“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.
Which?
“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.”
