Knowledge/Refrigerants/Prohibited charging, and why you can't go up in GWP
Prohibited charging, and why you can't go up in GWP
In force since 1 January 2020. You can't charge a system with a refrigerant that has a higher GWP (global warming potential) than the one it was designed to use. And it's not just permit holders. Anyone working on the equipment is covered, permit or not.
- In force since
- 1 Jan 2020prohibited charging
- The rule
- No GWP increaseover the design refrigerant
- Applies to
- Anyonepermit or no permit
- Under
- Ozone Protection Regulations1995, penalties apply
Who does the rule apply to?
The ban is on charging up in global warming potential from what the equipment was designed for. Doing it is an offence under the Ozone Protection and Synthetic Greenhouse Gas Management Regulations 1995, and penalties apply.
Here's the bit worth noticing in the Australian Refrigeration Council (ARC) guidance. This offence applies to any person carrying out work on RAC (refrigeration and air conditioning) equipment, regardless of whether they have a permit. Most refrigerant rules only apply to licence and permit holders. This one applies to whoever does the work.
So an unlicensed person doing the work isn't outside this rule. They're inside it, plus whatever else applies for working unlicensed.
What are the exemptions?
| Exemption | What it allows |
|---|---|
| Equipment designed for HCFCs (hydrochlorofluorocarbons), like R22 | An R22 system may be converted to R407C, which has zero ozone depleting potential (ODP) |
| Equipment essential for health or public safety | Where no lower-GWP option exists |
The R22 case is the one you'll meet. R22 has an ODP of 0.055 and a GWP of 1,810. R407C has zero ODP and a GWP of 1,774. So on the AR4 figures Australian law uses, R407C actually comes in slightly lower on GWP, as well as getting rid of the ozone damage.
That means the R22 to R407C conversion isn't a GWP increase in the first place. The exemption is what matters for any HCFC conversion that would go up.
What does it mean on a real job?
Mostly it means you can't solve a supply problem by putting the wrong gas in. If a unit was designed for R32 (GWP 675) and the only cylinder on the van is R410A (GWP 2,088), there's no legal way to make that work.
Think about this now, not halfway through the transition. The industry is heading toward lower-GWP refrigerants, and whatever gas a system was designed for sets the ceiling on what it can legally be charged with for the rest of its life.
Going the other way is fine. Nothing here stops a lower-GWP refrigerant where the equipment and the manufacturer support it. The ban only works in one direction.
Working out what the transition means for you?
There's a lot of noise about what's banned and when, and most of it is either early or wrong. What matters is what you buy and stock this year.
Kevin will give you the straight version.
Who this is for: small and medium HVAC contractors in Victoria. If you're a homeowner after a rebate or a repair, you need a licensed contractor, not us, and yours can point you the right way.
Related
- Refrigerant recovery, and the tools A2L won't shareEvery recovery rule in one place, the equipment standards behind them, and why your A1 recovery kit generally isn't fit for A2L gas.
- Identify refrigerant by the label, never by the colourAustralia doesn't use the American whole-body colour system. Cylinders are white or galvanised with a coloured band, and four common gases aren't charted.
- Glide, and why blends can only be charged as liquidPure refrigerants can go in as vapour or liquid. Under the Australian code, every blend goes in as liquid, glide or not. R513A is where people get caught.
- R744 CO2 is a different world: 63 bar at 25 degreesAbove 31°C, CO2 won't condense, so transcritical is normal running for a CO2 heat pump water heater here. Ordinary HVAC gauges aren't rated anywhere near it.
Review date: 1 April 2027. Figures in this area change without much notice and this page carries some that will go stale. Every number above is dated and sourced so you can check it yourself. If you find something out of date here, tell us and we will fix it.