If you operate a business using commercial refrigeration equipment, there are regulations and legal requirements you need to be aware of in order to make a fully informed purchase decision. Rules around the sale and use of professional refrigeration equipment have changed significantly over the last few years.
A new cooler you buy today may be removed from the market in less than 12 months due to further regulatory changes. It is important to know what the rules are and why they exist in order to make the right choice for your business.
Be Ready is an educational campaign produced by True Refrigeration, intended to simplify the explanation of, and keep operators updated on, the ever-evolving state of regulatory changes which affect the development and availability of commercial refrigeration equipment in Europe and the UK.
We all have a responsibility in the fight against global warming.
Are you ready?
Globally, professional refrigeration is now a highly regulated industry after the refrigerant gasses traditionally used for commercial cooling were identified as a significant contributor towards global warming, and also as products with a high potential for the reduction of energy consumption.
Through legislation, governing bodies are mandating the phase out of environmentally harmful gasses and setting minimum energy performance standards, ensuring new products which are brought to market offer progressively greener credentials.
These standards vary between countries and regions but share similar goals:
Consumers, organisations and governments around the world are increasingly aware of, and concerned about, the environmental impact of all aspects of life. Professional Refrigeration is a small part of this puzzle, but we all have a part to play, if we are to succeed.
The F-Gas Regulation aims to reduce Global Warming emissions caused by refrigerants typically found in heating and cooling applications, including commercial refrigeration equipment. It mandates a schedule of gradual phase-down’s and outright bans over an agreed time period, to reduce the consumption of, and change the way in which the industry is allowed to use, these environmentally unfriendly gasses.
In effect since 2015, the eventual goal is a reduction in the use of HFCs (hydrofluorocarbons) of 79% by 2030, encouraging manufacturers, services companies and operators to adopt technologies operating on refrigerants with significantly lower Global Warming Potential.
Big changes came into effect on January 1, 2020, banning the sale of new commercial refrigeration equipment operating on R404A refrigerant, the most widely used gas in commercial cooling at the time, due to its very high Global Warming Potential (GWP).
The next big date for F-Gas is January 1, 2022, when sales of new coolers using R134a will similarly be banned.
The second piece of legislation operators should be aware of is the Energy Labelling Regulation.
Consumers will be familiar with the “Letter grade” labelling found on many electronic products sold throughout Europe, including washing machines, domestic refrigerators, lighting and televisions.
Since 2016, some types of professional refrigeration have also been required to have labels, allowing operators to more easily benchmark and compare running costs of similar products on a like-for-like basis.
Labelling (and the testing requirements behind it) is also a route to remove from the market, products that can’t perform or use excessive energy.
From March 1, 2021, the Energy Labelling Regulation has been extended to also require labels on glass door and “doorless” multideck coolers (i.e. “Refrigerating Appliances with a Direct Sales Function”).
For commercial refrigeration equipment, Hydrocarbons (commonly abbreviated as “HC”) have proved to be the next step, not only in terms of environmental responsibility, but also more energy efficient products.
Hydrocarbon refrigerants are natural, non-toxic gasses that have no ozone depleting properties and low global warming potential. For this reason, they have been selected as the environmentally friendly successor to hydrofluorocarbon (HFC) refrigerants for commercial refrigeration, after being used widely for many years in domestic refrigeration.
R290 specifically, a highly refined propane, is the primary HC refrigerant gas now used in both commercial refrigerator and freezer equipment, and presents a number of opportunities
Today, operators in the know are choosing HC refrigeration for their businesses, as part of their corporate sustainability objectives, to increase environmental responsibility, and prioritise waste energy reduction.
Global Warming Potential (GWP) is the relative measure of how much heat a greenhouse gas traps in the atmosphere. R290 carries a GWP of just 3, a massive reduction compared to typical HFC gasses. It also has ZERO ozone depleting properties (ODP)
R290’s thermodynamic properties are also superior to HFC’s, with a heat capacitance around 90% greater than R404A, and lower viscosity. This means that R290 can absorb more heat, faster, resulting in quicker temperature recovery and when harnessed by the latest in energy efficient components, significantly lower energy consumption.
For operators with existing refrigeration equipment, it’s never been more important to understand what type of equipment you have, what it is costing you to operate and maintain it and the potential impact on your organisations carbon footprint and sustainability targets.
Since the introduction of regulations for commercial refrigeration equipment, great advances have been made by some manufacturers to improve the energy efficiency and environmental impact of their products.
It is important that operators understand and factor into their purchase decision not only the initial capital cost of equipment, but also the operating costs over the lifetime of the product.
The Energy Labelling Regulation made it mandatory for manufacturers to publish comparable energy consumption data about their products, allowing operators to benchmark running costs of similar products.
For existing older and discontinued products, labelling may not exist, so it may be necessary to record energy use directly from equipment in your kitchen or contact the manufacturer directly for information.
In some cases, operating cost can equate to several times the purchase cost over the product lifetime, and it is often the case that cheaper equipment is less energy efficient, sometimes significantly so. Only by understanding the amount of energy consumed can you make a fully informed decision.
In addition to the monetary savings for your business associated with using less energy, the positive environmental impact can also be considerable, and contribute towards your organisation’s sustainability goals and targets.
Frameworks like the Ecodesign Directive and Energy Labelling Regulation are mechanisms for reducing energy demand and in turn reducing the emissions produced when generating power.
By choosing more energy efficient equipment over products which require more energy to operate, there is also this “environment saving” factor to also consider.
If you know the kWh consumption of the equipment currently in your business, or are comparing data for new equipment as part of a planned purchase, the difference between two or more products can be entered into a Greenhouse Gas Equivalencies Calculator to determine the level of greenhouse gas emissions which can be avoided by choosing one over the other.
This difference might be small comparing one refrigerated cabinet against another, but for operators who have large estates and many assets, the greenhouse gas emission reduction can be considerable.
Comparing two products today covered by the ‘Professional refrigerators’ label, where one is rated “A” (consuming 328 kWh/annum) and the other “D” (consuming 953 kWh/annum), the difference in cost for running the two might be £81.25 per year (based on a cost of £0.13 per kWh).
This saving can be multiplied up for each year the unit is in use and also by the number of assets in service. A kitchen typically has several pieces of refrigeration equipment, and an operator may have many sites. These accumulated savings can be significant.
Working to be “more environmentally sustainable” as a business isn’t just good PR anymore.
Consumers are increasingly choosing to live more sustainable lifestyles, being more particular than ever before about the brands, products and services they support. This is especially the case with younger age groups, such as Millennials, with studies showing they also eat out more often than other groups and spend more while doing it.
The “values” which a business acts on and publicises are increasingly the deciding factors for consumers choosing where to dine and what to eat.
A survey carried out on behalf of the Sustainable Restaurant Association revealed that over 80% of respondents said that sustainability had been a deciding factor when choosing where to go eat. Another survey, produced by CGA in association with UKHospitality, found that over four in five respondents (83%) expect hospitality brands to take part in sustainable practices.
There are many positive steps which food-led businesses can take to improve their sustainability and reduce their environmental impact, not limited to shortening supply chains, offering more vegetarian and vegan options, and reducing food waste, packaging, water use, and energy consumption.
For many operators, your choice of refrigeration equipment may seem like a small consideration in the grander scheme, but these small wins do add up. Choosing today’s energy-leading “HC” refrigerators is a win for you, due to the reduced operating costs, and a win for the environment.
The regulations are in the place. The phase-out deadlines are upon us. Now is the time to assess your refrigeration assets and determine the impact on your operation.
Regardless of F-Gas, undertaking regular audits and keeping an up to date record of the refrigeration equipment assets in your estate is just good practice. With accurate data, you can effectively determine the point at which equipment replacement makes sense.
To avoid the added costs and legal obligations of F-Gas, and receive the benefits of HC refrigeration technology, any existing assets operating on HFC gases which are out of warranty, in poor condition and/or 5+ years old should be considered for replacement.
The 2016 Energy Labelling Regulation made it mandatory for manufacturers to publish comparable energy consumption data about their products, allowing operators to benchmark running costs of similar products.
Originally this was limited to solid door/drawer foodservice kitchen refrigerator and freezer products, with labels obtained from individual manufacturer websites.
From March 1, 2021, the product scope was extended to also require labels on glass door retail cabinets and open multideck products.
For existing older and discontinued products, labelling may not exist, so it may be necessary to record energy use directly from equipment in your kitchen, or contact the manufacturer directly for information.
Since 1 January 2019, manufacturers have been required to register applicable products with the European Product Database for Energy Labelling, before selling them on the European market.
From March 2021, new style energy labels will begin to be introduced featuring scannable QR codes to access further product information. Categories will include televisions, dishwashers and household refrigeration, but also commercial ‘Refrigerators with a Direct Sales Function’. In time, all existing labels will undergo a redesign to the new style, at which point they will also feature QR codes linking to EPREL.
The database is the European Commission’s method of ensuring compliance for products which enter into and/or are sold on the European market. In order for a product to be registered and approved, manufacturers must evidence that the product has CE certification and provide test reports from an accredited source which prove the product meets minimum energy and performance standards.
EPREL is not a traditional website you can find through search engines or by typing in a .com or .eu address, nor is it a comparison site where information for multiple products can be easily viewed side-by-side. The scope may be extended in future to add this functionality, but today it is limited to providing individual product information pages, only accessible by scanning the QR code on a new style label.
It is important for consumers to confirm that applicable products have an energy label featuring a QR code which links through to a corresponding page on EPREL. If this cannot be found, then there is no guarantee that the product meets minimum performance standards or has evidenced any of the materials required in order to be lawfully placed on the European market.
The European Energy Labelling Regulation covers many categories of product, and as a result, the transition to the new style of label is something that is planned to occur in phases.
For products categorised as ‘Professional Refrigeration’ (the original labelling requirement introduced 2016), the style of label has not yet changed, and so no QR code or corresponding EPREL page for these products exists yet.
For glass door and multideck commercial refrigeration equipment, the labelling requirement was introduced 1 March 2021, and so the new style label (with QR code) is already applicable.
It should be noted that these types of products can be categorised as either ‘Refrigeration with a Direct Sales Function’ or as ‘Beverage Coolers’ by the manufacturer, with similar looking labels but the huge difference that one is, and one is not, certified for food storage. This is a key point of difference which consumers should be aware of.
Since the UK has now exited the EU, labels for this locality now display a Union Jack flag in the header instead of the Flag of Europe, however the product testing procedures and requirements remain harmonised and can be compared like-for-like.
A point of difference is that the QR code on new style labels displaying the UK flag does not link to EPREL, rather the manufacturers own website, and so the strict additional verification requirements which go along with being published on EPREL also do not apply.
The ‘Professional Refrigerators’ product category applies to various commercial refrigerator and freezer solid door/drawer storage cabinets, commonly used in foodservice kitchen and hospitality settings, including upright and counter units, plus other types such as blast chillers.
It has been a requirement since 2016 that these products meet minimum energy performance standards and carry labels. The EU estimates that regulating these products could create energy savings of 15.6 TWh by 2030 (1 terawatt hour = one billion kilowatt hours).
EN16825:2016 is the European test standard applicable to ‘Professional Refrigerators’ and freezers. It consists of two sequential 24 hour test periods, with energy consumption measured during second 24hr period.
The cabinet is loaded in a specified way with bricks made of “Tylose gel” (a substance which simulates the properties of lean beef). Some of these bricks (referred to as measurement packs or “m-packs”) contain a temperature probe which is attached to test machinery, recording their temperature over the course of the test.
For refrigerators, the door is opened 6 times per hour (for 7 seconds) for 12 hours in a row, and all m-packs must stay within a -1°C to 5°C range at all times to successfully pass.
For freezers, the door is opened 6 times per hour for 7 seconds for the first 4 hours. Then remains closed for 4 hours. Then another 4 hour opening cycle same as the first. All m-packs must stay below -15°C, for the full period in order to successfully pass.
EN16825 tests are performed in special environment chambers which can be set to specific conditions, typically 30°C or 40°C. These ambient temperatures have been selected as being representative of conditions found in some commercial kitchen environments, and are referred to as Regular Duty or “Climate Class 4” and Heavy Duty or “Climate Class 5”. The Climate Class which a product has been tested to is a part of the energy label for ‘Professional Refrigerators’.
The letter grade on the label is called it’s “Energy Efficiency Class” (EEC) and is calculated by taking the amount of energy consumed during a successful EN16825 test at Climate Class 4 and the Net usable capacity, to calculate a numeric figure called the “Energy Efficiency Index” (EEI).
This EEI is then applied against a set table containing acceptable energy ranges and associated letter bandings to determine the EEC of the product. The bandings of the table are designed to change over time, rescaling as the average energy efficiency of new products improves, and so removing the less efficient ones from sale.
|Energy efficiency classes of professional refrigerated storage cabinets
|EEI < 5
|5 ≤ EEI < 10
|10 ≤ EEI < 15
|15 ≤ EEI < 25
|25 ≤ EEI < 30
|35 ≤ EEI < 50
|50 ≤ EEI < 75
|75 ≤ EEI < 85
|85 ≤ EEI < 95
|95 ≤ EEI < 115
|Net Volume (litres)
|24 hr/Energy Consumption (kWh)
|Annual Energy Consumption (kWh)
The result of this testing which is published and visible to consumers is the energy label, which looks like this for ‘Professional Refrigerator’ products:
Climate Class “5” on a label confirms that the product is able to operate efficiently under the “heavy-duty” conditions (40 °C/ 40% Relative Humidity) typical of many commercial kitchens.
Climate Class “4” on a label means the product isn’t guaranteed to be able to operate efficiently in an environment above 30°C.
The EEC letter grade on the label is a quick way to determine the energy efficiency of a product as it compares to others on the market.
Since labels for this product category have not yet transitions, the scale is still ‘A+++ to G’, rather than the ‘A to G’ range which all new style labels have, and there are no QR codes linking to EPREL.
For a more in-depth understanding of what the product will cost your business to operate, the kWh/annum figure from the label can be multiplied by the cost paid per kWh in order to determine a rough annual operating cost, which then can be multiplied up by a number of years. It is not uncommon for quality commercial refrigeration equipment which is properly maintained to have a 10+ year service life.
The ‘Refrigerating Appliances with a Direct Sales Function’ product category includes glass door and “doorless” multideck merchandising coolers and freezers, as well as refrigerated vending machines and ice-cream freezer cabinets.
From March 1, 2021, these products were required to meet minimum energy performance standards and carry energy labels in order to be sold in the European and UK markets. It has been estimated that expanding the product scope of the regulation will lead to additional energy savings of 48 TWh in 2030 (comparable to half of the total energy consumption of Belgium in 2016).
EN23953-2:2015 is the European test standard applicable to ‘Refrigerating Appliances with a Direct Sales Function’. It attempts to simulate real retail conditions by requiring cabinet lighting to be on for 12 hours (service time) and off for 12 hours during a 24-hour period.
The cabinet is loaded in a specified way with bricks made of “Tylose gel”. Some of these bricks (referred to as measurement packs or “m-packs”) contain a temperature probe which is attached to specialist data capture equipment, recording their temperature over the course of the test.
All m-packs must stay within a specified temperature range, but the range can vary depending on the product type:
|Highest temperature of warmest M-package (°C)
|Lowest temperature of coldest M-package (°C)
|Highest temperature of warmest M-package (°C)
|Highest minimum temperature of all M-package (°C)
The Temperature Class which a product has performed to is not stated directly on the product label, however this information is listed on EPREL by scanning the QR code.
The letter grade on the label is called it’s “Energy Efficiency Class” (EEC) and for these products is calculated by taking the amount of energy consumed during a successful EN23953 test and a predefined “standard” figure for the type of product being tested, to calculate a numeric figure called the “Energy Efficiency Index” (EEI).
This EEI is then applied against a set table containing acceptable energy ranges and associated letter bandings to determine the EEC of the product.
|Energy efficiency classes of refrigerating appliances with a direct sales function
|EEI < 10
|10 ≤ EEI < 20
|20 ≤ EEI < 35
|35 ≤ EEI < 50
|50 ≤ EEI < 65
|65 ≤ EEI < 80
|EEI ≥ 80
Unlike the current ‘Professional refrigerators’ letter range, the scale for ‘Refrigerators with a direct sales function’ ranges from A to G, where A is most efficient.
The result of this testing which is published and visible to consumers is the energy label, which looks like this for ‘Refrigerators with a direct sales function’ products:
NOTE: points 6 & 7 are not displayed on labels for freezer products, and points 8 & 9 are not displayed on labels for refrigerator products.
The EEC letter grade on the label is a quick way to determine the energy efficiency of a product as it compares to others on the market.
For a more in-depth understanding of what the product will cost your business to operate, the kWh/annum figure from the label can be multiplied by the cost paid per kWh in order to determine a rough annual operating cost, which then can be multiplied up by a number of years.
As part of the 1 March 2021 labelling requirement for glass door refrigeration equipment, there is also a separate category definition for ‘Beverage Coolers’. When registering glass door products with EPREL, the manufacturer must decide whether to class them as ‘Refrigerators with a direct sales function’ or as ‘Beverage Coolers’. Different testing procedures apply as the intended use is not the same. The label information is also different but similar in appearance.
The big difference between these two product types is that that one is designed, intended and tested to hold perishable food goods, and the other is not.
EN16902 is the European testing standard applicable to ‘Beverage Cooler’ type products and uses 330ml drink cans rather than food simulating Tylose packages. The test also requires no periodic door openings.
As such, the kWh/annum energy use information on ‘Direct Sales Function’ and ‘Beverage Cooler’ labels should also not be compared like-for-like.
Unlike the ‘Direct Sales Function’ label which states the actual high and low temperature range recorded during testing, the single °C figure displayed on the ‘Beverage Coolers’ label is a combined average, the range of which may be outside of food-safe temperatures. Since the product/test is intended for soft drinks, this isn’t an issue, as long as you don’t try to store food in it.
When comparing product labels prior to a purchase, the consumer must be aware of how to spot the difference between these two different but similar looking labels. There is nothing on the label itself to explicitly indicate that one is intended for food storage and one is not, but this is the reality.
If you are intending a buy a refrigerator to store and retail perishable goods, including milk, then it must be a product with a ‘Direct Sales Function’ label and not a ‘Beverage Cooler’. On a distributor e-commerce website, all glass door products (regardless of EPREL classification) may be grouped together on a single page. Consumer vigilance is required.
True’s wide range of glass fronted refrigeration products are designed, tested and approved for the retail merchandising of packaged food products, complying with the ‘Refrigerators with a Direct Sales Function’ requirement. We do not manufacture products specifically for beverage merchandising, although some operators do prefer the superior pull-down and colder holding temperatures of our products for this application.
Whether looking to buy your first cooler, replacing an older model, or just curious about whether you could save money and make a more positive environmental impact by upgrading to newer products, below is a quick guide to the steps you can take to help make an informed choice:
Note: Some refrigeration product types, such as saladettes and other prep tables aren’t currently applicable under the labelling regulation.
True first started testing R290 HC in 2007. Since then, our Natural Refrigeration development initiative has seen the redevelopment of our entire product range.
Our European in-house testing facilities are independently accredited with ISO/IEC 17025, the main ISO standard used by testing and calibration laboratories and is a formal recognition of competence. 17025 is our evidence to customers and the authorities of our ability to consistently produce precise and accurate test results.
Our approach to the advancement of refrigeration technology and commitment to reducing environmental impact are key factors in our being the preferred refrigeration supply partner to many forward thinking and like-minded operators globally.
As a result of this commitment and investment, True now produce several of the most energy efficient commercial refrigeration products currently available on the market.
We are helping operators to be more environmentally responsible, achieve targets to reduce energy consumption, save money, and supplying them with a better, more reliable refrigeration product.
We are Ready. Are you?