In Switzerland, refrigerants are regulated by Annex 2.10 of the Chemical Risk Reduction Ordinance (ORRChem). The development of this regulation reflects the advancing state of the technology. The result has been a gradually extended list of substances and substance groups that were prohibited or restricted for use as refrigerants due to their impact on the ozone layer and climate (see graphic). Transitional provisions exist for the use of refrigerants to facilitate the adjustment to the respective new prohibitions, and temporary exemptions can be granted on the basis of a detailed application (see below).
1. Refrigerants stable in the atmosphere
The prohibitions of Annex 2.10, section 2.1, paragraph 2 and 3, ORRChem, refer to the manufacture and placing on the market of appliances as well as mobile and stationary systems that operate with refrigerants stable in the atmosphere. In particular, on 1 December 2013 a prohibition entered into force for the following stationary systems using refrigerants stable in the atmosphere and exceeding certain cooling capacities:
- air conditioning systems and heat pumps;
- commercial refrigeration systems;
- industrial refrigeration systems;
- ice rinks.
From 1 September 2015 on, the ORRChem implements adaptations to the existing restrictions of refrigerants stable in the atmosphere. Important changes refer to the definition of threshold values for the permitted amount of refrigerant per cooling capacity produced, and to the consideration of the waste heat utilization. The following documents illustrate the ban and applicable restrictions on the stationary equipment concerned as of 1 September 2015 in accordance with the ORRChem (documents in German, Italian and French are available under the respective language versions of this website):
Regelung Kälteanlagen - Grafische Zusammenfassung (PDF, 73 kB, 07.05.2018)(available in German, French and Italian)
Übersicht über die wichtigsten Kältemittel (PDF, 92 kB, 30.11.2017)(available in German, French and Italian)
Implementing the provisions of the ORRChem leads to an increasing use of refrigerants having a higher toxicity or flammability, that can induce local risks. The implementation of the security standards SN EN 378 for stationary systems minimize such risks.
If due to the state of the technology it is not possible to comply with standards SN EN 378-1:2008+A2:2012, SN EN 378-2:2008+A2:2012 und SN EN 378-3:2008+A1:2012 without using a refrigerant stable in the atmosphere, the FOEN may grant an exemption from the above ban for a given stationary system with refrigerants stable in the atmosphere on the basis of a detailed application (Annex 2.10, section 2.2, ORRChem).
In the event that an exemption should be granted, the following requirements nonetheless have to be complied with:
- Refrigerants that are stable in the atmosphere with the lowest possible impact on climate must be used, according to the state of the technology; and
- Measures must be taken to prevent emissions of refrigerants, according to the state of the technology.
For submitting requests for exemptions, the following form can be used:
Gesuchsformular Ausnahmebewilligung für Kälteanlagen (DOC, 273 kB, 30.11.2017)(available in German, French and Italian)
A new simplified exemption procedure exists for the placing on the market of temporary refrigeration systems. A correspondent exemption can be requested using the following form:
Gesuchsformular für temporäre Kälteanlagen (DOC, 123 kB, 30.11.2017)(available in German, French and Italian)
An enforcement aid has been published in November 2017, with the purpose of providing a practical aid to implementing the regulations:
The enforcement aid describes the status of technology for the various areas of application (industrial refrigeration, commercial refrigeration, air conditioning). The state of the technology is defined in terms of impact on the environment, energy efficiency, status of industrial development, operational safety, availability on the market, economic compatibility and overall protection of human beings and the environment.
Import and export
From 1 June 2019, any person wishing to import refrigerants stable in the atmosphere or export a gross mass exceeding 20 kg of refrigerants stable in the atmosphere requires authorisation from the FOEN. More information and the application forms are available on the FOEN's website for substances stable in the atmosphere.
The requirement of obtaining a cantonal or PEBKA permit for the manufacture of any refrigeration systems containing more than 3 kilograms of refrigerants that are stable in air has been repealed with effect from 1 December 2013. This requirement was replaced by the prohibition of refrigeration systems with cooling capacities above specific thresholds (see above).
In the case that a cantonal or PEBKA permit for the manufacture of a given stationary system with more than 3 kg refrigerant stable in the atmosphere has been issued before 1 December 2013, the corresponding system was authorised to be manufactured until 31 December 2016 (Annex 2.10, section 7, ORRChem).
2. Refrigerants that deplete the ozone layer
Reminder of bans in accordance with Annex 2.10, ORRChem
- Bringing refrigerants containing CFCs or halons onto the market, and using them for refilling refrigeration systems, has been prohibited since 1 January 2004
- Bringing refrigerants containing virgin HCFCs onto the market, and using them for refilling refrigeration systems, has been prohibited since 1 January 2010
- Bringing refrigerants containing HCFCs onto the market, and using them for refilling refrigeration systems, has been prohibited since 1 January 2015
3. Leakage inspections, service log and reporting procedure
The aim of the instructions cited below is to ensure that authorities, specialists and owners/operators of refrigeration systems or heat pumps are provided with detailed information and harmonised solutions with a view to implementing the provisions of Annex 2.10 of ORRChem relating to:
- the service log book, which must be kept by the owner for all equipment and installations that contain more than 3 kilograms of refrigerants
- periodical leakage inspections of equipment and installations that contain more than 3 kilograms of refrigerants that deplete the ozone layer or are stable in the atmosphere; in particular in relation to the frequency and form of the inspections depending on the type of equipment and installation
- the reporting requirement or the owner concerning the commissioning or decommissioning of installations containing more than 3 kilograms of refrigerants that deplete the ozone layer or are stable in air, as well as installations that are already in operation.
The reporting of commissioning or decommissioning a stationary system containing more than 3 kg of ozone-depleting refrigerants or refrigerants stable in the atmosphere, as well as of not yet reported existing systems shall be made by:
Last modification 01.05.2019