Regulatory developments on renewable energy
The energy transition process initiated by Europe, the push towards renewable energy combined with the energy crisis that has been unleashed in recent months, have significantly contributed to rethinking and reviewing the energy, economic and environmental strategies of the entire European area.
In recent months, according to national and EU regulatory programs, various technical regulations had to be issued that impacted the appliances and plant design of the air conditioning sector which, as is well known, is one of the most energy-intensive sectors.
Their enactment today marks a halt, useful for legislators to rethink and reformulate certain strategic positions on energy issues. But we can now look at some of their contents, which can provide us with a concise overview of the impact we can expect on our business, once published.
We therefore try to provide an overview of the regulatory developments that impact or will impact on air conditioning products and plant design.
- Revision of the RED II Directive on the use of renewable energy for air conditioning
- Revision of the EPBD Directive (2018/844, which replaced by Directive 2010/31)
- Revision of Regulation no. 517/2014 (F-Gas)
Revision of the RED II Directive on the use of renewable energy for air conditioning
The Delegated Regulation (EU) 2022/759, published last May, amends Annex VII of Directive (EU) 2018/2001 (RED) regarding the method of calculating the amount of renewable energy used for cooling.
The Regulation indicates a calculation method according to which a portion of the energy produced for cooling the rooms or the process cooling energy can be considered as renewable. Being a Regulation and not a Directive, theoretically the content of the Regulation becomes operational immediately in the various EU countries. Again theoretically, therefore, for the calculation of the percentage of renewable energy used in air conditioning systems, in addition to that extracted from the environment for heating, it could also be calculated that subtracted from the environment during air conditioning. However, this possibility is not yet clear and therefore not applicable (also because it would be necessary, to do so, to update everything from the legislation on the methods of calculating the quantity of renewable energy to be counted), and therefore clarifications are in progress at the Ministry, to understand the application methods. For now, therefore, this Regulation should apply exclusively to the calculation of the renewable energy quotas for the achievement of national objectives in relation to European commitments.
Revision of the EPBD Directive (2018/844, which replaced by Directive 2010/31)
This Directive is important as it dictates the main rules regarding the energy efficiency of buildings. In force for some years, a revision text has already been drawn up, presented by the European Commission at the end of 2021 and which has raised many observations and some criticisms about its contents.
And the new items are so many and could have an important impact on both the design and the owners of the buildings. In the revision text, for example, we read that all public buildings must be reported at least to Energy Class F by January 1, 2027, as well as non-residential private ones, while for residential ones the deadline will be January 1, 2030.
The Commission has also included in the revision proposal the concept of "building intelligence", ie buildings capable of using information and communication technologies and electronic systems to adapt their functioning to the needs of the occupants and to the network, all to improve energy efficiency and their overall performance. A Regulation dedicated to the practical implementation of this function should be finalized by 2025.
The scheme of the Energy Performance Certificates will also be subject to revision, to make them more easily understandable and complete with other useful data for the end user, for example the energy consumption of the building.
The review goes even further, proposing the elimination of incentives for fossil fuel-fired boilers, as a technology unable to use renewable energy. For this reason, this requirement will not impact on electric and gas heat pumps.
The proposed revision of the Directive published by the European Commission contains other changes, but we remind you that this document, once approved and published, must be implemented by the various Member States, with the right to adhere to the contents in a total or even partial way, in to what extent the transposition will have to take into account the various political, economic and environmental conditions of the various regions.
The Directive approval procedure is still in progress and at present the exact period in which it could be issued is not known.
Revision of Regulation no. 517/2014 (F-Gas)
The current regulation provides indications and dictates the rules for the use of climate-changing fluorinated refrigerant gases (HFCs). The current review would like to dictate further stringent provisions regarding the reduction of the use of refrigerant gases and their impact on the climate, recalling compliance with the Kigali Amendment under the Montreal Protocol, with limitations on the production and consumption of HFCs and other F-gases even beyond 2030.
In the text of the proposal, which was presented on April 5 by the European Commission, the following changes are indicated:
- The reduction of the maximum quantity of HFCs that can be placed on the market by 2030, going from 21% currently in force, to about 5% compared to 2015 values.
- The obligation of periodic checks also for systems served by low GWP synthetic gases (for example HFO) based on the kg of refrigerant inserted in the system and not on the basis of TCO2eq.
- The extension of the ban on the placing on the market of some refrigeration and air conditioning equipment that contain refrigerants with a GWP greater than 150 starting from 2024.
- The extension of the ban on the use for maintenance and assistance of fluorinated gases with GWP equal to or greater than 2020 also to equipment with a content of less than 40TCO2eq.
- The establishment of an "F-Gas Portal" for the general management of quotas and companies interconnected with the European Union one-stop shop for the customs environment, in order to monitor any illegal trade, indicating to the various States to introduce electronic management of register data.
It is therefore clear that the Commission intends to give a strong push to the migration towards low GWP refrigerants (less than 150) already available today, but for obvious reasons still very little used.
The content of the proposed revision of the Regulation is now being negotiated between the Member States and the European Council. Its entry into force is estimated for January 2024.