Complexities of Refrigerant Regulations - Sanhua's perspective

Complexities of Refrigerant Regulations - Sanhua's perspective

Federico Bisco, Technical Director of Sanhua Europe, has studied the matter in depth, especially on the refrigerant gas front. His own articulated opinion on the topic of PFAS begins with a general and almost market observation rather than a technical one: 

“It seems that the intention of the legislators goes well beyond the environmental or technical problems, and is more directed towards reducing the dependence of the European market on non-EU productions, such as that of fluorinated refrigerants. In fact, about 80 percent takes place outside the European community area and the remaining 20 percent within the countries of the European Union, but it takes place under license from companies whose headquarters are located elsewhere.”

A consideration that invites an evaluation of the market perspective

“Europe is certainly still a fairly important market, but restrictive regulations such as those set by the F-gas Regulation or this revision of the REACH Regulation are certainly capable of characterizing our continent as an extremely compelling replacement market. At the same time, and despite the environmental market which is also growing in other areas such as the USA or China, markets with higher growth rates are more gradual in pushing the transition towards less impactful solutions. In doing so, they’re perhaps establishing operating conditions for manufacturers of machines and components and installers, and less strenuous and less drastic maintenance.”

Some environmentalists might say that they’re taking it easy …

“That’s not true—in China, valve bodies have been produced in stainless steel for some time now. It’s the only solution to date capable of avoiding the problems associated with the presence of lead in copper alloys, specifically brass, which have afflicted our market and which, despite a legislative restriction, still haven’t been solved. This is because to date producing brass without using lead—and, therefore, without triggering the environmental and health risks associated with this use—is an impracticable solution for cost reasons. And in the USA, HFOs are being used massively to tackle the world of air conditioning in which there’s no other solution than R290, which doesn’t seem possible in Europe.”

But let’s get back to us—to the restriction proposed under the REACH Regulation.

“The main defendant is R134a, considered as such due to its degenerative potential in PFAS, as a consequence of involving R1234yf. However, attention then turned to other gases such as R32, R1234ze and blends of HFO, among which we can mention R455A, R454C and R454B. This establishes a real and tangible difficulty for facing the future, because it puts practically everything that’s an alternative to propane out of the running. And if R290 up to 20 kilowatts is considered “acceptable” in terms of manageability, beyond the 20-kilowatt threshold a serious problem arises, with the associated consequences.


“We’re destined to see direct expansion systems reduced to a minimum; we’ll basically have only hydronic systems to allow the use of highly flammable gases in primary circuits without creating risks in confined spaces. The two blades of the scissors, F-gas and PFAS, seem to leave little room, even if someone claims to be able to use carbon dioxide also in applications intended for air conditioning!”

A rather audacious idea—to date, transcritical CO2 is efficient in combined applications, in which both refrigeration and air conditioning with heat recovery are worked on.

“The data from some trials seem to support these possible uses, but these are complex and expensive machines with a strong economic impact on the supply chain in terms of initial construction and installation costs. There are large market operators such as Panasonic or specialized operators such as Enex who are making heavy investments and are obtaining results with applications dedicated to air conditioning.”

A rather widespread uncertainty prevails.

“No matter how much we explore, however, nothing reduces the extent of the impact on the supply chain, and perplexity with respect to this regulatory pressure is also growing due to the fact that to date PFAS don’t yet have a clear risk profile: The scientific literature on the subject is not entirely in agreement and the traceable studies on the subject lead to conflicting conclusions. This allows a will to prevail that’s almost more guided by a political direction than by responsibility towards the environment or towards the health of the populations potentially affected by the PFAS cycle.”

But is the components market ready for this transition?

“After a few years of regulatory uncertainty, the recent update of the EN60335-2-24/40/89 standard has allowed us to gain a clearer picture of the product requirements necessary to operate in systems that adopt flammable fluids: The update has incorporated key and fundamental clauses such as 22.116 and 22.117 present in EN60335-2-40. The certification process necessary to certify the safety of electro-mechanical components is certainly now clearer and this allows Sanhua, in collaboration with important German certification bodies, to guarantee the total safety of its products in systems operating with A2L and A3 refrigerants. The product certifications obtained are aimed at verifying electrical safety and demonstrate that Sanhua components do not constitute potential sources of ignition. Among the many tests carried out by the certification bodies, we can mention the verification of the surface temperature of the coils in conditions of maximum stress (short circuit) and that there are no contacts that could generate sparks. This is certainly a methodological point that favors the transition, but, at the same time, it makes it necessary for those who apply the technologies—the operators in the field—to update them. And in any case, the general PFAS problem is still not solved, because the potential inclusion of PTFE and Teflon among the substances at risk of a ban could complicate the matter. At the moment, there’s no “economical” alternative available which allows us to overcome this obstacle.”

Is derogation plausible? Could it help?

“Yes, and it wouldn’t be the first derogation in this field: Let’s not forget that the presence of lead, we mentioned earlier, in the copper alloys (brass in particular) used to produce components is already the subject of a derogation that’s exceeded twenty years of life, because an acceptable replacement solution couldn’t be found. The industrial costs of fungible solutions are 80 percent higher and the impact in terms of commercial prices of any attempted solution has proved to be such as to induce the legislator to grant its use. Teflon could have the same “treatment” and perhaps, in our current state of knowledge and experimentation, it would be desirable.”

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