Lack of restriction on high-GWP mobile air-conditioning refrigerants in Australia: A missed opportunity

A column by VASA President Brett Meads

You could be forgiven for thinking the following is a crude attempt at satire, perhaps even sarcasm – or maybe a bad dream – however, you would be wrong. This is a bizarre set of circumstances, with long-term negative environmental consequences, thanks to a sad omission by those within the Department of Climate Change, Energy, the Environment and Water (DCCEEW).

By the time you read this the proposed restrictions on small air conditioning equipment with high global warming potential (GWP) refrigerant will have come into effect as of 1 July 2024.

In short, the ban applies to air conditioning equipment designed for cooling or heating (or both) a stationary space, primarily for human comfort, if the equipment is:

•  an outdoor unit for a single-head split air conditioning system
• a window/wall air conditioner

And the equipment:

• has a standard refrigerant charge of 2.6 kilograms or less, and
• contains, or is designed to operate with, a HFC refrigerant that has a global warming potential (GWP) of more than 750

All the above is great, and it is certainly a step in the right direction. The intent is to rid equipment meeting the prescribed criteria of high GWP refrigerants, such as R134a (GWP 1430) and R410A (GWP 2088).

The decision to set the GWP limit at 750 seems to be a convenient nod of approval for the continued use of R32, with a GWP of 675, which is still better than that of R410A with a GWP some three times higher.

The real issue here – the head scratching bit – is in the list of exclusions in relation to this ban.

Among other examples, the ban will not apply to equipment that is “designed for use in mobile applications such as motor vehicles, caravans, aircraft and boats”.

Why are motor vehicles excluded, you ask? I have no idea.

Let’s assemble some relevant points:

• Most light vehicle, light commercial, off highway, and agricultural vehicles have a refrigerant charge of less than 2.6 kilograms. Once vented to atmosphere, the refrigerant charge originating from a mobile system is no less damaging to the environment that the equivalent refrigerant charge originating from a stationary system.
• Because of the engineering requirements of a mobile AC system, most utilise a flexible line (rubber/composite hose) as part of the refrigerant loop. Regardless of the brand, flexible lines present a higher risk of refrigerant leakage over time when compared with a hard line.
• Mobile applications, such as motor vehicles, are not bolted to a building or a concrete pad. They are driven around in close proximity to other motor vehicles and occasionally bump into one another, resulting in a complete refrigerant charge loss to the atmosphere.
• (And here is the kicker) We have a commercially proven, low-GWP alternative for mobile systems, with a GWP of less than 1.

After many years of research and significant cost to the global industry, a viable alternative to R134a was developed for use in mobile applications. R1234yf has been in wide commercial use globally for more than seven years. 

The main driver behind this change was a result of global communities not missing an opportunity, and regulating the use of low GWP refrigerants in mobile platforms.

This scenario becomes more absurd when you consider that, as we no longer have a new vehicle manufacturing base in Australia, most of the vehicles sold new in our dealerships are still using high-GWP R134a refrigerant, even though the same platform is sold in the country of origin, and most other global export markets, with low GWP R1234yf refrigerant.

Yes, I know we are seeing an increasing number of models sold new in Australia with R1234yf refrigerant, however, the fact that we have not put in place any mechanism to hasten this shift to low GWP alternatives for our fleet during the last seven years is almost beyond belief.

But wait, there’s more. The result of not imposing a ban on high-GWP refrigerants in motor vehicles, when there is a viable alternative, means that manufacturers can continue to choose the refrigerant used for our market.

The insanity of this is no more obvious than when considering the current offering of ‘environmentally friendly’ electric vehicles.

Not only do many manufacturers still use R134a in vehicles sold in our market, they have also increased the refrigerant charge to accommodate complex system architecture, involving battery thermal management in addition to occupant comfort. 

Some random new car examples – and I am not brand-shaming here, it just happens to be data I have at hand– include:

• Toyota bZ4X: R134a charge of 620 grams
• Hyundai Ioniq 5: R134a charge of 950 grams
• Kia EV9: R134a charge of 1375 grams (yes, 1.375 kg of GWP 1430 R134a, equivalent to nearly two tonnes of CO2 if released to atmosphere)

It is kind of crazy to think that one frontal impact to your ‘environmentally friendly’ EV could have a serious global warming impact – when it need not be that way.

Given that mobile platforms tend to be ‘leaky’ over time, and that they drive around at speed and bump into one another, and that we have a viable low-GWP alternative already used overseas in most platforms, I don’t know how you would describe the continued use of high-GWP refrigerants in vehicles sold new in Australia.

As for our federal regulators not regulating the use of low GWP refrigerants in mobile applications, I am fairly sure you would describe that as a lost opportunity.