17. appendix 1: The complete country studies

17.1 Denmark

17.1.1 Country regulations with relevance

Legal (obligations, requirements, or prohibitions, including (but not limited to) acts, laws, regulations, and administrative or executive orders)

Denmark has implemented several regulations to reduce the usage of fluorinated greenhouse gases. Denmark’s primary F-gas legislation is the EU F-gas Regulation (517/2014). The law aims to reduce HFC usage by phasing down production and consumption by 79% by 2030. The regulation limits the amounts of HFCs that can be placed on the market in the EU and requires companies to report their HFC usage and emissions. As a supplement, Denmark has implemented national legislation, which is updated continuously. The latest update is from May 13^th, 2021, with Bekendtgørelse 1013.

F-gas bekendtgørelsen (2021)

The legislation prescribes further strictures than the EU legislation; the regulation explicitly omits HFOs, including when part of a blend with other refrigerants covered by the legislation. The Danish Environmental Protection Agency (EPA) (Miljøstyrelsen) enforces the regulations. Under the regulation, companies must keep records of their HFC usage and provide them to the EPA. Companies must also ensure their employees are qualified to handle and recover HFCs.

The Danish Environmental Protection Agency has appointed the organisation “Kølebranchens Miljøordning”, (The Danish Refrigeration Installers’ Environmental Scheme (KMO),

KMO (n.d.a)

to issue authorisations and keep track of which companies and individuals have permission to educate, trade and handle HFCs, including HFOs.

Soft regulatory instruments

The Danish Environmental Agency has established a knowledge centre for Climate-Friendly Refrigerants (Videncenter for Klimavenlige Kølemidler). The knowledge centre provides information, advice, and guidelines on refrigerants to technicians, manufacturers, and developers.

Education and Documentation Requirements

Denmark has different training and documentation requirements, depending on the refrigerant type and on the amount of refrigerant. In rough terms, it is possible to categorise the documentation requirements in three groups.

MAC: Individuals and companies must be certified according to Directive 2006/40/EC (MAC-directive)
Directive 2006/40/EC
to work with air conditioning systems on all types of vehicles. The authorisation is only relevant for the auto sector and systems below a 2.5 kg filling charge.
Christonik ApS (2023)
Category II requirements: Companies and personnel working with heat pumps and air conditioning systems with a refrigerant charge under 2.5 kg⁷ must meet Category II requirements.
KMO (n.d.b)
The educational requirements are more extensive, and all usage of HFC is ideally reported to KMO.
Category I requirements: The Category I requirements for working with systems larger than 2,5 kg coolant are more comprehensive. The Danish Working Environment Authority (WEA) sets educational requirements and restrictions. Category I companies are met with requirements of using a quality assurance system according to ISO 9001 with reference to BEK nr 1977 of 27/10/2021, appendix 7
BEK nr 1977 af 27/10/2021
and annually third-party control.

17.1.2 Monitoring

KMO was established in 1992, and in addition to the mandate mentioned above, another goal of KMO is to track the usage of HFCs and HFOs in Denmark. Originally the intention was that all authorised companies should report their use of refrigerants in KMO’s database. In practice, it has become a voluntary system that allows companies to register their refrigerant consumption. Companies have different systems for monitoring their consumption and not all refrigerant consumption is reported to KMO. Due to a database crash in January 2022,

KMO (2022)

submitting any usage data has been impossible for a period of time. As a consequence, there is a lack of overview of which companies and persons are currently approved to work with HFC substances.

KMO (2023)

In practice, sales and imports are recorded by each wholesaler and refrigeration company. This results in decentralised tracking, and mapping the amount of F-gas handled nationally can be difficult.

17.1.3 Use of HFO Substances in Denmark

The Danish F-gas consumption is well described in the report “Danish consumption and emission of F-gases in 2020”, from the Danish Environmental Protection Agency.

The Danish Environment Protection Agency (2020)

The report lists the import and consumption of F-gases in Denmark, including some information and data on HFOs. The quantities of HFOs imported are increasing. In 2019, 22.7 tonnes of HFOs were imported, which increased to 30.2 in 2020. According to the Danish Tax Agency, the quantities of HFO substances imported in 2022 were 34.7 tonnes. It is expected that there has been and will be a growth in the usage of HFOs in recent years due to the low GWP factor.

Year	Refrigerant	Quantity (Tonnes)
2022	HFO-1234yf	30.5
2022	HFO-1234ze	4.2
	Total:	34.7

Table 6 Danish HFO-1234yf and HFO-1234ze import in 2022 (The Danish Tax Agency (2023))

There is no overview of the amount of HFOs exported.

The usage of HFOs can be divided into different sectors based on their usage. This section describes the following: MAC in cars, RACHP equipment, products which use HFOs as blowing agents, such as insulation materials, and as an aerosol propellant in spray cans.

According to the latest data reported to the EU, the following number of Danish companies reported activities in the field of F-gas refrigerants. This includes all types of F-gases and not just HFO; a company can report on more than one activity:

Ludig et al (2022)

Importers	13
Exporters	3
Equipment importers	16
Destruction companies	0
Quota authorisers	1

The Auto sector

It has not been possible to determine the exact quantities of the auto sector related HFOs imported, recycled, or disposed of in Denmark. Sources insinuate that they find it likely that only a minor amount of HFO from cars is sent to destruction. The selling price of HFO is at a level where stakeholders in the market find it profitable to collect and recycle HFO.

Danish Car Recycling Association (2023)

RACHP

There is a general preference in Denmark towards using natural refrigerants in cooling systems and heat pumps. This shift is driven by the desire to reduce the environmental impact of traditional synthetic refrigerants and move towards more sustainable and climate-friendly alternatives. The trend for using HFOs is not as strong as in other European countries, but they are used in some commercial refrigeration and heat pump installations.

Ahlsell (2023)

A large part of imported HFO-1234ze is expected to be used for commercial refrigeration.

Danish Environment Protection agency (2020)

Aerosol propellants

HFO-1234ze has substituted HFCs in aerosols for specific industrial purposes since 2019.

Danish Environment Protection agency (2020)

17.1.4 Existing systems for collection and end-of-life treatments of HFOs

KMO

The collection of HFOs from the refrigeration and air-conditioning industry mainly occurs at the wholesalers. Wholesalers can participate in a voluntary KMO collection scheme for HFCs/HFOs. In 2020, KMO established a return scheme for flammable refrigerants such as HFOs.

KMO (2020)

New refrigerants are sold with a KMO fee. To some extent, this fee covers the wholesaler's handling costs and the destruction or reuse of the recovered refrigerants. The customers who hand in used refrigerant will get a refund. The size of the refund depends on whether the refrigerant is clean or contaminated.

The price of refrigerants at the wholesaler depends on three elements: The KMO fee, the CO₂ tax, and the product's price. It is only possible to get a part of the KMO fee back. The KMO tax is found on all F-gases, both HFCs and HFOs. The figure below shows a graphical price example of HFO and HFC. The size of the CO₂ tax is determined by law. For example, the current tax level on HFO is 0.17 €/kg and 36.2 €/kg for R134a.

Skat (n.d.)

Figure 7

The refrigerants are transported in approved service cylinders, and each wholesaler has their unique service cylinders. There is a distinction made between flammable and non-flammable substances. Service cylinders are either bought or rented.

Most fluorinated refrigerants returned to the wholesalers are then exported to Germany, France, or the Netherlands. In some cases, the used refrigerants are purified through distillation, reimported to Denmark, and sold as regenerated refrigerants. Regenerated, reimported refrigerants do not count in the EU import quota system and are not subject to CO₂ taxation, as the refrigerants have already been taxed and registered previously. It is possible to regenerate up to 80% of a batch; this applies to both HFCs and HFOs. Chlorofluorocarbons and hydrochlorofluorocarbons (CFCs and HCFCs) are always destroyed.

Some wholesalers don’t regenerate, and the export is primarily for destruction.

Ahlsell (2023)

Another option for disposing of HFOs and HFCs is at recycling sites. These are municipal and are not part of KMO's voluntary return scheme. If return cylinders with refrigerants are handed in at a recycling site, a fee must be paid, and the return cylinders are lost to the recycling site. Due to the waste fee and the cost associated with the purchase of a new one return cylinder, the quantity that is returned at the recycling sites is very limited. Return cylinders are pressure tanks and are, therefore, handled as hazardous waste and sent to destruction. It is typically Stena Recycling that handles refrigerants from the recycling sites. Previously, Fortum in Nyborg received fluorinated refrigerants for destruction. However, currently, they do not offer this service.

Fortum Waste Solutions A/S (2023)

HFO is exported for reclamation and as waste for incineration to other EU countries, primarily Germany, France or the Netherlands. Sources indicate that the exported quantity is considerably lower than the imported quantity.

Ahlsell (2023)

In some cases, the used refrigerants are purified through distillation, reimported to Denmark, and sold as regenerated refrigerant. Regenerated, reimported refrigerants do not count in the EU import quota system and are not subject to CO₂ taxation, as the refrigerants have already been taxed and registered previously. As mentioned above, it is possible to regenerate up to 80% of a batch of HFCs or HFOs, whereas CFCs and HCFCs are always destroyed. Other wholesalers do not regenerate, and the export is primarily for destruction.

Ahlsell (2023)

End-of-Life Vehicles

Both new and second-hand imported vehicles are covered by producer responsibility in Denmark. To import vehicles in Denmark, it is required to register at The Danish Producer Responsibility (DPA). DPA is established under the Danish Environmental Protection Act and administers the national register and Danish legislation on producer responsibility. At end-of-life, the producer, company or private person who has imported the vehicle is required to hand over the car to either the importer or to an ELV reception site. In Denmark, the last owner receives a car scrapping premium when the car is handed over to the car breaker. Stena Recycling has established a collaboration on a return system with Danish car scrappers.

Stena Recycling (n.d.)

WEEE

The rules for extended producer responsibility for WEEE in Denmark are the same for importers and producers. All must register their business at DPA. Importers and producers are required to take back or ensure a take-back scheme, e.g., by joining a compliance scheme operated by a producer organisation. The largest producer organisation in Denmark is Elretur.

Elretur (n.d.)

Products

In waste where the HFO is included as a component (as a blowing agent, for example), the product is treated as waste concerning the product as a whole. The waste is usually treated as a small combustible fraction or sent to landfill.

Stena Recycling (2023)

17.2 The Faroe Islands

The Faroe Islands are a part of the Danish kingdom, but The Faroe Islands have had their own home rule act since 1948, the first paragraph stating that the Faroe Islands are a home-ruling society. Umhvørvisstovan – the Environmental Agency of the Faroe Islands – is the national environmental authority. In 1988, the first act on Environmental Protection was put in force. The Faroe Islands is not a member of the European Union or the EEA area. Denmark initially ratified the Montreal Protocol without making a territorial exclusion of the Faroe Islands, but in 1991, Denmark expressed reservations about the application of the Montreal Protocol to the Faroe Islands. In 1997, however, Denmark lifted the reservation again. The Faroe Islands have also been excluded from some of the subsequent amendments to the Montreal Protocol. These reservations have been lifted again as well. The Faroe Islands are not territorially excluded from the ratification of the Kigali Amendment.

UNEP ozone secretariat (n.d.)

The Faroe Islands, therefore, need to phase down their consumption of HFCs due to the high GWP of HFCs, even though the Faroe Islands are not under any legal commitment to meet the Kyoto Protocol. However, the Faroese government have signed the United Nations Framework Convention on Climate Change (UNFCCC). The Faroese Environment Agency report their GHG emissions annually to the IPCC as a part of the inventory for the Kingdom of Denmark, with HFCs and other f-gases being included in the list of GHG emissions that the Faroe Islands report on.

Nielsen et al (2022)

17.2.1 Country regulations with relevance

Legal (obligations, requirements, or prohibitions, including (but not limited to) acts, laws, regulations, and administrative or executive orders)

The Faroe Islands do currently not have any legislation on F-gases. The Faroe parliament is currently in the process of adopting a regulation on F-gases. However, HFOs are not explicitly included in the new proposed legislation.

Umhvørvisstovan (2023)

General waste handling is regulated by the Environment Protection Act.

Sæmundsdóttir (2021)

Fiscal (subsidies, taxes, or charges)

The Ministry of Finance and the Ministry of Environment, together with Umhvørvisstovan (the Environmental Protection Agency), have made a proposal to change the bill on tax on production and import and custom regulation in order to put a tax on the import of F-gases. The tax will be based on the gases’ GWP values, and the size of the tax will be similar to the Icelandic taxes. HFOs are not included in the new taxation.

Umhvørvisstovan (2023)

The Faroe Islands practice extended producer responsibility, and the scheme is run by the two waste management facilities, IRF and KB. The fees for using waste facilities, transfer and sorting stations, landfills and incineration plants are decided at a national level.

Swedish Competition Authority et al (2016)

Faroese companies pay a gate fee for waste; the price is higher for mixed waste and lower for clean, sorted fractions. For example, the gate fee for WEEE is 5 DKK/kg.

Swedish Competition Authority et al (2016)

Soft regulatory instruments (recommendations, technical standards, voluntary bottom-up initiatives (self-regulation), legislation-induced co-regulatory actions)

None were identified.

17.2.2 Use of HFO Substances in the Faroe Islands

The Faroe Islands have ratified the Kigali Amendment, and they need to phase down the use of HFCs. There is some information available concerning HFC consumption that can serve as an indicator for future HFO needs. The recently submitted emission inventory report for Denmark, Greenland, and the Faroe Islands for 1990-2020 also maps HFC emissions on the Faroe Islands.

Nielsen et al (2022)

Most F-gases that are emitted are HFCs (nearly 99%)
There is no production of HFCs on the Faroe Islands.
Four types of HFCs are in use on the Faroe Islands, namely the HFC gas blend HFC-507a that has substituted HCFC-22. HFC-507a has no ODP but has a high GWP; it is mainly used for refrigeration both domestically, commercially and in the industry; this also includes fishing vessels that previously also used HCFC-22.
There has been an increase in HFC emissions in recent years due to the rise in the use of HFC-125 and HFC-143a, both components in the HFC-blend HFC-507a.

The auto sector

No data on the use of HFOs in the auto sector were obtained, but considering the European market, there is no doubt that most new passenger vehicles imported to the Faroe Islands from Europe will contain HFO-1234yf in their MAC system.

Umhvørvisstovan (2023)

Refrigeration, Air Conditioning and Heat Pumps (RACHP)

There is an increase in heat pump installations on the Faroe Islands, and the authorities generally recommend shifting to heat pumps. Heat pumps are also being installed in newly constructed buildings. Several of the installed heat pumps use HFC/HFO blends. Students at the Faroese Vocational School receive information about HFOs as part of their education.

Vinnuháskúlin (2023)

Larger Industrial Fishing vessels mainly use ammonia as an on-ship refrigerant. Smaller fishing vessels use other refrigerants, HFCs or HFC blends. But there is an ongoing shift towards using ammonia and CO₂ on fishing vessels.

Umhvørvisstovan (2023)

Foaming agents

No use of HFOs was identified. Isolation foams are generally incinerated on the Faroe Islands.

IRF (2023)

Aerosol propellants

No use of HFOs was identified. Spray cans are exported to Stena Recycling in Denmark.

IRF (2023)

17.2.3 Existing systems for collection and end-of-life treatments of HFOs

Industrial and commercial clients can purchase gas cylinders for F-gas recovery. These are then transported to- or picked up by the waste company and forwarded to a collection point where the cylinders are labelled and provided with a pictogram and later exported for destruction.

IRF (2023)

The system for shipping vessels is different. Shipping vessels purchase chemicals, including refrigerants, via global suppliers (e.g., Unitor or Drew Marine) that deliver to ports across the globe. They can then pick up the gas cylinders at a prespecified port and return them to a port as well,

Vinnuháskúlin (2023)

and there exist different cylinder exchange programs using standardised cylinders. Typically, the fishing vessel’s engineer handles and maintains the equipment on the fishing vessels instead of a refrigeration technician.

Vinnuháskúlin (2023)

The Faroe Islands have two different waste and recycling companies; both companies handle waste from private households as well as waste from institutions and companies:

Interkommunali Renovatiónsfelagsskapurin L/F (IRF) is a Faroese inter-municipal waste and recycling company owned by 29 Faroese municipalities. Their activities include the collection of industrial waste in all the municipalities and the collection of hazardous waste.
Dansk Affaldsforening (n.d.a)
The IRF handles the waste from appr. 11 000 households.
The other company is Kommunala Brennistøðin (KB) and covers the capital of Tórshavn. The KB handles approximately the waste of 7 500 households.
Dansk Affaldsforening (n.d.b)
KB also handles vehicle scrappage on the Faroe Islands and the prior environmental treatment of cars for scrapping. IRF have a collaboration with KB regarding vehicle scrapping.
IRF (2023)

The IRF and KB are responsible for waste collection and treatment. Each company has facilities, including incinerators, landfills (for non-combustible waste) and reuse or recycling centres. Recycling infrastructure in The Faroe Islands is limited, and recyclables are exported

Papineschi et at (2019)

Two companies operate waste shipments and must report their waste transfers annually.

All F-gases are shipped to Denmark. There are no destruction or reclamation facilities for F-gases in the Faroe Islands. Used WEEE equipment is also shipped to Denmark for destruction by Stena Recycling; both KB and IRF export to Stena Recycling in Denmark. IRF does currently not receive any HFOs.

IRF (2023)

Further guidelines and instructions from a governmental level concerning how to handle construction waste, the risks of improper handling of systems or appliances containing refrigerants when renovating, and how to handle hazardous substances that are being phased out are requested by practitioners. There is also a need for further action to implement circular economy ambitions better.

IRF (2023)

Monitoring systems

There are no existing monitoring systems in place for HFOs, but all registered HFC importers are required annually to supply information to the EPA. The reporting form has an option to report on other F-gases than HFCs; here, both 1234yf and 1234ze have been reported.

17.3 Finland

17.3.1 Country regulations with relevance

Legal (obligations, requirements, or prohibitions, including (but not limited to) acts, laws, regulations, and administrative or executive orders)

The main legal requirements in Finland are the EU F-gas Regulation (517/2014) and the EU WEEE Directive (2012)/19/EU). Both have been implemented in national law.

Ymparisto (2023)

Furthermore, the Finnish waste legislation follows the EU waste legislation.

The Finnish training and certification scheme goes beyond the EU F-gas Regulation since all garages need to be certified, and the scheme covers all mobile equipment and activities such as recovery, installation, and repair.

Birchby et al (2022)

A government decree from 2016 outlays required qualifications for handling vehicle equipment containing fluorinated greenhouse gases. The act describes the requirements for the operator and individuals working with the installation, maintenance, reparation, refilling, decommission and recycling of refrigerants. They are defined according to the definition of fluorinated greenhouse gases in the EU F-gas Regulation (517/2014), and HFOs are therefore not included. HFOs are not listed in the annex specifying different refrigerants. However, any blends containing fluorinated greenhouse gases are subject to the requirements. The requirements differ depending on whether the equipment contains less or at least 3 kg or more refrigerant. All require a certain level of education.

Tukes (2016)

The Finnish Environment Institute Syke is responsible for the market surveillance of refrigerants and equipment containing refrigerants.

Ymparisto (2023); Syke (2023)

A data collection system also collects data on F-gas quantities used in bulk and equipment. Syke is responsible for collecting annual data on F-gases for Finland’s GHG emission inventory and also collects data on HFOs. According to the Environmental Protection Act (517/2014) 165§, companies must report requested data on fluorinated greenhouse gases to Syke.

Miljöskyddslag (2014)

HFOs are reported in the GHG inventory as additional information and not included in the national total.

Syke (2023)

The Finnish Chemicals Agency Tukes is the responsible authority supervising that the refrigeration branch complies with the qualification requirements. There are currently (2023) no qualification requirements for handling HFOs, so the following description for required qualifications concerns HFCs.

Ymparisto (2023); Syke (2023)

There are no refrigerant storage reporting requirements to the emergency services by the Chemical Safety Act unless the refrigerants are highly flammable. Tukes lists HFO-1234yf to be such a substance, so if more than 1 ton of HFO-1234yf is stored in cylinders or contained in appliances, it needs to be reported to the authorities.

Tukes (n.d.a.)

Tukes

Companies and individuals that install equipment containing fluorinated greenhouse gases (F-gases) need to be approved and qualified by Tukes before starting their operations if they provide any of the following tasks:

Connect or open refrigerant circuits of equipment containing F-gases.
Recover F-gases or F-gas-based solvents from equipment.
Carry out leak checks on the equipment.

All RACHP companies and individuals are publicly listed, making it possible to check for certified personnel, and the listings can be found on Tukes' website. The register also holds information on companies that service mobile air conditioning and the waste management companies that treat F-gases. Only companies registered by Tukes are allowed to buy refrigerants that contain F-gases and equipment containing them,

Tukes (n.d.b)

except the following actions do not require any qualifications regarding F-gases:

For buying for resale
To sell
For collection, transport, and delivery.
Ymparisto 2023

There are currently no qualification and approval requirements from Tukes relevant to handling HFOs

Syke (2023)

Hazardous waste

The Finnish waste legislation is based on the EU Waste Framework Directive. F-gases are classified as hazardous in the Government decree on waste (179/2012) and must, therefore, be treated as hazardous waste. They are listed under 14 06 waste organic solvents, refrigerants, and foam/aerosol propellants with waste code number 14 06 01* Chlorofluorocarbons, HFCFC, HFC.

Ministry of the environment (2012)

Taxation

F-gases are recovered, reclaimed, and destroyed in Finland, but no official scheme supports the practice. There are no taxes on HFC or other refrigerants in Finland, nor are there any money-based take-back schemes.

Ministry of the environment (2012)

17.3.2 Use of HFO Substances in Finland

According to the latest data reported to the EU, the following number of Finnish companies reported activities in the field of F-gas refrigerants. This includes all types of F-gases and not just HFO; a company can report on more than one activity:

Ludig et al (2022)

Importers	5
Exporters	1
Equipment importers	15
Destruction Companies	2
Quota Authorisers	1

Finland has both import and export of HFOs. The import consists of equipment containing HFO and HFO in bulk. HFOs are primarily imported in equipment, but there has been a significant increase in bulk import in recent years; most are expected to go to MAC applications.

Import of the following HFO substances has been identified in Finland: HFO-1234yf, HFO-1234ze(E), HFO-1336mzz(Z) and HFO-1233zd(E).

Ymparisto (2023)

The auto sector

HFO-1234yf has been the refrigerant in all new cars imported and registered in Finland since 2018. Only pure HFOs are used for this application. The first passenger vehicles in Finland equipped with HFO-1234yf were imported and registered in 2012. Light-duty vehicles equipped with HFO-1234yf were first reported in 2016, and in 2020 the share of light-duty vehicles constituted 39%. It has, however, still been possible to import used cars equipped with HFC-134a. Syke has estimated that of the used vehicles imported in 2020, 80% were equipped with HFC-134a, and 20% were equipped with HFO-1234yf, compared to 90% and 10% in 2018.

Statistics Finland & Ministry of the environment (2022)

There is one car manufacturing plant in Finland that mainly exports its products. There is, therefore, also some export of R1234yf out of Finland in passenger cars.

Syke (2023)

For transport refrigeration, The HFC/HFO blend R-452A was introduced to the market in 2015 and is now widely used in new transport refrigeration equipment.

Statistics Finland & Ministry of the environment (2022)

RACHP Sector

HFOs are used in all RAC equipment except domestic refrigeration. Both pure HFOs and HFC/HFO blends are used in applications. In commercial, industrial and transport refrigeration, practically only HFO/HFC blends are used. In stationary AC (incl. heat pumps), pure HFOs and blends are used, while in MAC, only pure HFOs are used.

Syke (2023)

Larger refrigeration and air conditioning equipment: In Finland’s 5^th Biennial Report under the UNFCCC from 2022, it is projected that the use of F-gas refrigerants in commercial refrigeration (food retail stores and professional kitchens) will be fully phased out and replaced by natural refrigerants such as CO₂and hydrocarbons by 2035.
Statistics Finland & Ministry of the environment (2022)
According to a spokesperson from the industry, CO₂ is mainstreamed in commercial refrigeration. Industrial refrigeration mainly uses ammonia, and propane and butane are used for smaller equipment.
In Finland, HFOs are used in larger heat pumps and chillers (100 kWh) installed in commercial buildings and by industry.
Large heat pumps (0.1 MW- 20 MW): It is estimated that until 2019, all installed heat pumps of this size contained R-134A. Since 2019, there has been data on the instalment of large heat pumps containing HFO-1234ze, but only a small percentage of annually installed large heat pumps contained HFO-1234ze in 2019 and 2020 (less than 10%). Several other refrigerants are also reported to be used for this type of heat pump, including ammonia and the HFC/HFO blends R-450A and R-513A.
Statistics Finland & Ministry of the environment (2022)

Foaming agents and aerosol propellants

In Finland, HFOs are known to be used as foaming agents and aerosol propellants. Imports of aerosol sprays containing HFO aerosol propellant have been identified and registered since at least 2018.

Syke (2023)

17.3.3 Existing Systems for Collection and End-of-life Treatments of HFOs

F-gases are classified as hazardous waste in Finland. Hazardous waste may only be processed or utilised by a facility with an environmental permit. All F-gases should be delivered for recycling. Several waste handling companies are authorised to collect and transport waste with waste code 14 06 01*. The companies are listed below, some operate in the entire country, and some in specific regions:

Avfallshanteringskollen (n.d.)

Eco Scandic Oy
EKA-Palvelut
Kaeser Kompressorit Oy
Kuljetusliike Harry From Oy
Lahti Minikonepalvelu Oy
Liedon kunta, Kisälli
Mantilan Kuljetus Oy
MEK-Trans Oy Ab
Kuljetusliike Nykänen Oy
Salon
Salon Hyötykäytto Oy
Stena Recycling Oy
Kuljetusliike J. Pääaho Oy
Transkivimäki Oy
Mj Salmela Oy
Veikko Lehti Oy
Syke (2023)

Recovery

According to a spokesperson from the industry, even though HFOs are not covered by the current legislation, HFOs are handled in the same way as HFCs. HFOs are, therefore, often also included in reporting required for fluorinated greenhouse gases. While the recovery practice started slowly, it is now working well, and several recovered refrigerants are being reclaimed.

SKLL (2023)

Foam-blowing agents in foam products are generally not considered recyclable, so they are incinerated after recovery.

Maintenance and decommissioning of MAC: In 2012, Tukes published a guide on handling R1234yf in MAC systems. They refer to the safety sheets from Honeywell and DuPont, describe R1234yf as highly flammable, and state it may cause frostbite and cause suffocation if not handled correctly. People are required to wear personal protective equipment gear, including protective eyewear and heat-insulating protective gloves. Furthermore, HFC refrigerants, for instance, R134a, must not be added to MAC systems that work with R1234yf, and R1234yf may not be added to AC systems meant for R134a. It is also required to purchase new maintenance equipment to handle R1234yf. Service- and test equipment for HFC refrigerants must not be used for R1234yf.
Tukes (2012)
Collection of WEEE: Finland has Extended Producer Responsibility (EPR) for Waste from Electrical and Electronic Equipment (WEEE), meaning that importers and producers are responsible for waste management after decommissioning and pay a fee for the equipment. Numerous producer organisations administrate and are responsible for collecting, transporting, managing, and recycling WEEE on behalf of their members.
Centre for Economic Development, Transport and the Environment (n.d)

End-of-life Treatment Options

Permits for destruction and reclamation go through the local municipalities.

Syke (2023)

Destruction: Fortum is the only company that destroys refrigerants in Finland. They incinerate refrigerants and are required to report the amounts to Syke. Fortum does not export refrigerants for destruction elsewhere.
Syke (2023)
Recycling/ reclamation: Two companies in Finland have an environmental permit for refrigerant recycling: Eco Scandic Oy and Darment. Eco Scandic Oy receives refrigerants from both Sweden and Finland. They are currently testing a new business model that is partly based on providing reclamation as a service, meaning that the recovering entity buys back the reclaimed refrigerant at a fixed lower price lower than the market price. But they also sell reclaimed refrigerants to third parties that do not recover or collect refrigerants. Reclaimed refrigerants are generally cheaper than virgin.
Eco Scandic (2023)
They received a total of 67 tons of F-gas for reclamation in 2022. Of these, less than 2% were HFOs (1.34 tonnes), mainly composed of HFO-1234yf and HFO-1234ze. This is considered to be partly due to the relative novelty of HFOs in HVAC-R equipment since the average lifetime for these appliances is approximately at least 5-7 years. Eco Scandic Oy has a waste fee in Sweden and Finland of at least 4,5€/kg, as stipulated on their website. However, waste fees can range from 18€/kg, depending on the service provider. Eco Scandic has agreements with several wholesalers, providing reclamation of their recovered F-gases and then selling them back to the wholesaler. According to Eco Scandic Oy, the take-back models vary sporadically in the different sectors. Eco Scandic Oy typically creates a specific take-back model in collaboration with the specific stakeholder. Eco Scandic Oy reclaims HFC/HFO blends and pure HFCs and HFOs. Eco Scandic Oy sends unreclaimable F-gases are sent to Fortum for destruction. The approach varies slightly when it is an A2L-classified refrigerant rather than a non-flammable refrigerant, Eco Scandic Oy processes both types.
Eco Scandic (2023)
Export of Waste: No waste export of HFO substances was identified.

17.3.4 Other Findings

Natural refrigerants are widely used for several applications, but adequate natural alternatives are not available for certain applications. Flammability is especially an issue. Some companies in Finland are working on research and development on natural refrigerant applications.
Syke (2023)
The industry is generally waiting for the upcoming legislation, both the forthcoming revised F-gas Regulation and what a potential ban on PFAS can entail, waiting to see the best way to proceed.
SKLL (2023)
There is a need for more qualified personnel to install equipment because of increased demand, while there is a decreasing interest in education. There was a university education programme, but it has been closed. It is expected that there will soon be a lack of engineers with system design expertise. However, another university has opened a new research field on heat pumps.
SKLL (2023)
There is a general concern for TFA in Finland, but no studies have been conducted.

17.4 Iceland

17.4.1 Country regulations with relevance

Legal (obligations, requirements, or prohibitions, including (but not limited to) acts, laws, regulations, and administrative or executive orders)

Iceland has signed the Montreal Protocol and accepted the Kigali Amendment.

Ozone Secretariat (n.d.)

Iceland is not part of the EU but is part of the internal European market via the EEA agreement.

Icelandic F-gas Regulation

The current Icelandic F-gas Regulation is from 2019; HFOs are currently not covered by the regulation since fluorinated greenhouse gases in the Icelandic regulation are defined as:

Hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride and other greenhouse gases that contain fluorine and are listed in Annex I to Regulation (EU) no. 517/2014 or mixtures containing any of these substances. (Article 3, point 2)

This definition excludes HFOs since HFOs only are listed in Annex II of the EU F gas regulation.

The regulation: 1066/2019: Reglugerð um flúoraðar gróðurhúsalofttegundir

Reglugerð nr. 1066/2019

has repealed earlier legislation with the same focus area, including

Keller et al (2020)

Regulation No 230/1998 prohibited importing, producing, and selling HFCs for uses other than refrigeration systems, air conditioning and drugs (MDIs).
Regulation No 834/2010 repealed 230/1998 and became a regulation specifically targeting F-gases (instead of all gases contributing to the greenhouse effect). This regulation did, to a large extent, implement regulation (EC) No 842/2006 as dictated by the EEA agreement.
This regulation also prohibited the production, import and sale of HFCs or products containing HFCs, except for HFCs used in refrigerants, air conditioning equipment and MDIs.
Regulation 1279/2018 amended 834/2010 by implementing import quotas according to the Kigali Amendment.

The current Icelandic Regulation 1066/2019 combined 843/2010 and 1279/2018 into the Icelandic legislative system and does largely adopt the rules articulated in Regulation (EU) No. 517/2014 on fluorinated greenhouse gases.

Regulation 517/2014/EU

The main difference is regarding the import quota.

Umhverfis Stofnun, n.d.

Iceland has its own quota system in place, as they are not included in the EU Commission’s quota system.

The Icelandic Regulation 1066/2019 states that 89% of the total allowed import quota each year is allocated to companies already on the market in the years leading up to the allocation. These actors will get a license with quotas corresponding to their average market share from the earlier period. The remaining 11% is allocated to actors who have applied for an import license. These actors will then be allocated a share of the 11%. As the EU regulation stipulates, Icelandic Regulation 1066/2019 Appendix I stipulates a step-by-step phasedown on imports of all hydrofluorocarbons to Iceland.

Reglugerð nr. 1066/2019

This means that currently (2023), only 35% of the original quantity (from the mean of the baseline years 2011-2013) can be imported to Iceland. In other words, the percentage of the baseline is currently set 10%-points lower in Icelandic legislation than what the EU regulation 517/2014 mandates.

Regulation 517/2014/EU

Likewise, the Icelandic regulation stipulates a percentage of baseline lower than the EU regulation in 2030. This outlines the overall framework for how to phase down HFCs (and certain other f-gases), which will influence how HFOs are continuedly treated in the future.

WEE regulation, no. 1061/2018

Besides Regulation 1066/2019, which is central to the general rule of F-gases in Iceland, Regulation 1061/2018 on Waste Electrical and Electronic Equipment

Reglugerð nr. 1061/2018

(WEEE) is relevant for the end-of-life treatment of F-gases. In short, this is an adoption of EU Directive 2012/19 on WEEE.

Directive (EU) 2012/19

Regarding F-gases, two appendixes to Regulation 1061/2018 are relevant: Appendix I(b) and II 188, also represented in the EU Regulation.

Directive (EU) 2012/19

Appendix I in Icelandic regulation 1061/2018 clearly defines the equipment relevant for the current compounds of interest – “heat exchangers”. This is also the case for the EU 2012/19 regulation, but the Icelandic list is less comprehensive.

Appendix II of Regulation 2012/19 specifies how the WEEE should be handled. By point 1i, chlorofluorocarbons, hydrochlorofluorocarbons, hydrofluorocarbons, and hydrocarbons must be removed from the electric and electronic equipment. These must be recycled or disposed of by the relevant law on waste. It must again be highlighted that HFOs are not currently explicitly addressed. Appendix II further stipulates that any ODS or gas with a GWP higher than 15 must be properly separated from the equipment and treated correctly in accordance with the regulation on F-gases. This includes gases contained in foam and cooling circuits. However, no pure HFOs have a GWP above 15; this is, therefore, only relevant for HFOs that are part of a blend.

The MAC directive, no. 822/2004

EU MAC Directive 2006/40/EC prohibits F-gases with a GWP higher than 150 from filling in mobile air-conditioning equipment.

Directive (EC) 2006/40

This has been implemented into Icelandic regulation 822/2004 through amendments introduced after 2006.

Reglugerð nr. 822/2004

Potential future developments

Iceland is awaiting the upcoming revision of the EU F-gas legislation. This will likely decide any future updates of the Icelandic F-gas legislation.

Umhverfis stofnun (2023)

There is generally a shift towards using natural refrigerants rather than towards HFOs; the transition to natural refrigerants is also officially supported, for instance through joint Nordic initiatives such as “Nordic Criteria of Green Public Procurement”,

Helgadóttir et al (2022)

a report published by the Nordic Council of Ministers that provides resources and guidance for the public administration to avoid the purchase or to find alternatives to appliances containing f-gases with a high GWP.

17.4.2 Fiscal (Subsidies, Taxes or Charges)

Icelandic Recycling fund

In Iceland, The Icelandic Recycling Fund aims to secure (economical) means for handling waste in Iceland

Úrvinnslusjóður (n.d.).

by leaning on the principle of “polluter pays”. This is mandated through Law no. 162/2002 on processing fee.

Lög nr. 162/2002

Part of this legislation and taxation are directed at refrigerants, as described in Article 8, point 9. Appendix XV further extrapolates which specific refrigerants are taxed in which amount (even though every refrigerant on the list is currently taxed the same amount). HFOs are implied in this taxation under “3824.9006: Other refrigerants” in Appendix XV.

The tax is collected as an expedition fee through import and is currently priced at 2,5 ISK/kg for every kind of refrigerant. The money is collected for The Icelandic Recycling Fund to pay for the waste handling this fund is responsible for. 0.5% is going to an administration fee to the Treasury. Before January 1^st, 2003, it cost 98 ISK/kg in import duty for all refrigerants.

Brynjarsson & Hilmarsson (2020)

In other words, the tax has been lowered considerably. Some argue that this tax (regarding F-gases) costs more to upkeep administratively than it is worthwhile because few claim the fund to the degree it was planned for. The tax was lowered because of a significant operating profit for refrigerants accumulated; each year, a couple of hundred tons of F-gases were imported, but only a few tons were returned for waste disposal.

Brynjarsson & Hilmarsson (2020)

Not all types of appliances are part of the Icelandic Recycling Fund’s jurisdiction. WEEE, refrigerants, foam, vehicles and fire extinguishing equipment are all part of their jurisdiction.

Iceland Recycling Fund (2023)

Law on Environmental and Natural Resource Taxes, no. 129/2009

The newest, significant Icelandic regulation (with taxation as the primary instrument) is adopted through Law no. 135: the Act of Amendment of various laws regarding the budget for 2020.

Lög nr. 135/2019

This creates a new chapter in the Law on Environmental and Natural Resource Taxes, no. 129/2009

Lög nr. 129/2009

- chapter III with articles 13–16. This is the legislature measure with the highest economically significant incitement for reducing the import of high GWP F-gases into Iceland. The amount of import duties to be paid is considerably more significant than the expedition fee for the Icelandic Recycling Fund. According to this legislation, the import duty to be paid for F-gases is between 30 ISK/kg–10.000 ISK/kg. The higher the GWP of the F-gas, the higher the tax is, up to a maximum of 10.000 pr. Kg, like it is in, e.g., Denmark.

Helgadóttir et al (2022)

Article 13 provides a table for specific F-gases and their respective tax price and (UK) customs numbers. The list in the legislative document contains several commonly used HFCs, PFCs and blends. Article 13, §3 stipulates that:

In the case of imports of fluorinated greenhouse gases other than those specified in paragraph 2. must pay tax based on the following criteria:
1. For fluorinated greenhouse gases not specified in the 2nd paragraph. must pay tax in the amount of ISK 10,000/kg.
2. For mixtures not specified in paragraph 2. the amount of tax shall be calculated based on the proportions of the materials that make up the mixture.
3. For other mixtures not specified in paragraph 2. and the provisions of item 2 cannot be applied. a tax in the amount of ISK 10,000/kg must be paid.

(Law no. 129/2009 [machine translated], 2009)

If the imported fluorinated GHGs are not listed in Article 13, the tax will be 10,000 ISK/kg; if it is a blend, the price will be determined based on the different components in the blend. Since HFOs are not classified as fluorinated greenhouse gases, there is no taxation on HFOs, and for any blends containing HFOs, that proportion does not count when calculating the price.

It is expected that import taxation rather than the quota system is responsible for the decrease in imports since imports are way below the allowed quotas. The import tax has received a mixed reception from the industry; some argue that HFCs should be even more expensive so that natural refrigerants would gain an economic advantage.

Umhverfis stofnun (2023)

17.4.3 Monitoring

There are no requirements to monitor HFOs; therefore, there is no official monitoring of HFOs in Iceland. Some information can be collected through the following:

The National Inventory Report (published by The Environment Agency of Iceland).
The Montreal Protocol and related amendments (Kigali amendment).
UNFCCC (e.g., Climate Action Plans).
EU f-gas working groups and EFTA.

Relevant stakeholders/actors with information on HFOs (and F-gases in general):

The Icelandic Recycling Fund
Terra Efnaeyding F-gas waste handling).
Umhverfis stofnun (The Environment Agency of Iceland)

17.4.4 Use of HFO Substances in Iceland

Very small amounts of pure HFOs are imported into Iceland; according to data from customs, it is only a few batches of a couple of kilos.

Umhverfis stofnun (2023)

HFOs are primarily imported in blends. The following blends containing HFOs have been identified in the import data since 2016:

R-448A 20% HFO-1234yf + 7% HFO-1234ze(E)
R-449A 25.3% HFO-1234yf
R-452A 30% HFO-1234yf
R-454C 78.5% HFO-1234yf
R-455A 75.5% HFO-1234yf
R-513A 56% HFO-1234yf
R-515B 91.1% HFO-1234ze(E)

The imported amounts of the different blends in kilograms can be seen in table 7, the amounts; the data from 2022 have not yet been confirmed.

	R-448A	R-449A	R-452A	R-454C	R-455A	R-513A	R-515B
2016		110
2017		110
2018		825	110
2019		3661	250
2020	358	6161	1178
2021		6298	440	20		193	120
2022		5555	286		30	22

Table 7

The general trend in choosing refrigerants is natural ones rather than newer synthetic ones, such as HFOs.

Umhverfis stofnun (2023)

The Auto sector

In connection with collecting data and information for the 2022 National inventory report, data obtained from the largest car importers in Iceland showed that all new vehicles they imported during 2019 used R-1234yf in their AC system. Since 2016 there has been a rapid increase in the proportion of passenger cars containing R-1234yf instead of R-134a. All vehicles imported from Europe are estimated to contain R-1234yf, and most cars imported into Iceland come from Europe. According to the Transport Authority, of all newly registered vehicles, only 3% were imported from outside Europe; individuals imported all these. Most of these cars were imported from North America, where R-134a still are in use.

Keller et al. (EAI), 2022

It is estimated that most pure HFOs imported into Iceland are to maintain MAC in passenger cars.

Umhverfis stofnun (2023)

RACHP

It is estimated that the amount of pure HFOs used in this sector is small, the food industry uses the HFC/HFO blend R449, but the amounts are small. There has been a significant shift in the fishing industry within the last 5–6 years. Several large refrigeration systems used in the fishing industry have been changed, and many new ones use ammonia or CO₂. Many fishing vessels use ammonia as well.

Iceland Recycling fund (2023)

However, in smaller fishing vessels, there are currently no natural refrigerant systems that are technically adequate, so there is a shift potential from HFCs to HFOs for this type of application.

Brynjarsson & Hilmarsson (2020)

Few heat pumps are used in Iceland, but it is a growing market.

Iceland Recycling fund (2023)

Foaming agents, Fire Protection and Aerosols

Identifying any use of HFO substances for these applications has not been possible.

Umhverfis stofnun (2023)

17.4.5 Existing Systems for Collection and End-of-life Treatments of HFOs

The Icelandic municipalities are responsible for F-gases while they are in use. The environment agency of Iceland (Umhverfis stofnun) is responsible for tracking the import and export of F-gases and enforcing legislation on waste treatment. There is no recycling, reclamation, or destruction of F-gases in Iceland. There is one incineration plant in Iceland, but it does not handle F-gases. Some companies and contractors working with refrigerants do basic recycling that allows immediate reuse.

Terra Efnaeyðing (2023)

Properly handled refrigerants are returned to authorised facilities in Iceland, Terra Efnaeyðing, for further deposition, and the Icelandic Recycling Fund repays a fee to companies after reporting how much is sent to recycling/destruction.

Poulsen et al (2022)

Only qualified personnel are allowed to handle refrigerants, and they need to be qualified according to § 7 in regulation 1066/2019 on fluorinated greenhouse gases. Again, HFOs are not covered by this legislation. Being a refrigerant technician in Iceland is not an isolated job description but is usually part of another job description, e.g., mechanic or electrician; the refrigeration industry would like this to change and make it an independent education.

Umhverfis stofnun (2023)

It has not been possible to determine the recovery rates of HFOs; it is generally estimated that some amounts of refrigerants are lost during waste management, in addition to what is lost during the use phase.

Iceland Recycling fund (2023)

Terra Efnaeyðing

Terra Efnaeyðing is the only waste company that handles F-gases at their facility located in Hafnarfjörður.

Brynjarsson & Hilmarsson (2020)

The f-gases are recovered and collected by servicing companies and handed over to a specialised company dealing with waste, such as Terra Efnaeyðing. Terra also collects from their customers, mainly companies and industry; they also gather from the municipal collection points. Terra has a local department in the North that collects before shipping to their facility in Hafnarfjörður.

Terra Efnaeyðing (2023)

All Collected F-gases are exported, and most are sent to Fortum in Denmark. There are documentation requirements for exporting refrigerants and fire extinguisher gas, and they require a permit.

The Auto sector

In the 2022 inventory report, the recovery of refrigerants from passenger cars was estimated to be 0.

Keller et al (2022)

However, this is illegal, and now car scrappers have begun to install the chambers necessary to recover refrigerants from the MAC systems during dismantling.

Umhverfis stofnun (2023b)

Terra does not receive any refrigerants from this sector.

Terra Efnaeyðing (2023)

This indicates no recovery or that recovered refrigerants are recycled locally.

RACHP

Refrigerants in large stationary equipment are filled onto gas cylinders when stationary equipment is decommissioned or emptied. Refrigerants in smaller equipment are recovered through vacuum chambers when the equipment is shredded, and then the refrigerant is shipped to Denmark. Almost all WEEE equipment is sent to Stena Recycling in Denmark or Sweden.

Foaming Agents and Aerosol Propellants

Foam-blowing agents from foams are likely not to be recovered; the foam will likely end up in landfills or be incinerated without any recovery of the foam-blowing agent.

Umhverfis stofnun (2023a)

The Icelandic Recycling Fund covers foams, so a processing fee must be paid. The responsibility for collecting the foam at decommissioning, e.g., when a building is dismantled, befalls those responsible for dismantling.

Iceland Recycling Fund (2023)

17.4.6 Strengths and Weaknesses

One significant barrier is that cylinders are not returned to importers when the refrigerant+ container is exported out of Iceland after decommissioning, meaning that the investment in the cylinder is lost when handed in at collection points.
There are currently very few collection points, and the distance to collection points is often identified as a barrier to handing in refrigerants; more locally located collection points and take-back centres will make it easier to return refrigerants for proper end-of-life treatment.
Equipment for proper decommissioning is expensive, and the cost for a small operator can be significant.
There is a need for education in alternative refrigerants.
According to the Icelandic Environment Agency, adequate control and certification have been lacking for many years²⁵. It is recommended that more resources are put into the general enforcement of end-of-life F-gas Regulation and treatment.

17.5 Norway

17.5.1 Country regulations with relevance

Legal (obligations, requirements, or prohibitions, including (but not limited to) acts, laws, regulations, and administrative or executive orders)

Norway is a party to the Montreal Protocol and has ratified the Kigali amendment, which went into force in 2019.

UNEP Ozone Secretariat (n.d)

Norway is not part of the EU, but Norway is a member of the European Economic Area (EEA). Norway adopted the EU F-gas Regulation, no 517/2014, in 2018, before that, the predominant F-gas Regulation in Norway was the EU F-gas Regulation no 842/2006, which was implemented into Norwegian legislation in 2010.

EEA Suppl. No 7 (2020)

Norway does not participate in the EU import regime for HFCs since it is not considered to be EEA-relevant.

Norwegian Ministry of Climate and Environment (2020-2021)

The EU WEEE directive is also implemented into Norwegian legislation, as is the EU MAC directive (Directive 2006/40/EC).

EEA Suppl. No 69 (2009) & EEA Suppl. No 18 (2018)

The Norwegian Environment Agency is responsible for enforcing the regulations on F-gases, except for the MAC directive that the Norwegian Public Roads Administration administers.

In accordance with the F-gas Regulation, you need a certification to work with F-gases. Isovator is the authorised certification body in Norway. They certify both companies and personnel. Isovator is also responsible for certifying operators working with vehicle AC.

Returgass (n.d.a)

Furthermore, Norway has implemented national regulations relevant to F-gases through the Norwegian Pollution Control Act

Forurensningsloven (1981)

and the Norwegian regulation on handling certain fluorinated greenhouse gases. Norway aims to be carbon neutral by 2030.

Norwegian Ministry of Climate and Environment (2020-2021)

According to Emissions Database for Global Atmospheric Research, EDGAR, the CO₂ emissions from Norway were 37,45 Mtonnes in 1990 and 42,33 Mtonnes in 2021.

Crippa et al (2022)

Due to the low global warming potential of HFO1234yf and HFO1234ze and according to EU F-gas Regulation (517/2014) Annex II, the gases are not subject to be reported unless the quantum is larger than 1000 tonnes of CO₂ equivalent.

Miljødirektoratet (2023)

Regulation (EU) 517/2014

Because of that, it has only been possible to quantify the imported bulks of HFO. In addition to bulk imports, HFOs are imported as part of blends or equipment, e.g., MAC systems. Obtaining an overview of imported HFO to the auto sector has not been possible.

Figure 8 Norway's bulk import of the two HFO substances, HFO-1234yf and HFO-1234ze, in Metric tonnes (Miljødirektoratet, 2023)

The primary objectives of the HFC regulation in Norway are to:

Minimise the environmental impact of HFCs, including their contribution to global warming.
Encourage the transition to alternative refrigerants with lower global warming potential (GWP) and improved energy efficiency.
Promote the adoption of sustainable technologies and practices in refrigeration, air conditioning, and foam insulation sectors.
Ensure proper handling, management, and disposal of HFCs to prevent their release into the atmosphere.
Establish quotas that gradually decrease over time to effectively control HFC production and import. Norwegian companies importing HFCs in bulk must obtain licenses from the Norwegian Environment Agency. These licenses come with reporting obligations, necessitating companies to provide detailed annual reports on their HFC imports.

Norway actively participates in international efforts to address the global impact of HFCs. The country aligns its regulatory framework with international agreements such as the Montreal Protocol and the Kigali Amendment, which aim to phase down the production and use of HFCs globally. Through these collaborations, Norway contributes to a unified approach to mitigate the environmental impacts of HFCs on a global scale.

The regulation of HFCs in Norway is critical to the country's commitment to environmental sustainability and combating climate change. Through comprehensive legislation, quotas, reporting obligations, financial incentives, and proper handling practices, Norway aims to minimise the use and impact of HFC. Due to the low CO₂ potential, HFO is not regulated by the Norwegian authorities.

Taxes and refund

In 2003 Norway implemented an excise duty on the production and import of HFCs, and in 2004 a refund scheme for the destruction of F-gases was introduced. The tax is refunded to the party delivering the waste to an approved collection point, ensuring proper end-of-life treatment. The tax is NOK 0.952 per kg (2023) multiplied by the GWP potential of the refrigerant.

Returgass (n.d.b)

The excise duty covers the import and production of the following:

Gas in bulk and import of all types of combination of HFC and PFC, both as known mixtures and in combination with other substances.
Products containing gas, for example, smaller air conditioning and refrigeration units, vehicle air conditioning units, expanding foam insulation and spray cans with HFC propellants.’
The Norwegian tax administration (n.d.)

The Norwegian Government plans to increase the taxes on HFCs as part of Norway’s 2021–2030 Climate Action Plan.

Norwegian Ministry of Climate and Environment (2021)

The objective is to create stronger financial incentives for individuals and businesses to opt for climate-friendly alternatives and ensure recovery and proper end-of-life treatment of refrigerants. The tax level is currently set at approximately NOK 590 per ton CO₂eq and is expected to be raised to around NOK 2,000 per ton CO₂eq by 2030; this will also result in a corresponding increase in tax refunds to the operator when handing in the refrigerant at a collection point. The Government considers this substantial increase essential to ensure Norway fulfils their commitment under the agreement with the EU to reduce emissions by 40% by 2030.

Norwegian Ministry of Climate and Environment (2021)

There are currently no taxes on HFOs, and if there were according to the existing method, the tax would be very low due to the low GWP of HFOs.

Penalties

The Norwegian Environment Agency is responsible for enforcing the regulations related to HFCs. Non-compliance with the regulatory requirements can lead to penalties, fines, or other legal consequences. The agency conducts inspections, monitors reported data and collaborates with stakeholders to ensure compliance and proper implementation of the regulations.

Miljødirektoratet (2023)

17.5.2 Use of HFO Substances in Norway

The largest consumers of HFOs are the automotive market, large-scale heat pumps for district heating e.g. in Oslo, refrigerant blends in smaller heat pumps, dryers, commercial and industrial refrigeration and blowing agents in various types of foams. Each industry has a different way of handling the end-of-life treatment of HFOs.

The Auto sector

Most newly registered cars in Norway use HFO-1234yf in their MAC system.

Miljødirektoratet (2023)

According to the MAC directive, mobile air conditioning (MAC) systems, including those in cars, are defined in terms of maximum allowable leakage rates. The specific leakage rates permitted depend on the type of the system. The systems must not contain gases with a GWP higher than 150. The leakage rate must not exceed 40 grams of refrigerant per year for one evaporator system and 60 grams per year for systems with dual evaporator systems.

EC (n.d.c)

Therefore, air conditioning systems in the car industry are known to have a continuous emission rate to the atmosphere. Service in the auto sector uses refrigerant recovery and filling machines to recover HFO from the air conditioning systems. The filling machines usually measure the refrigerant retracted from the systems, reuse the HFO and add the amount that the A/C system has lost during the service interval. Because of refrigerants' reuse and the systems' leaks, only a small amount is recovered from the auto sector and send for destruction. Refrigerants from scraped cars are often sold for reuse. The individual A/C systems in cars typically contain 400–1000 grams of HFO.

Returgass (2023) & Christonik ApS (2023)

Due to the large number of A/C systems, the Auto sector is a major source of emissions.

NRF (2020)

Some car brands and models sold in the European market use the natural refrigerant R744 (carbon dioxide). R744 operates at a much higher pressure and partly with lower energy efficiency. Therefore, the transition to R744 is expected to have long prospects, and HFO1234yf will be the primary refrigerant in the auto sector. Collection and recycling sites for end-of-life treatment of vehicles need permits from the Norwegian County governors.

Asphjell et al (2023)

RACHP

In Norway, there is a growing trend to use natural refrigerants and HFO refrigerants in cooling systems and heat pumps. This shift is driven by the desire to reduce the environmental impact of traditional synthetic refrigerants and move towards more sustainable and climate-friendly alternatives.

Natural refrigerants, such as carbon dioxide (CO2), ammonia (NH3), and hydrocarbons (HCs) like propane (R290) and isobutane (R600a), have gained significant attention due to their excellent environmental properties. These substances have no ozone depletion potential (ODP) and no or very low global warming potentials (GWPs), making them an attractive alternative to fluorinated refrigerants. This includes HFOs, which have negative effects related to PFAS and TFA. Natural refrigerants are increasingly utilised in various cooling systems and heat pumps in Norway. Carbon dioxide is commonly used in commercial refrigeration systems due to its low environmental impact. It has become popular for supermarkets, cold storage facilities, and industrial refrigeration. Ammonia is another natural refrigerant widely used in larger industrial cooling and heat pump systems. Its excellent thermodynamic properties make it highly efficient for large-scale refrigeration and air conditioning applications. In addition to systems with natural refrigerants, cooling systems and heat pumps using HFOs are also being introduced in Norway. HFOs, such as HFO-1234yf and HFO-1234ze, have significantly lower GWPs than traditional hydrofluorocarbons (HFCs). Although HFOs are synthetic refrigerants, their lower GWPs contribute to reducing greenhouse gas emissions and addressing climate change concerns. Commercial and industrial systems typically contain large amounts of refrigerant. Due to the safety aspects, such as toxicity and flammability when working with ammonia, there is a tendency to use HFO refrigerants in newer plants. Some newer heat pumps for district heating use HFO1234ze. There are no restrictions on how large fillings the plants can have, and it is not unusual that the filling is several tonnes.

VKE (2023)

Using natural refrigerants and HFOs in cooling systems and heat pumps aligns with Norway's sustainability and environmental protection commitment. In collaboration with industry stakeholders, the Norwegian government promotes adopting these alternatives to synthetic refrigerants with higher GWPs. In Norway, there are some apprehensions of using HFO due to PFAS concerns.

Proper training and certification of technicians and professionals are essential to ensure the safe and efficient use of natural refrigerants and HFOs. Regulations and standards govern these substances' installation, maintenance, and disposal, protecting human health and the environment. It has not been possible to determine whether HFO is exempt from the education requirements.

Stena Recycling and Revac handle WEEE in Norway. Stena Recycling exports its waste to Stena Recycling’s facility in Sweden, where the refrigerants and the foam-blowing agents are recovered and destroyed. Revac has up to 2022 delivered recovered refrigerants to the Norwegian Foundation for Refrigerant Recovery (SRG), while foam-blowing agents are sent to Germany for destruction.

Asphjell et al (2023)

From 2023 Revac also sends recovered refrigerants to Germany for destruction.

Miljødirektoratet (2023)

Foam-blowing Agents

HFOs are introduced as foam-blowing agents in some applications across the EU and Norway. It has not been possible to gather any data on quantities.

Asphjell et al (2023)

17.5.3 Existing Systems for Collection and End-of-life Treatments of HFOs

Stiftelsen Returgass (SRG) is a nationwide company

Returgass (n.d.d)

that collects and handles used refrigerants in Norway. SRG has developed a system with collection points (Grønt Returpunkt (GRP)) where service tanks are handed in after recovery for proper disposal. After collection, the refrigerant is analysed to determine quantity and content, and the party who delivers the refrigerant will receive a tax refund based on the analysis. Before payment, the waste handling costs are subtracted from the amount. The size of the payment is based on the refrigerant’s GWP-value. If the refrigerant type is not subject to a tax, which is the case for HFOs, then there is no payment and the associated costs for proper end-of-life treatment are charged to the customer. See the flowchart below.

Figure 9 The handling of used refrigerants at Isovator/ReturGass (Returgass (n.d.a)

SRG sometimes refer to flammable HFCs, and they have made a separate procedure description for handling them safely. SRG is monitoring the collection and quantities of refrigerants, and as shown in the bar chart, it is evident that HFO so far plays a minor role in the return system. This is likely because HFOs do not yet constitute a significant market share and while stationary products like heat pump and refrigeration plants haven’t been decommissioned. Another factor is that submitting HFO to the return system is associated with costs for the customer.

Returgass, & Miljødirektoratet (2023)

SRG has so far registered three types of HFOs:

HFO-1234yf, HFO1234ze and HFO-1233zd
Returgass (2023)

The sources are not known precisely, but it is presumably refrigerant mixtures from heat pumps, dryers, the auto sector, and refrigeration systems.

None of the refrigerants delivered to SRG are recycled or reclaimed. All collected refrigerants are sent to France for destruction.

Asphjell et al (2023)

Figure 10 In 2020, SRG received the following amounts of refrigerant gases, halon, SF6, oil and glycol measured in kg (Returgass (n.d.c)

Pricing of refrigerants

The price of refrigerants at the wholesaler depends on the F-gas tax and the product's price. It is possible to get a tax refund when the refrigerants are sent to processing at SRG. There are no taxes on HFOs and, therefore, no refund. Figure 11 (below) shows a graphical price example of HFO and HFC. The tax level is currently set at approximately NOK 590 per ton CO₂eq and is expected to be raised to around NOK 2,000 per ton CO₂eq by 2030.

Norwegian Ministry of Climate and Environment (n.d.)

Figure 11

Current end-of-life treatment options

The collecting system for HFC gasses in Norway is very efficient and has a high collection rate. HFO gasses are mainly unregulated due to their low GWP and the lack of environmental taxation, and they have not been completely implemented in the regulatory system yet.

17.6 Sweden

17.6.1 Country regulations with relevance

Legal (obligations, requirements, or prohibitions, including (but not limited to) acts, laws, regulations, and administrative or executive orders)

Overall, the primary legislation regarding F-gases in Sweden is Regulation (EU) No. 517/2014

Regulation (EU) No. 517/2014

and Regulation (SE) No 2016:1128.

SFS 2016:1128

The WEEE directive is also of relevance.

Directive (EU) 2012/19

Naturvårdsverket is the competent authority on F-gases in Sweden. Sweden had national legislation in place for controlling refrigerants before joining the European Union. The first Refrigerants Order was issued in 1988, controlling CFCs, HCFCs and later HFCs were added. Refrigeration Foundation in consultation with the Swedish Environmental Protection Agency developed Swedish Refrigeration Code of Best Practice (Svenska Kylnorm) and supplementary Fact Sheets were linked to the Refrigerants Order. The Code of Best practice is updated and still effective,

Naturvårdsverket (2022)

The Swedish regulation 2016:1128 is a complement to the EU regulation 517/2014 and is stricter primarily because it includes mobile equipment in the certificates and leakage control requirements and generally has a few additional reporting requirements. Furthermore, the Swedish legislation (2016:1128, § 12) mandates that those who supply F-gases must take these back and provide containers for this purpose, free of charge.

SFS 2016:1128

There is no refund scheme for taking back F-gases in Sweden.

Poulsen (2022)

Like the legislation in the other Nordic countries, Swedish legislation mandates that equipment and appliances (mobile and stationary) containing HFCs are journaled. According to paragraph 15 in the Swedish legislation an operator must if:

…there are at least 14 tonnes of carbon dioxide equivalents in a stationary facility, in a facility on a ship or in mobile equipment that is subject to leakage control according to § 11 or according to Article 3.3 second paragraph and 4.1-4.3 of the EU regulation on f-gases.

report at the latest 31 March every year to the supervisory authority the following:

“The report must contain

the results of the leak checks carried out during the calendar year,
information on equipment scrapped during the calendar year,
the information specified in Article 6.1 of the regulation on f-gases,
the operator's organisation number, postal address, and billing address,
address and property designation of the property where the equipment is located, if the equipment is stationary,
a list of the equipment, and
in the case of equipment on a ship, the ship's name, signal letters or the like.”

This means that on top of the details required by EU regulation 517/2014 (like quantities and type of F-gas), information on a facility containing the equipment, with organisation, location, etc., must also be journaled if the collective amount contained in equipment equals or is greater than 14 tons CO₂e. Furthermore, the undertaker is required to submit these records to the supervisory authority in Sweden. In case less than 14 tons of CO2e are present in the facility but more than 5 tons of CO₂e in a single piece of equipment, only the details stipulated in the EU regulation 517/2014 must be journaled and kept for at least five years.

Svenska kyl- og varmepumpforeningen (2023)

Regulation 2016:1128 uses the same F-gas definition as in (EU) no. 517/2014. HFOs are, therefore, not covered by the regulation. However, the regulation states that if a system that contains 14 tons CO₂eq or more is to be converted to another refrigerant than HFC, it needs to be reported to the authorities.

SFS 2016:1128

Penalties

The penalties with relevance for end-of-life treatment of F-gases especially concern documentation and correct recycling/reclamation/destruction. The actors with supervisory responsibility can, in general, impose environmental penalty fees:

"Whoever has supervisory responsibility according to the Environmental Supervision Ordinance (2011:13) can impose environmental penalty fees. There is currently no supervisory responsibility for f-gases in mobile equipment other than motor vehicles, aircraft or trains."

More specifically, the penalties identified of relevance are listed below according to different regulations and fees, etc:

Naturvårdsverket (n.d.)

Delayed report to the EU registers in case of production, import, export or destruction, or late review by an auditor.	EU 517/2014 Art 19.1-19.5, 19.6	Environmental sanction fee MSA regulation ch. 9 § 7
Recycling has not been carried out by certified or trained personnel.	EU 517/2014 article 8.1 or 8.3	Indictment MB 29 ch. 3 § item 7
MSA Ordinance = Ordinance (2012:259) on Environmental Sanction Fees, the Ordinance has been updated for the new f-gas Ordinances 2017 under Ordinances 2016:1130 and 2016:1305 MB = Environmental Code, regulation (1998:808)

Table 8

The Requirements under Article 8 in (EU) no 517/2014 do not extend to Annex II gases.

Fiscal Subsidies

A fee for F-gases (and other chemicals listed in Swedish legislation) must be paid annually:
§ 5 of Swedish Ordinance 1998:940 stipulates that:

“The chemical fee must be paid annually for the calendar year and must consist of

a registration fee of SEK 600 for each product or organism subject to notification, but no more than SEK 70,000 per year, and
a quantity fee of SEK 12 per ton of products and organisms subject to notification, but no more than SEK 70,000 per year.”

However, HFOs are not listed in SFS 2008:245 and are not subject to a fee.

Soft regulatory instruments (recommendations, technical standards, voluntary bottom-up initiatives (self-regulation), legislation-induced co-regulatory actions)

No special soft regulation from authorities in Sweden has been identified. There are some examples of industry initiatives trying to create circular business models for the use of F-gases. The Finnish reclamation company Eco Scandic work on promoting the recycling and reclamation of F-gases throughout EU.

Eco Scandic (2023)

Eco Scandic is based in Finland and collects F-gases (from designated collection points) for end-of-life treatment from Sweden and Finland. Eco Scandic sees great potential in reclaiming and using reclaimed F-gases to close the loop around the EU F-gas market. Another initiative is creating an alternative (turnkey) business model for F-gases. Instead of users/operators of F-gases sending them to reclamation or destruction during their end-of-life and then buying back either reclaimed or virgin F-gases, they suggest a leasing model. You can lease F-gases from Eco Scandic, which then maintains them and makes sure the operators have what F-gas they need during their contract. This model is still new and in its early phases.

Monitoring

In accordance with Article 19, any undertaking that has destroyed at least 1 metric tonne of F-gases is obliged to report to the Commission by 31 March each year, Sweden does not have a national database for collecting these data. According to the NIR modelling, all F-gases are assumed destroyed, which is not what happens in practice, as at least some F-gases are being reclaimed and reused.

Eco Scandic (2023)

Currently, the limit for monitoring is at 5 kg CO₂e pr. System. The Swedish Refrigeration and Heat Pump Association have concretely recommended setting the value at 3 kg CO₂e instead to ensure proper monitoring of HFOs.

Svenska Kyl- & varmepumpforeningen (2023)

As stated earlier, HFOs often slip through the regulation today, mainly because the CO₂e of HFOs is so low.

17.6.2 Use of HFO Substances in Sweden

According to the latest data reported to the EU, the following number of Swedish companies reported activities in the field of F-gas refrigerants. This includes all types of F-gases and not just HFO; a company can report on more than one activity:

Ludig et al (2022)

Importers	12
Exporters	3
Equipment importers	26
Destruction companies	1
Quota authorisers	3

Import and Export of HFOs

HFO-1234yf, HFO-1234ze and HFO-1336mzz have CN code 2903 51 00. The following quantities were reported imported and exported in 2022:

SCB (2023)

CN code	Import of goods, adjusted for non-response, Metric ton	export of goods, adjusted for non-response, Metric ton
290351	454	38

Table 9

The Auto sector

Around 2012, HFO-1234yf was introduced into Sweden’s MAC sector in passenger cars due to the EU MAC directive.

Gustafsson (2011)

An agreement was made between Svenska miljöemissions data (SMED) and Kemikalieinspektionen (KemI) to have the MAC sector journal and report on the stock of HFO-1234yf. Data shows that HFOs have quickly risen since their introduction in Sweden.

Naturvårdsverket (2023)

In 2015, 26,8 tonnes of the HFO 1234yf was imported; in 2016, it was 82,3 tonnes.

KEMI (n.d.)

The majority of HFO-1234yf imported is expected to be used for MAC. A recent paper reveals that in 2018, there was estimated to be 145,4 tonnes of (total) HFO in the MAC sector, and in 2019 this was at 314,5 tonnes.

Poulsen (2022)

An informant reports that most HFOs received for end-of-life treatment are HFO-1234yf from the MAC sector, whereas the rest are of insignificant quantities.

EcoScandic Oy (2023)

RACHP

Most larger refrigeration systems in Sweden already use natural refrigerants, which requires entirely different systems than those using F-gases.

Svenska kyl- & värmepumpforeningen (2023)

HFO-1234ze appears to be the HFO refrigerant of choice for these types of applications, if used.

Eco Scandic (2023)

Heat pumps: According to the Swedish Refrigeration & Heat Pump Association (kyl & värmepumpforeningen), the demand for heat pumps is rapidly increasing in Sweden. It is uncertain how many new heat pumps use HFOs or HFO/HFC blends. The Swedish Refrigeration & Heat Pump Association sent out a questionnaire asking their members about how they perceive the increase in demand, as well as what type of refrigerant is used in the heat pumps they install, but HFOs were not a possible response option in the questionnaire.
Svenska kyl- & värmepumpforeningen (2022)

Foaming Agents, Fire Protection and Aerosols

According to the latest Swedish national inventory report, an increasing proportion of XPS foams use other blowing agents than HFCs, such as CO₂and HFOs. However, there is not any available data on the proportions.

Naturvårdsverket (2022)

HFO-1234ze is known to be a suitable aerosol propellant, but it is probably only in insignificant quantities so far. An expert estimate that HFOs will be used much more in the future.

Eco Scandic (2023)

17.6.3 Existing Systems for Collection and End-of-life Treatments of HFOs

According to a spokesperson for practitioners, HFCs and HFOs are treated the same in practice, even though there are no legal requirements for handling and monitoring HFOs. The technical barriers for HFOs are generally the same as for HFC’s existing barriers.

Svenska Kyl- og Varmepumpforeningen & Eco Scandic (2023)

Furthermore, HFOs, as listed in EU regulation 517/2014 Annex II, have not yet been discussed in detail in the Swedish Environmental Agency.

Naturvårdsverket (2023)

Therefore, it is still uncertain how exactly HFOs should optimally be treated for end-of-life treatment.

From what can be derived from accessible reports (mainly NIR), it points to the fact that take-back systems for F-gases in Sweden generally are very effective. Combined with the fact that HFOs are largely treated the same way as HFCs, this means good opportunities exist for fitting HFOs into the existing end-of-life treatment system. However, more research into the actual practice is recommended as more and new types of HFOs are being recovered for end-of-life treatment, and following new regulations is being mandated.

Recycling

The four main recyclers operating in Sweden, according to The Swedish Refrigeration and Heat Pump Association, are:

Ahlsell
Kylma
Dahl
Eco Scandic

Several professional collectors buy recovered refrigerants, recycle them, and sell them back to operating companies. Many practitioners working with F-gases reuse and recycle the F-gases themselves.

Svenska kyl- og varmepumpforeningen (2023)

Foam blowing agents

Regarding F-gases in foam, insulation foam is processed at certain waste treatment facilities, and the F-gas is collected.

Poulsen (2022)

Reclaiming these F-gases from the foam is not economically viable, therefore almost all of this is sent to destruction.

Eco Scandic (2023)

According to EcoScandic at end-of-life, the foam is shredded in a vacuum-sealed chamber, where the gases are collected (at a WEEE plant) and typically sent to incineratio). Only one plant in the Nordics is actively restructuring its current operations to recover and sort HFCs (which will be able to recover HFOs as well).

WEEE

In practice, “WEEE” facilities receive equipment containing F-gases at end-of-life. Here, the F-gases are removed from the equipment and collected for further treatment, often for destruction.

Poulsen (2022)

The F-gases that need simple recycling are typically treated in a facility in Sweden, while those that need more complex recycling are exported (typically to Finland).

Svenska kyl- og varmepumpforeningen & Eco Scandic (2023)

Again, the current procedure for end-of-life treatment of HFOs is the same as for HFCs so that the facilities can handle HFOs in the same way that HFCs are handled.

Svenska kyl- og varmepumpforeningen, Eco Scandic & Fortum Waste (202

Reclamation

Eco Scandic is one of the few end-of-life treatment companies that are doing full reclamation throughout all the Nordic countries. They received a total of 67 tons of F-gas for reclamation in 2022. Of these, less than 2% were HFOs (1.34 tonnes), mainly composed of HFO-1234yf and HFO-1234ze. This is partly due to the relative novelty of HFOs in HVAC-R equipment since the average lifetime for these appliances is approximately at least 5-7 years. Eco Scandic has a waste fee in Sweden and Finland of at least 4,5€/kg, as stipulated on their website. However, waste fees can range from 18€/kg, depending on the service provider. Eco Scandic has agreements with several wholesalers, providing reclamation of their recovered F-gases and then selling them back to the wholesaler. According to Eco Scandic Oy, the take-back models vary sporadically in the different sectors. Eco Scandic typically create a specific take-back model in collaboration with the specific stakeholder. Eco Scandic reclaims HFC/HFO blends and pure HFCs and HFOs. Eco Scandic sends unreclaimable F-gases are sent to Fortum for destruction. The approach varies slightly when it is an A2L-classified refrigerant rather than a non-flammable refrigerant, Eco Scandic Oy processes both types.

Eco Scandic (2023)

Destruction

Fortum is the only destruction company in Sweden that destroys recovered refrigerants; Fortum also imports recovered refrigerants from other countries for destruction in Sweden. Fortum also receives F-gases from waste companies that collect waste from different industries, from recyclers of products containing F-gases, from companies that service equipment containing refrigerants and from retailers of refrigerants. For destruction (as opposed to recycling/reclaiming), the technical barrier mostly consists of capacity limitations.

Fortum Waste (2023)

Regulations are limiting the levels of how much fluoride that can be emitted during the incineration process. During the “washing/scrubbing” process, which is part of the destruction of F-gases, restrictions exist on how much fluoride you can run through the system and emit. There is a limit to how fast you can decrease the fluoride levels in the gas; therefore, this is the immediate and general barrier and limiting factor for the destruction of F-gases. Fortum incinerates multiple fluorinated substances, not just F-gases. There are no technical differences in the way of handling HFCs and HFOs. Whereas there is a difference between HFCs/HFOs and other fluorinated substances such as SF6 and PFC. Fortum also receives F-gases used as aerosol propellants.

Fortum Waste (2023)

Fortum registers whom they receive F-gases from, allowing them to get information on sector uses etc.

17.7 Germany

17.7.1 Country regulations with relevance

The legislation with relevance for F-gases in Germany is based on EU legislation. The current German Chemicals Climate Protection Ordinance (Chemikalien-Klimaschutzverordnung) is based on the EU F-gas Regulation and uses the same definitions.

The EU Waste Framework Directive (2008/98/EC) is enacted in Germany by the Waste Management Act (Kreislaufwirtschaftsgesetz - KrWG). The German federal states (Bundesländer) are responsible for any waste management scheme. All waste treatment bodies must be authorised and be permitted to treat any waste with the respective waste code number.

Umweltbundesamt (2023)

HFOs are considered hazardous waste, and the waste code number must be identified with the regional waste management company; one possible code is 140601* CFC, HCFC, HFC.

The End-of-life Vehicle Act transposes Directive 2000/53/EC into national law, and the German Electrical and Electronic Equipment Act (ElektroG) transposes the EU WEEE Directive into national law. The regulation has been amended twice, in 2015 (ElektroG2) and in 2022, when the German Electrical and Electronic Equipment Act (ElektroG3) and the Ordinance on Requirements for the Treatment of Waste Electrical and Electronic Equipment came into force. Part of the scope is to expand the network for return points to increase the collection rate of WEEE.

Ecosistant (2022)

Manufacturers are required to register with the foundation ‘Stiftung Elektro-Altgeräte Register’ (stiftung ear) as well as make a monetary contribution to WEEE collection, treatment, and recycling.

Ear (n.d.a)

Soft regulatory instruments

There are some funding programmes for new RACHP equipment where HFCs and HFOs are excluded or funded less to promote the use of natural refrigerants.

Associations provide standards for how to deal with refrigerants after decommissioning, for instance, in schooling materials for the climate service in vehicles or guidelines of service employers’ liability insurance associations. The German Environment Agency (UBA) strongly supports using non-halogenated substances (natural refrigerants) whenever it is technically feasible and has done so since the 1990s.

Umweltbundesamt (2023)

17.7.2 Use of HFO Substances in Germany

According to the latest data reported to the EU, the following number of German companies reported activities in the field of F-gas refrigerants. This includes all types of F-gases and not just HFO; a company can report on more than one activity:

Ludig et al (2022)

Producers	3
Importers	50
Exporters	18
Equipment importers	114
Destruction companies	7
Feedstock users	1
Quota authorisers	11

Data from 2021 on the amounts of HFO-1234yf and HFO-1234ze and the type of application where they are deployed:

	Amount (part of blends included) in applications	2021 (metric tons)
1233zd	2 F 1 f, Stationary Air-Conditioning	21.3
1234yf	2 F 1 a, Commercial Refrigeration	301.7
	2 F 1 d, Transport Refrigeration	58.0
	2 F 1 e, Mobile Air-Conditioning	9611,6
	2 F 1 f, Stationary Air-Conditioning	160.3
1234ze	2 F 1 a, Commercial Refrigeration	27.6
1234ze	2 F 1 f, Stationary Air-Conditioning	710.2

Table 10 Amount of HFO-1234yf and HFO-1234ze in metric tons and the types of applications where it is in use, From Umwelt Bundesamt (2023)

The auto sector

HFO-1234yf is used in the MAC system in almost all new vehicles (cars).

The RACHP sector

In commercial refrigeration, pure HFO-1234ze is used in condensing units as well as several HFO blends in central systems (R-448A, R-449A), condensing units (R-449A, R-452A, R-454C, R-455A, R-513A) and plug-in appliances (R-454C, R-455A).

In vehicle refrigeration, there are current attempts to use pure HFOs in small refrigeration systems. Besides, some HFO blends are used increasingly, e.g., R-452A in all size classes of refrigerated vehicles and reefer containers and the blend R-513A only in reefer containers.

In larger industrial refrigeration and stationary air conditioning, numerous refrigerants are used. In centrifugal chillers, it is mainly HFO-1234ze(E) and, to a minor extent, R-1233zd(E). Other chiller types, such as chillers with reciprocating or screw compressors, use R-1234ze(E) and other refrigerants. The blends R-454B, R-513A, and R-515B are also in centrifugal and other chillers.

In domestic heat pumps, HFOs are not used pure, only in blends. The following blends are used for heat pumps: R-450A, R-448A, R-449A, R-452B, R-454B, R-454C, R-513A, and R-515B.

Foaming agents:

Building and Construction: HFO-1234ze is used for XPS foam, and HFO-1336mzz(Z) for PUR foams.
Foaming agents in products: Identifying any use of HFOs in this sector has not been possible.

Aerosol Propellants:

HFO-1234ze is used in aerosols. A blend of R-1234ze(E) and R-134a is used in rare cases, for instance, for electric cooling spray and filling of pressure cushions in heating and tank technology.

Umwelt Bundesamt (2023)

17.7.3 Existing Systems for Collection and End-of-life Treatments of HFOs

Take-back facilities depend on the specific refrigerant and the type of systems, but it is often done via gas trades or waste management companies. Germany implemented a legally binding take-back scheme in 2009. Section 4 of the German Federal Chemicals Climate Protection Ordinance states that producers and distributors must take back HFC refrigerants after they have been recovered.

Chemikalien-Klimaschutzverordnung (2008)

Distributors and producers can charge contractors a fee when they hand in HFC refrigerants, and this has been identified as a limiting factor for the scheme since it discourages some from delivering recovered refrigerants since it is associated with a cost.

EIA (2016)

End-of-life Vehicles

In Germany, car producers have individual contracts with facilities handling collection and dismantling. Both car producers and importers must take back their own vehicle brand at an authorised facility designated by the car producer; the car owner is obliged to bring the car to the authorised, permitted facility and will be given the certificate of destruction after handing it in. Collection and dismantling facilities are organised in loose networks, but negotiations happen between the individual car producer or importer and the individual facility.

Monier et al (2014)

There are over a thousand authorised dismantling facilities and dozens of authorised shredding facilities in Germany to ensure the disposal of ELVs.

Zimmerman et al (2022)

WEEE

The German Electrical and Electronic Equipment Act enforces that anyone who places electrical or electronic equipment on the market is responsible for its recycling. Since 2005, Germany has had a producer-led government-regulated system.

The take-back concept differs depending on whether the equipment is business-to-consumer (b2c) or business-to-business (b2b). Since 2022, producers of b2b equipment are obligated to create a reasonable system for returning WEEE; this cannot be passed on to the customer. The customer can be imposed with the financial obligation of disposing of WEEE, but the producer has to set up the system and submit the take-back concept to EAR.

Ear (n.d.b)

For b2c equipment, the public waste disposal authorities have set up collection sites where WEEE from private households can be delivered. When the containers at the collection sites are full, it is reported to the EAR that notifies the producer or authorised representative, who must pick up and replace the container with an empty one.

Ear (n.d.c)

The producers are responsible for financing the provision and pick-up of containers.

Reclamation & Destruction

Several destruction and reclamation facilities in Germany handle F-gases, including HFOs. However, there are currently no data on the amounts of HFOs recovered.
There is no regular waste export of F-gases out of Germany.

Barriers

There is a shortage of pressure vessels that, combined with the many different types of refrigerants on the market, lead to small amounts and mixing of refrigerants, which makes recovery difficult.

Umweltbundesamt (2023)

17.7.4 Monitoring systems

The use of HFOs must be reported as part of the Environmental Statistics Act (Umweltstatistikgesetz) to the Federal Statistical Office (Statistisches Bundesamt, destatis.de).

Umweltbundesamt (2023)

17.7.5 Other

The uncertainty of the effects of breakdown products from F-gases that end up in the environment is of great concern, partly due to their persistence in the environment and their impact on the environment and human health. Germany has carried out a country-wide measurement programme to determine the quantities of TFA (trifluoroacetate) in precipitation, which is a breakdown product of HFCs and HFOs. TFA is a very mobile substance, and it ends up via precipitation in the water bodies. There are no currently known environmental conditions in which TFA degrades. In drinking water production, no practicable and economical method exists for its removal.

Umweltbundesamt (2021)

TFA is very stable (several decades) and will, therefore, accumulate over time.

Behringer et al (2021)

17.8 Switzerland

17.8.1 Country regulations with relevance

Switzerland has ratified the Montreal Protocol and all subsequent amendments. HFOs are not regulated in Switzerland only if they are contained in blends with other F-gases. F-gases are regulated under the Chemical Risk Reduction Ordinance (ORRChem).

Annex 1.5 ORRChem includes regulation for the import, export, and general use of F-gases.
Annex 2.3 covers the use of solvents.
Annex 2.9 covers the use of foams.
Annex 2.10 covers the use of refrigerants.
Annex 2.11 covers the use of extinguishing agents.
Annex 2.12 covers the use of aerosols.

HCFOs, however, are regulated under Annex 1.4: Substances that deplete the ozone layer, and the abovementioned annexes since HCFOs are classified as ozone-depleting substances. F-gases are considered special waste under the Ordinance on Lists for the Transport of Waste (waste code 14 06 01) and must be disposed of accordingly.

It is stated in ORRCHEM that “Any person who receives appliance or systems containing refrigerants for disposal must remove the refrigerants contained and dispose of them separately and appropriately”.

The manufacture, installation, maintenance or disposal of refrigeration, air conditioning or heat recovery appliances or systems requires a License. Licenses from EU and EFTA member states are considered equivalent to the Swiss one.

ORRChem (2005)

The Basel Convention and OECD agreement regulates the export of waste. It is implemented into the Swiss Ordinance on the Movement of Waste. Switzerland only exports waste to other countries in Europe, mainly to Germany. Switzerland does not have a quota system like in the EU. Import permits are granted for all HFCs for applications with authorised use.

BAFU (2023)

Switzerland has not adopted the EU WEEE directive. Switzerland has adopted The Ordinance on the Return, Take-back and Disposal of Electrical and Electronic Equipment (ORDEE), which requires Producer responsibility for the take-back of electrical and electronic equipment. The Ordinance came into force in 1998.

BAFU (n.d.1)

Soft regulatory instruments

There is an officially communicated preference for natural refrigerants and general encouragement of the industry, partly due to possible future regulations on HFOs in Europe.
Numerous funding opportunities exist in Switzerland (+200) for low GWP alternatives. However, there exist several challenges:
- The funding application schemes are considered to be complicated.
- Another barrier is that some outdated rules and regulations concerning flammability still exist that hinder new technical systems that deploy natural refrigerants.
  Schecho AG (2023)

17.8.2 Use of HFO Substances in Switzerland

HFOs are used across all the below-mentioned sectors, and the shift to low GWP refrigerants, including HFOs, is considered important for reaching the Swiss climate target.

Schecho AG (2023)

The auto sector

As in the EU, HFC-134a has not been allowed as a refrigerant in new vehicles' AC equipment since 2017. In new vehicles, HFO-1234yf is considered the state of the technology.

BAFU (2023)

RACHP sector

HFOs are specially used in larger RACHP types of equipment or systems. In Switzerland, it is not allowed to use HFCs in RACHP systems of more than 400 kW, and HFOs are primarily used instead.

BAFU (2023)

Domestic heat pumps mainly use HFC or HFC/HFO blends. The use of hydrocarbons in heat pumps is increasing.

BAFU (2023)

Foaming agents

HFOs are used as a replacement for HFCs as a foaming agent in building and construction foams and foam products.

Aerosol propellants

HFOs are in use as an aerosol propellant as a replacement for HFCs.

17.8.3 Existing Systems for Collection and End-of-life Treatments of HFOs

Recovery, collection and end-of-life treatment of refrigerants

Only private companies with an environmental permit can recycle and do reclamation. 9 waste treatment facilities are authorised to handle waste under code 14 06 01 or dispose of it. Some companies are also authorised to reclaim F-gases.

BAFU (n.d.2)

Recovering and delivering F-gases back to the company for further treatment is obligatory. You pay a fee to cover recovery and recycling costs when buying equipment. Both private consumers and companies are required to pay. After handing in the recovered refrigerant, the contractor receives documentation for the delivery.

Schecho AG (2023)

WEEE

The Swiss authorities have approved three collective compliance Schemes for WEEE; the SENS scheme deals with disused electrical and electronic appliances. Manufacturers, retailers, importers and collection points must create a take-back system and take back appliances from their product range free of charge. Consumers must hand in their WEEE at the retailer, manufacturer, importer, collection point or specialised recycling facility and not discard it as household waste. The scheme is financed by an advance recycling contribution (ARC). This financing scheme was introduced based on the ORDEE implemented in 1998, see section 1.1.1.

Sens eRecycling (n.d)

End-of-life vehicles

The disposal of end-of-life vehicles in Switzerland is based on the polluter-pays principle. The Swiss Auto Recycling Foundation was founded in 1992 and put an advance disposal fee on new vehicles at importation. Waste disposal companies that accept end-of-life vehicles need a permit from their local canton.

BAFU (n.d.3)

Data on waste elimination in Switzerland

Waste under the code 14 06 01 in the European Waste Catalogue includes CFCs, HCFCs, HFCs and HFOs and blends, so the numbers below are a total for category.

BAFU (2023)

The quantity of pure HFOs is unknown.

	2020	2021
Export for recycling and reclamation (tonnes)	93	89
Export for incineration (tonnes)	12	0
Domestic Incineration (tonnes)	43	81
Domestic recycling (tonnes)	11	5
Import of waste (tonnes)	0	0

Table 11 Waste statistics for waster under code 14 06 01*, data from BAFU, available at: https://www.bafu.admin.ch/bafu/en/home/topics/waste/state/data.html

17.8.4 Monitoring systems

There are numerous reporting requirements in Switzerland, including:

Import and Export of HFCs
Commissioning and decommissioning of stationary equipment with more than 3 kg of refrigerant, no matter the kind of refrigerant.
Keeping a maintenance log for equipment or systems containing more than 3 kg of refrigerant.
BAFU (Hrsg) (2022)

17.8.5 Other

Switzerland is aware of the potential environmental risks of TFA, a degradation product of some HFOs. FOEN has commissioned an ongoing study investigating the contribution of different emission sources. The study findings shall help evaluate possible future regulation.
BAFU (2023)
Some practitioners experience a lack of transparency and coherence between the different cantons (member states) in Switzerland. The different cantons can have different rules or interpret national regulations differently. This means that if you apply for an, e.g., plant building permit in one canton and get permission and then apply for the same in another region, you might not get permission there.
Schecho AG (2023)
There is a decreasing interest in the education to become a refrigeration technician.
Schecho AG (2023)