Laws And Regulations

The effects of climate change can be seen worldwide. Protecting the climate is one of the most important responsibilities. However, this responsibility presents enormous challenges to all involved.

The Kyoto Protocol outlines worldwide goals regarding climate protection, among other things. In addition to target reductions of carbon dioxide, this protocol also outlines target reductions for fluorinated greenhouse gases such as refrigerant R134a due to their high potential of contributing to the greenhouse effect.

Numerous laws have been created for the automotive industry, for example at the European level. For example, chemical-climate protection regulations were put into effect on August 1, 2008 in Germany in order to define the European legislation in more detail.

• Provision (EU) no. 1005/2009
• Provision (EU) no. 842/2006
• Provision (EU) no. 706/2007
• Provision (EU) no. 307/2008
• Guideline 2006/40/EU
• Chemical-climate protection provision, recycling management and disposal regulations (for Germany)

Maintenance and repair work on the A/C system refrigerant circuit 

All individuals performing maintenance and repair work on vehicle A/C systems must have completed a training program and be competent in the work required. Other regulations may apply in addition to those of the European Union.

The following general points apply 

Operation, repair, decommissioning, take-back obligation

• When operating, repairing and decommissioning items that contain refrigerant, allowing the refrigerant to vent into the air is prohibited.
• Keep records about the quantities used during operation and maintenance (Refrigerant Log, refer to Volkswagen Service Net, Handbooks, Service Handbook; Protecting the Environment; Emission Protection) so they can be presented to the authorities upon request. Other provisions may apply in countries that are not members of the EU.
• Distributors of the substances and preparations discussed above are obligated to accept these items back after use or to ensure they are accepted by a third party of their choosing.
• Maintenance and decommissioning of items containing refrigerant that are named in the legislation Substances and preparations named in this legislation may only be accepted by those with the necessary expertise and technical equipment.

Criminal offenses and infringements of the law 

• Willfully or negligently venting refrigerant into the air when operating, repairing or decommissioning items that contain refrigerant constitutes a violation of the laws and legislation described above.

Technical Regulations For Compressed Gases (TRG) 400, 401, 402 

Only excerpts concerning vehicle manufacturers and workshops are listed below.

TRG 400 (General Regulations For Charging Systems) 

2. Definition of terms and explanations

2. 1 Charging systems

2.1.1 Charging systems are systems for filling mobile compressed-gas vessels. The charging system includes the premises and facilities concerned.

2. 4 Charging systems requiring a permit

Charging systems requiring a permit are ones used to transfer compressed gases to mobile compressed-gas vessels for supplying to third parties.

5 Charging systems not requiring a permit are ones used for transferring compressed gases to mobile compressed-gas vessels for internal use only.

TRG 401 (Installation Of Charging Systems) 

Does not apply to vehicle manufacturers or workshops.

TRG 402 (Operation Of Charging Systems) 

2. Employees and employee instruction

2. 1 Charging systems are only to be operated and maintained by personnel

• who are 18 years of age and older
• who possess the necessary technical knowledge
• who can be relied upon to work diligently.

2. 2 Supervised work may also be performed by personnel that do not meet the requirements stipulated in item 2. 1, points 1 and 2.

2. 3 Employees are to be given instruction on the following topics before beginning work and at regular, appropriate intervals, however at least once a year:

• Hazards specifically associated with handling compressed gases
• Safety regulations, particularly the applicable TRG
• Procedures in the event of malfunction, damage and accidents
• The use of fire-extinguishing and protective equipment
• Operation and maintenance of the charging system according to the operating instructions.

Charging (a separate TRG applies to vessels from other countries and their charging) 

A compressed-gas vessel is only to be filled with the compressed gas declared on it and the quantity must comply with the stipulated pressure, weight or volume data (refer to g15, Para. 2, pressure vessel regulations).

2. In the case of vessels approved for use with several types of compressed gas, the compressed gas with which it is to be filled and - if the compressed gas has a tk greater than or equal to -10 °C (14 °F) (tk = critical temperature) - the maximum permissible charging weight in line with TRG 104 No. 3. 3 must be marked on the vessel prior to connection for filling.

3. Compressed-gas vessels marked with the maximum permissible charge pressure in bar at 15 °C (59 °F) must be filled manometrically. If, at the time of filling, the temperature is not 15 °C (59 °F), the pressure corresponding to the prevailing temperature must be established; it must be ensured that the permissible charge pressure at 15 °C (59 °F) is not exceeded in the compressed- gas vessel. The charged vessels are to be checked by way of random pressure measurements to determine possible overfilling.

4. Compressed-gas vessels on which the maximum permissible capacity is indicated by the net weight (filling weight, permissible weight of fill) in kilograms must be filled gravimetrically. The vessels are to be weighed during filling and subsequently subjected to a weight check on special scales to establish possible overfilling. Scales used for this purpose must be calibrated.

5. Under certain conditions, gases with a tk greater than or equal to 70 °C (158 °F) may be transferred volumetrically from compressed-gas vessels with a maximum volume of 150 l to compressed-gas vessels with a volume of maximum 1000 ccm. The stipulations of the TRG apply to the transfer of liquefied gas to cylinders used by workmen.

6. Vessels in vehicles for

(1) Gases with tk greater than or equal to +70 °C (158 °F) (refer to TRG 101 Annex 3)

(2) Industrial gas mixtures with tk greater than or equal to +70 °C (158 °F) (refer to TRG 102 Annex 1 Groups 3) or

Liquefied extremely low-temperature compressed gases (refer to TRG 103) may, contrary to item 4, be filled volumetrically if the charging system and/or the vessels is/are equipped with devices for measuring or limiting the volume of the charge and - with the exception of motor vehicle vessels as per item 3 - for measuring the temperature of the charge. When filling volumetrically, it must be ensured that the permissible charge weight indicated on the vessel is not exceeded. To determine possible overfilling, the filled containers are to be checked gravimetrically on a calibrated scale or - provided that the pressurized gases are not highly toxic - volumetrically. Volumetric checking requires the use of appropriate equipment with completely separate charging and checking devices.

7. Charging and check measurements are to be performed by different people. Check measurements must be performed immediately upon completion of the filling process.

8. Overfilled vessels must be drained immediately and in a safe manner until the permissible fill is attained. The compressed-gas fill is then to be determined again.

9. Items 4 to 7 do not apply to vessels for liquefied, extremely low-temperature compressed gases which are neither flammable nor toxic; this does not affect the provisions of road traffic legislation.

10. When filling compressed gas vessels with liquefied gases at charging temperatures less than or equal to -20 °C (-4 °F), the compressed gas vessel (if the vessel material has not been tested for temperatures less than or equal to -20 °C (-4 °F) is not to be released from the charging system for transportation until the vessel wall temperature is greater than or equal to +20 °C (68 °F).

Recycling and Disposal Regulations 

Specifications and rules for handling and disposing of refrigerants and refrigerant oils can be found in the chemical-climate protection provision and recycling and disposal regulations. These are valid in Germany. Different specifications and rules may apply in other countries.

Refrigerant, Keeping Records 

The environmental statistics law requires records to be kept on the use of refrigerants.

Consequently, motor vehicle workshops may well have to provide the relevant local authorities with information on their use of refrigerant. It is therefore recommended to keep records of the quantities used during operation and maintenance (refrigerant log) and present them to the relevant authorities upon request.