Refrigerants

In Switzerland, refrigerants are regulated by Annex 2.10 of the Chemical Risk Reduction Ordinance (ORRChem). A key objective of the Ordinance is to reduce emissions  of ozone depleting and potent climate-warming refrigerants. The Ordinance is regularely updated to keep it in line with the advancing state of the art.     

Relevant legal provisions


1. Refrigerants stable in the atmosphere in stationary systems

Refrigerants stable in the atmosphere are refrigerants, which contain any of the substances stable in the atmosphere according to Annex 1.5 ORRChem (Annex 2.10 number 1 paragraph 3 ORRChem). A system is considered stationary if it is used unmoved.

Prohibitions

Annex 2.10 number 2.1 paragraphs 3 to 7 ORRChem prohibit the placing on the market (including import) of certain stationary systems (e.g. air conditioning systems, industrial cooling systems, heat pumps) that use refrigerants stable in the atmosphere. The ban applies in particular to systems with high cooling capacities, systems containing refrigerants stable in the atmosphere with high global warming potentials, and systems with high filling capacities.

The guide to “systems containing refrigerants: from concept to placing on the market” (available in German, French and Italian) explains these regulations in more detail. It defines the state of the art in the various fields of application. 

 

Anlagen mit Kältemitteln: vom Konzept bis zum Inverkehrbringen

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This publication does not exist in English. It is available in other languages.

The guide also contains the following practical summaries:

Particular attention should be paid to the following new provisions:

  • Since 1 June 2019, a licence is required to import and export of certain refrigerants stable in the atmosphere (see information on substances stable in the atmosphere). 
  • Since 1 January 2020 onwards, stricter regulations will apply to the placing on the market of stationary installations containing refrigerants stable in the atmosphere (Annex 2.10 number 2.1 paragraph 3 ORRChem).
  • Since 1 January 2020 onwards, servicing (refilling) with non-regenerated refrigerants stable in the atmosphere with a global warming potential of 2500 or more in installations with a filling capacity of 40 tonnes CO2 equivalents or more are prohibited (Annex 2.10 number 3.3 and number 7 paragraph 5 ORRChem).
 

Exemptions

In the case of systems that are clearly unable to comply with standards SN EN 378-1:2017, SN EN 378-2:2017 and SN EN 378-3:2017 without using a refrigerant stable in the atmosphere, the FOEN may grant an exemption from the prohibition specified in Annex 2.10 number 2.1 paragraph 3 ORRChem for a given system (see Annex 2.10 number 2.2 paragraph 8 ORRChem).

The following form can be used to request an exemption: 

 

A simplified exemption procedure exists for the placing on the market of temporary refrigeration systems using the following form:

 

2. Refrigerants stable in the atmosphere in appliances and mobile systems 

An appliance is a plug-in system for refrigeration which is not permanently connected to cool or heat distribution piping; also fixed appliances are classified as appliances rather than as systems (Annex 2.10 number 1 paragraph 6 ORRChem). To promote uniform enforcement practice, the following terms are further specified from a technical point of view:

  • A "plug-in system" is a compact system which can be connected and operated unchanged, directly and without the need for tools after delivery to its installation site and whose maximum electrical power consumption does not exceed 4 kW.
  • "Permanently connected" is defined as a permanent (non-detachable) welded or brazed joint in accordance with the specifications of SN EN 378-2:2017 section 6.2.3.2.2.
 

Mobile systems are considered to be systems if they are used in a mobile way (in contrast to stationary systems), e.g. air conditioning systems in cars or public transport vehicles, transport refrigeration for containers on trucks, etc.

Prohibitions

Annex 2.10 number 2.1 paragraph 2 ORRChem prohibits the manufacture and placing on the market (including import) of certain appliances and mobile systems that use refrigerants stable in the atmosphere (see list below).

Exemptions 

Appliances and mobile systems listed in Annex 2.10 number 2.1 paragraph 2 letters b-f ORRChem are permitted subject to certain requirements. The current technology must be such that no substitute is available, the refrigerant stable in the atmosphere with the smallest impact on the climate must be used, and state-of-the-art measures must be taken to prevent refrigerant emissions (Annex 2.10 number 2.2 paragraph 2 ORRChem). Annex 2.10 number 7 paragraph 4 ORRChem regulates the transitional period after a change in the state of the art; the FOEN gives notice of these changes on this page after consultation with the industry concerned.

On the basis of a well-founded application, the FOEN may grant temporary exemptions from the prohibitions of Annex 2.10 number 2.1 paragraph 2 letters a and b ORRChem under the aforementioned conditions (Annex 2.10 number 2.2 paragraph 7 ORRChem) .

 

For the appliances and mobile systems listed below, the current state of the art is as follows:

a) Household refrigerators and freezers: Household refrigerators and freezers have been manufactured without refrigerants stable in the atmosphere according to the state-of-the-art for several years, with the result that no exemption is available under ORRChem for non-compliant appliances. Other household cooling and freezing appliances, such as ice machines for home use, are not covered by this provision.

b) Commercial cooling and freezing appliances:

 

c) Household appliances containing heat pumps, in particular appliances for dehumidifying and drying: An alternative currently does not exist, so the direct exemption applies for all uses.

 

d) Air conditioners

e) Air conditioning systems used in motor vehicles

f) Mobile refrigeration systems for the transport of goods: An alternative currently does not exist, so the direct exemption applies for all uses.

 

3. Ozone-depleting refrigerants

Ozone-depleting refrigerants are refrigerants that contain any of the substances that deplete the ozone layer according to Annex 1.4 ORRChem (Annex 2.10 number 1 paragraph 2 ORRChem).

Prohibitions

  • Placing refrigerants containing CFCs or halons on the market and their use for refilling appliances and systems, has been prohibited since 1 January 2004.
  • Placing refrigerants containing virgin HCFCs on the market and their use for refilling appliances and systems, has been prohibited since 1 January 2010.
  • Placing refrigerants containing HCFCs on the market and their use for refilling appliances and systems, has been prohibited since 1 January 2015.

Exemptions

Since 1 June 2019, the manufacturing, placing on the market, import for private purposes and export of appliances and systems that use ozone-depleting refrigerants has been permitted, subject to certain requirements. The current technology must be such that no alternative is available, the refrigerant used must have an ozone depleting potential of not more than 0.0005 and state-of-the-art measures must be taken to prevent refrigerant emissions (Annex 2.10 number 2.2 paragraph 6 ORRChem). Annex 2.10 number 7 paragraph 4 ORRChem regulates the transitional period after a change in the state of the art; the FOEN gives notice of these changes on this page after consultation with the industry concerned.

 
 

4. Leakage checks, maintenance log and reporting procedures

Annex 2.10 numbers 3.4, 3.5 and 5 ORRChem lay down certain obligations with regard to checking for leaks, keeping a maintenance log and giving notice of certain systems and appliances that use refrigerants. The “Guideline on Stationary Systems and Devices with Refrigerants" (available in German, French and Italian) explains these obligations. 

 

Anlagen und Geräte mit Kältemitteln: Betrieb und Wartung

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This publication does not exist in English. It is available in other languages.

Particular attention should be paid to the following new provision:

  • Since 1 June 2019, notice must be given of all stationary systems containing more than 3 kg of refrigerants, irrespective of the refrigerant used. This obligation also applies to already existing systems.

Notice should be given to the Swiss Registration Office for Refrigeration Systems and Heat Pumps (SMKW):

Schweizerische Meldestelle für Kälteanlagen und Wärmepumpen (SMKW)
Hubrainweg 10
8124 Maur

 

Further information

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Last modification 08.10.2020

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