Regulations to reduce fluorocarbon leaks from refrigeration and air conditioning systems have been tightening for years but are now biting with new vigour. Developers should now look to review building designs to take account of new HVAC requirements, performance differences and costlier insulation materials.

The entire refrigerant lifecycle is now regulated, from production through to safe disposal and recycling. There are significant retraining responsibilities for engineers and mandatory inspection schedules for building operators. Regulations also compel developers, HVAC manufacturers, importers and wholesalers, installers, engineers and building operators to document their compliance.

In this article, I want to take a close look at the new aircon regs and how they will affect new commercial development in Bristol.

Update on F-Gas Regulation and Refrigerants

New F-Gas regulations reflect binding international commitments and will be largely unaffected by Brexit. They concern all users of fluorinated “greenhouse gases”, including HFCs (hydrofluorocarbons), PFCs (perfluorocarbons) and sulphur hexafluoride (SF6).

Everyone manufacturing, importing, exporting, reselling, operating or servicing equipment containing F gases (notably HVAC and refrigeration systems) has new obligations. EN 378, the safety standard for air-conditioning equipment, has been updated to reflect the new requirements.

Fluorinated gases replaced ozone-damaging CFCs in the 1980s, but these substitute refrigerants and propellants have global warming effects up to 23,000 times that of carbon dioxide, weight for weight. Ironically, CO2 is now considered a leading environmentally friendly alternative to F-gases.

F-gases also contribute to global warming indirectly. This is because the increasing uptake of refrigeration and air conditioning equipment (especially in hot developing nations such as India, Southern China and Brazil) leads to increased energy consumption. If this sounds pedantic, by some estimates refrigeration and air conditioning will account for 19% of actual CO2 emissions worldwide by 2050.

F-gases are also used in polyurethane and polystyrene insulation manufacturing, fire protection systems, high voltage switchgear and aluminium production: all potential concerns for developers and the construction industry.

Below is a breakdown of the main changes to the air conditioning regulations and how it will affect suppliers, operators and commercial property developers in Bristol and beyond.


A significant overhead for developers and subcontractors will be retraining personnel, from designers to maintenance engineers, in order to comply with new regulations and understand new refrigerant technologies. Employers must also have company F-gas certificates.

A number of organisations are accredited to provide qualifications, including Siemens Power Academy and the National Grid. However, qualifications are not transferable between one speciality and another (fire protection systems, air conditioning, switchgear, or solvent recovery). You can check whether a qualification covers a particular job by looking at the guidance from the Department for Environment, Food and Rural Affairs (DEFRA).


A list of F Gas chemicals is available can be found here. Only organisations awarded a quota can import or produce HFCs and you must ensure (in writing) that they are legitimate quota holders before delivery. Letters of assurance evidencing legitimate use by qualified personnel are required throughout the supply chain and must record company and contractor certificate details as well as the F-Gas and quantities supplied.


All products must now be labelled with the weight of fluorocarbon contained and its CO2 global warming equivalent. These details are required in mandatory record-keeping, and tables have been published to help calculate the figures.


Suppliers and operators should be ready when asked for the carbon-loading of an air conditioning or refrigeration system – the CO2-equivalent damage (GWP) of the gas multiplied by its quantity. Since 1st January 2017, this figure is used to calculate the mandatory frequency of leak checks, usually 1-4 per year. Leakages must be measured, recorded, and ameliorated.

Developments in Bristol: Ensuring Compliance

Bristol’s commercial market has been bucking national trends with businesses choosing to locate here. As such, it could be more impacted by the regulations than other major cities in the UK.

Notable city developments include the Aurora in the Finzels Reach business district and Glass Wharf near Temple Meads. Both have been widely praised for commitments to sustainability but as with most modern buildings with lots of glass, depend heavily on air conditioning.

Nearby Temple Quarter Campus is a development worth £300 million to the city, encompassing an enterprise hub and student village. Also nearby is the Paintworks (Phase 3) development near Brislington and Totterdown.

Recently approved Engine Shed 2 will build on the old George & Railway Hotel with a large glass office block above a two storey retail space. Again, this is a design heavily dependent on air conditioning.


One of the best alternatives to HFCs, environmentally speaking, is carbon dioxide. Supermarket CO2 cascade refrigeration systems are already common but only work well in cooler environments (one reason supermarkets seem colder than they used to be).

In new systems, temperature-tolerant non-fluorinated hydrocarbons are good all-rounders, while Hydrofluoro-olefins (HFOs) have the least climatic effect and best energy efficiency.

Older systems can continue to run, provided that they are well maintained against leakage and eventually emptied by a qualified disposal company, but owners are concerned their refrigerants (like R404A and R410A) will become unavailable. Often these can be refilled with less damaging R407A or R407F, but prices of all refrigerants are rising.

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