F-Gas Regulation (Regulation (EU) 2024/573)
On the 29th January 2024 the EU announced the adoption Regulation (EU) 2024/573 to phase out fluorinated gases (F-gases) and other substances that contribute to global warming and ozone layer depletion. These regulations came into effect on 11th March 2024.
For more information about the legislation, visit EUR-lex.europe.eu
Article 13 part 9 states that “The Putting into Operation of the following electrical switchgear using, or whose functioning relies upon, fluorinated greenhouse gases in insulating or breaking medium shall be prohibited as follows”:
- From 1 January 2026, medium voltage electrical switchgear for primary and secondary distribution up to and including 24 kV
- From 1 January 2030, medium voltage electrical switchgear for primary and secondary distribution from more than 24 kV up to and including 52 kV
- From 1 January 2028, high voltage electrical switchgear from 52 kV up to and including 145 kV and up to and including 50 kA short circuit current, with a global warming potential of 1 or more
- From 1 January 2032, high voltage electrical switchgear of more than 145 kV or more than 50 kA short circuit current, with a global warming potential of 1or more
| Voltage range | Prohibition date | Switchgear voltage |
|---|---|---|
0-24 kV | 1st Jan 2026 | 10/20 kV (MV) |
>24 kV ≤ 52 kV | 1st Jan 2030 | 38 kV |
>52 kV ≤ 145 kV ≤50 kA | 1st Jan 2028 | 110 kV |
>145 kV >50 kA | 1st Jan 2032 | 220/400 kV |
To avoid any delays, all contestable developers should familiarise themselves with the requirements of the legislation to ensure switchgear being put into operation after the prohibition date complies. ESB Networks will not be in a position to commission or connect contestably built switchgear which does not comply with the legislation.
We understand that these changes may have significant implications for your projects, and we are here to support you through this transition. ESB Networks are actively assessing the impacts of these regulations to transmission and distribution standards in consultation with industry stakeholders. Further updates will be provided as available. Please see the FAQ's below for further information.
Frequently asked questions
Note: While every effort has been made to highlight commonly asked questions and provide support with ESB Networks interpretation, this does not replace other entities legal responsibility or their interpretation. ESB Networks advise the customer to seek independent legal advice on interpretation of any legislation. This is only one interpretation and since it is subject to a final interpretation by the courts of Ireland or the European Court of Justice, then there is no guarantee that this interpretation is correct. Ultimately, it is the legal responsibility of the installer to carry out and complete “Putting into Operation”.
The European Commission have published a set of FAQs about fluorinated greenhouse gases (F-gases), their impact, and EU regulations.
The European Commission have also published a set of FAQs specifically on the impact of these regulations in respect of electrical switchgear within the FAQ - Fluorinated Greenhouse Gases - Climate Action.
What is stated in the legislation in relation to prohibition on SF6 switchgear?
The Regulation prohibits the putting into operation of electrical switchgear using, or whose functioning relies upon, fluorinated greenhouse gases in insulating or breaking medium on a phased basis as set out below, unless evidence can be provided that that the order for the electrical switchgear was placed before 11 March 2024 (Article 13.14).
Article 13.9 of the Regulation requires that switchgear ordered after 11 March 2024 must be put into operation before the below dates:
(a) from 1 January 2026, medium voltage electrical switchgear for primary and secondary distribution up to and including 24 kV;
(b) from 1 January 2030, medium voltage electrical switchgear for primary and secondary distribution from more than 24 kV up to and including 52 kV;
(c) from 1 January 2028, high voltage electrical switchgear from 52 kV up to and including 145 kV and up to and including 50 kA short circuit current, with a global warming potential of 1 or more;
(d) from 1 January 2032, high voltage electrical switchgear of more than 145 kV or more than 50 kA short circuit current, with a global warming potential of 1 or more.)
What does putting into operation mean?
Guidance has been issued by the European Commission in its issued "FAQs on switchgear as regulated by the F-gas Regulation (EU) 2024/573"
“Putting into Operation” of electrical switchgear using fluorinated gases is the moment of handover of the equipment to the operator for use/exploitation after the completion of any necessary tests of functionality, performance or other, and any required inspections. On the other hand energization or connection to the grid is not a requirement.
Please refer to Schedule A to these FAQ's for more information.
What is Global Warming Potential?
There are several alternative switchgear technologies using different gas mixtures.
Air based switchgear products with GWP <1 or C4FN based products with GWP <1000. For reference, SF6 has a GWP of 24,300.
Is "putting into operation" equivalent to first energisation/connection to the distribution or transmission network?
Note that all entities procuring and putting electrical switchgear into operation are obliged to comply with Regulation (EU) 2024/573.
How does my project demonstrate compliance when installing switchgear that contains fluorinated gases?
1. For switchgear ordered before 11 March 2024 - by providing evidence that the order for the electrical switchgear has been placed before 11 March 2024. The customer shall provide a completed copy of Schedule A to these FAQ's, Part 2 for this case scenario. The customer must also notify the competent authority where a derogation is relied upon.
2a. For switchgear ordered on or after 11 March 2024, which was put into operation before the prohibition date - by providing evidence that the switchgear was put into operation before the prohibition date. The customer shall provide a completed copy of Schedule A to these FAQ's, Part 1 for this case scenario.
2b. For switchgear ordered on or after 11 March 2024, which was put into operation after the prohibition date - by providing evidence that a derogation under Article 13, paragraphs 11 or 12 or 15 applies. The customer shall provide a completed copy of Schedule A to these FAQ's, Parts 3 or Part 5 for these case scenarios. The customer must also notify the competent authority where a derogation is relied upon.
Please refer to Schedule A to these FAQ's.
Who is responsible for ensuring the equipment is 'compliantly put into operation'
The operator is the undertaking exercising actual power over the technical functioning of the switchgear. This is further clarified by the FAQs issued by the European Commission as follows.
"Where switchgear is put into operation by an undertaking, this undertaking is deemed to be the operator until legal handover to another undertaking which then becomes the operator responsible for compliance"
For the purposes of contestably built assets the Customer is responsible at the point of putting into operation per definition in FAQ 'What does putting into operation mean?'. ESB Networks will require declarations of compliance for putting into operation to be completed prior to handover.
For the purposes of assets engineered, procured and constructed by a Contractor they are deemed responsible at the point of putting into operation per definition in FAQ 'What does putting into operation mean?'. ESB Networks will require declarations of compliance for putting into operation to be completed prior to handover.
I ordered switchgear before 11th March 2024, does Regulation (EU) 2024/573 apply to me?
I ordered switchgear after 11th March 2024, does Regulation (EU) 2024/573 apply to me?
Are there derogations to allow where SF6 switchgear is purchased after the 11th March but will not be put into operation until after the Prohibition date?
If the SF6 switchgear is installed but due to an outage delay (outside IPP control) pushes MV connection into 2026 does the equipment need to be replaced with non SF6 before it can be energised?
Note that all entities procuring and putting electrical switchgear into operation are obliged to comply with Regulation (EU) 2024/573.
How does my project demonstrate compliance when installing switchgear that does not contain fluorinated gases?
Does the DSO have preferred SF6 alternatives at MV or 38kV. Are there likely to be any types that the DSO would not accept?
At 10 kV, 20 kV and 38 kV, Regulation (EU) 2024/573 sets out compliant switchgear as f-gas free, subject to any derogations in Article 13.
At 110 kV, 220 kV, 400 kV, Regulation (EU) 2024/573 sets out compliant switchgear as GWP<1, subject to any derogations in Article 13.
Refer to FAQ 'What is stated in the legislation in relation to prohibition on SF6 switchgear?'.
If planning permission was granted for SF6 switchgear, and the footprint will now be larger, is there a derogation to cover this or must planning be sought again?
Can you guarantee me connection this year as I have already built my substation and I have a connection date in Q4 this year?
Does Regulation (EU) 2024/573 apply to both the ESB Networks and customer sides of an installation (e.g. EGIP/EV module) or just the DSO side?
All entities must comply with Regulation (EU) 2024/573, therefore only switchgear which complies with Article 13 can be accepted. Customers are responsible for compliance with the regulation in respect of their own assets.
Refer to FAQ 'What is stated in the legislation in relation to prohibition on SF6 switchgear?'.
What if i can only get switchgear using SF6 from the market?
Please refer to Regulation (EU) 2024/573, Article 13.11 and 13.12 for further details.
Please also refer to Schedule A to these FAQ's, Part 3 for this case scenario.
What if i can only get switchgear using C4FN from the market?
Please refer to Regulation (EU) 2024/573, Article 13.11 and 13.12 for further details.
Please also refer to Schedule A to these FAQ's, Part 3 for this case scenario.
Does this apply to individual items of switchgear, e.g. MV AIS CB’s
Refer to FAQ 'What is stated in the legislation in relation to prohibition on SF6 switchgear?'.
Any derogation mechanism for the use of SF6 switchgear for extension?
Please also refer to Schedule A to these FAQ's, Part 5 for this case scenario.
If switchgear is energised in the factory prior to dispatch, has it been put into operation, if not where?
No. "Putting into Operation" is not at manufacturing stage, this is at handover to the operator for use in its final location, i.e. installed, or assembled as per design.
Refer to FAQ 'What does putting into operation mean?'.
What actual documentation would be needed to ensure that we are deemed compliant?
My contestable substation assets have not transferred ownership. If my existing SF6 switchgear fails in service do I have to replace it with SF6 free switchgear? Are there any derogation mechanisms for the use of SF6 switchgear for fault scenarios?
For example, if a part of GIS equipment fails which can be replaced, this is permitted under Art. 13.18 of Regulation (EU) 2024/573. However, if the nature of the failure involves replacing the entire electrical switchgear such as a failure of Ring Main Unit, the replacement unit will be subject to the "Putting into Operation" restriction under Art. 13.9. (Refer to FAQ 'What is stated in the legislation in relation to prohibition on SF6 switchgear?' for Prohibition, FAQ 'What does putting into operation mean?' for "Putting into Operation" and also Schedule A to these FAQ's for compliance).
Art. 13.18 of Regulation (EU) 2024/573 states: "Parts of equipment may be installed for repair or servicing of existing electrical switchgear provided that there is no change of the type of fluorinated greenhouse gas used that leads to an increase of the global warming potential of the fluorinated greenhouse gas used or an increase in the amount of fluorinated greenhouse gases contained in the equipment."
Is there any link between Asset Transfer and putting into operation?
No. However it is advisable to transfer all contestable assets at the earliest opportunity as the customer remains responsible for all risks associated with the ownership, insurance and maintenance of the assets until asset transfer is completed.
Refer to FAQ 'What does putting into operation mean?'
Please also refer to Schedule A to these FAQ's for further information.