge for Turkey to follow those provisions a possible Road Map for Turkey has been proposed in that respect A series of sector-focused consultation workshops will be conducted in the framework of the Project where the details of implementation of those provisions in Turkey as well as the possible relevant Road Map may be discussed

48 Thank you for your attention! Contact : jankozak@poczta.neostrada.pl