Report No 12-11002
January 2012
Wayne Hennessy

Authors
CRL Ref:
Title:
Client Name:
Client Addres s:
Attention:
Date of Issue :
Reviewed By:
Name &
Designation:
Dr T W Matheson
General Manager Operations
Confidentiality Clause:
This report must be quoted in full except with the permission of CRL Energy Ltd.
Published by the Ministry for the Environment – September 2012
Publication No CR 129

1.
Executive Summary ..............................................................4
2.
Introduction ......................................................................5
3.
Methodology ......................................................................5
4.
Air Conditioning and Heat Pump Equipment .................................7
5.
Household Refrigeration Equipment ........................................ 10
6.
Commercial Refrigeration Equipment ...................................... 11
7.
Dehumidifiers .................................................................. 14
8.
Fire Extinguishing Equipment ................................................ 14
9.
Aerosol Cans .................................................................... 15
10.
Acknowledgements ............................................................ 16
11.
References ...................................................................... 16
GLOSSARY
AC
EECA
GHG
GWP
HCFCs
HFCs
IPCC
MEPS
SGG
Air Conditioning
Energy Efficiency and Conservation Authority
Greenhouse Gases
Global Warming Potential
Hydrochlorofluorocarbons
Hydrofluorocarbons (in this context, mainly
-R134a, R404A, R507A for refrigeration equipment)
-R407C and R410A for AC.
Intergovernmental Panel on Climate Change
Minimum Energy Performance Standards
Synthetic Greenhouse Gas
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1.
The purpose of this project is to identify a set of changes to the Working Tariff
Document of New Zealand regarding imported equipment containing SGGs. Policy changes will be proposed so that importers pay a levy to Customs based on Tariff
Document categories instead of being subject to the Emissions Trading Scheme.
2.
Based on CRL Energy’s HFC inventory equipment surveys, on Australian data and on
NZ industry expertise, several new import categories have been proposed, together with default refrigerant charges for levy assessment or assessing some categories by requiring declaration of refrigerant amounts for levy purposes.
3.
CRL Energy recommends that each of the 5 current AC and heat pump equipment import categories be split into 4 single phase cooling capacity categories and each of those into one refrigerant category with HFCs (assumed to be R410A) and one without. There should be two new import categories for three phase AC equipment units (whole units and parts) and each of those split into one refrigerant category with
HFCs and one without.
4.
CRL Energy recommends that each of the 14 current refrigerator and freezer equipment import categories be split into one refrigerant category with HFCs (R134a assumed) and one without.
5.
CRL Energy recommends that new sets of import categories be created for:
 commercial, portable, scientific or medical refrigerators or freezers (five volume categories),
 ice and ice cream makers and
 refrigerated beverage vending machines.
For these and for the current 8418.50.00.01, 8418.50.00.09 and 8418.69.00.00 categories, each set should have one refrigerant category with HFCs, one with HFC-
134a only and one without HFCs (assumed to be R404A).
6.
A new water cooler category should be created and split into one refrigerant category with HFCs and one without. There should be the same treatment for dehumidifiers.
7.
A new set of import categories be created for refrigerated transport units: one refrigerant category with HFCs, one with HFC-134a only and one without HFCs.
Importers should be required to declare refrigerant amounts for levy purposes.
8.
CRL Energy recommends that HFC categories should be added to the classification sections for fire extinguishing equipment and for aerosol cans. This would be useful for inventory purposes and to identify importers and it could provide the basis for a levying alternative.
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Under current legislation for the NZ Emissions Trading Scheme, importers of synthetic greenhouse gases (SGGs
1
) are required to report the amounts imported (as bulk gases or contained in equipment) for 2012. From 2013 they are also required to purchase NZ units equivalent to their imports. The Emissions Trading Scheme Review Panel recommended that an import levy scheme be investigated for SGG equipment as an alternative that would reduce transaction costs.
The purpose of this report is to identify a set of changes to the Working Tariff Document of
New Zealand regarding imported equipment containing SGGs. The content of the report will be used to propose policy changes so that importers pay a levy to the Customs Service based on Tariff Document categories instead of being subject to the Emissions Trading Scheme.
The current content of the Tariff Document is insufficient for that policy purpose.
The report outlines the approach that was used, options that were considered and provides detailed recommendations, including an appendix presenting the recommended changes to the
Working Tariff Document classification codes and levy metrics.
In preparing this report, some discussions were carried out with industry experts and NZ
Customs Service officials to ensure the recommendations are robust in terms of the benefits and costs of various classification and metric options. Public consultation is likely to follow decisions by Ministers on the levy approach to pricing SGGs.
Only SGGs imported in refrigeration and air conditioning equipment, aerosols and fire extinguishers are in the scope of this work. Sulphur hexafluoride imported in electrical switchgear and other goods is excluded from the scope of the work, as are SGGs imported in air conditioning systems of motor vehicles and in insulation foam.
CRL Energy is undertaking this project because of its work in assessing HFC emissions for the National Inventory Report since 2004 (CRL Energy 2011). The methodology was to review the Working Tariff Document classification codes and to collect data on the imports of types and charges of HFC equipment as a basis for recommended classification changes and proposed levy metrics.
Six sets of surveys were reviewed for data on HFC equipment imports and sales. These surveys were designed to estimate the transition from HCFCs to HFCs for commercial refrigeration and particularly for air conditioning equipment. The respondents covered a selection of more than 100 equipment sellers that Energy Efficiency and Conservation
Authority (EECA) maintains sales records for appliance Minimum Energy Performance
1 In the context of this study the SGGs are nearly all hydrofluorocarbons (HFCs): mainly HFC-134a (often known as R134A) and the HFC mixtures R404A, R507A (for refrigeration equipment) and R407C and R410A
(for AC equipment) Perfluorocarbons are minor components of some rarely used refrigerant mixtures..
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Standards (MEPS) regulations 2 . Some of these surveys included average refrigerant charges for different categories and sizes of household refrigeration and AC equipment. For estimating these charges in other equipment, industry experts have been consulted over the last 7 years and further discussions have been undertaken for this study.
For inventory purposes, import statistics from Statistics NZ have been used to estimate import volumes for household refrigerators, freezers and dehumidifiers (with a reasonable degree of certainty) and for stand-alone commercial chillers and freezers, where the quality of the information is very limited because of classification difficulties (CRL Energy 2011).
To identify the wide range of equipment included in the two commercial refrigeration categories, Customs (2011) helpfully provided a spreadsheet of imported equipment descriptions and quantities. By analysing this information, various sub-groups have been characterised as a basis for future import categories.
A DSEWPaC (2011) official has kindly supplied quarterly summaries of 2010 imports of equipment containing HFCs, broken down into 23 equipment and 8 HFC refrigerant categories. Average refrigerant unit charges were calculated for each category and the quarterly variability is discussed in each section below as an indicator of the range of equipment imported into Australia. While noting that the range of NZ imports is likely to be quite different in some categories (because of Australia’s much wider manufacturing base), these figures have been very helpful in developing estimated average refrigerant charges for some NZ equipment imports.
The levying approach of choosing average refrigerant charges for classes of equipment raises inevitable equity questions for sectors where there is reasonably good information on the relationship between refrigerant charges and cooling capacity for the AC sector or internal volume for household refrigerators and freezers. For sectors like commercial refrigeration equipment where there is relatively poor information (mainly because of the diverse range of units), the task of assigning average values is even more difficult because of the risks of overestimating and under-estimating actual refrigerant charge quantities in different types of equipment.
The methodology used here is to separate the commercial refrigeration equipment classes into as many individual equipment types as feasible so that the remaining “other” category is much smaller than the current classification (and equity issues are minimised).
Another equity issue arises from the gradual switching to low GWP alternative HFC refrigerants. The anecdotal evidence from New Zealand and the quantitative evidence from
Australian imports is that usage of these alternative HFCs in pre-charged imports is currently negligible. However, they are likely to increase as they become commercially significant overseas (mainly in Europe initially), so this may be an issue needing to be addressed in about
5 years. In the absence of information about alternatives likely to become commercially significant, it would be very difficult to set import categories currently that reward such innovation by setting low GWP limits for levying purposes.
2 The author is grateful to EECA for providing summaries of these sales records.
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International Customs classification
Customs classifications for refrigeration and AC equipment were reviewed for Australia,
Europe and the US to see if any useful examples could be found for New Zealand. The results were of limited use but they are noted here.
Australian Customs (2012) uses classifications very similar to NZ ones with the following exceptions. AC window/wall units (8415.10) are split by cooling capacity into <3kW, 3-
4kW, 4-5kW and >5kW. The “Other” refrigerating equipment category (8418.69) is split into
“Ice-making machines” and “Other”. The refrigerating equipment parts category (8418.9) is split into “Furniture designed to receive refrigerating or freezing equipment” and “Other”.
European Union Customs (2011) uses classifications very similar to NZ ones with the following exceptions.

Combined refrigerator-freezers (8418.10) and household refrigerators (8418.21) are split into those with a capacity exceeding 340 litres and “other” (together with <250 and 250-340 litre classes for the latter).

Chest freezers (8418.30) are split into <400, 400-800 and >800 litres capacity.

Upright freezers (8418.40) are split into <250, 250-900 and >900 litres capacity.

Other refrigerating furniture (8418.50) is split into “refrigerated showcases and counters”, “for frozen food storage”, “other” and (confusingly)”other refrigerating furniture”.

The refrigerating equipment parts category (8418.9) is split into “Furniture designed to receive refrigerating or freezing equipment” and “Other”(which is further split into
“evaporators and condensers” and “other”).
From January 2011, the USEPA (2012) has required that importers and exporters of fluorinated GHGs contained in pre-charged equipment or closed-cell foams must report the quantity of each fluorinated GHG imported or exported 3 . No information was found on import classification that was useful for this study.
The Working Tariff Document currently uses the following AC import classifications 4

8415.10.10.00 Air conditioning machines; comprising a motor-driven fan and
: elements for changing the temperature and humidity, window or wall types, selfcontained or split-system

8415.81.00.10 Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle (reversible heat pumps)

8415.82.10.00 Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit

8415.90.00.00 Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof
3 The threshold for reporting is a total of 25,000 tonnes of carbon dioxide equivalent imported or exported.
4 Other categories not relevant here are 8415.20 for AC in motor vehicles and 8415.82 for AC equipment not including a refrigerating unit.
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
8418.61.00.10 Heat pumps; other than air conditioning machines of heading no. 8415
(this is considered later in the 8418 section).
With no size breakdown, import statistics for these categories have been found to be of no benefit for inventory purposes. Breaking these classes in terms of equipment size and refrigerant type will have benefits for the National Inventory Report as well as for simplifying
Emissions Trading Scheme compliance.
Single phase equipment
For GHG inventory assessment, AC equipment offers the great advantage that kilowatts (kW) cooling capacity has a high correlation with refrigerant charge. Large scale AC importers appear to have a detailed understanding of the charge types and quantities in their various equipment models but it is not clear if this is true for smaller equipment importers.
CRL Energy assesses that 4 cooling capacity import categories for single phase AC equipment (mainly for households and offices) would provide sufficient accuracy for both inventory purposes and for fairness in terms of an SGG levy. The alternative approach of 4 refrigerant charge categories would not provide any added accuracy or fairness but could be more likely to result in mis-reporting.
DSEWPaC (2011) summaries of 2010 imports of stationary AC equipment containing HFCs are reported in the following categories: refrigerated portable AC, packaged window, packaged air cooled, packaged water cooled, split system single head, split system multihead/variable reverse flow, low and high pressure chillers, other AC, heat pumps other than split system AC, and pre-charged compressors and other parts. There is undoubtedly much value in terms of market research and for energy efficiency purposes in having these more detailed categories but CRL Energy believes for inventory and levying purposes, the cooling capacity and refrigerant type splits are sufficient.
For the sake of simplicity, CRL Energy considers all HFC refrigerants in the AC sector can reasonably be treated as R410A. The refrigerants proportions of chillers sold in Europe
(Eurovent 2012) are 70% R410A, 20% R407C and 10% R134a. The proportions for nonchiller, non-vehicle AC imports into Australia in 2010 were 93% R410A, 4.7% R407C and
1.8% R134a (with 0.1% or less each for R404A, R407A, R407B and R417A).
It is likely that the R410A proportion for smaller AC equipment is even higher in New
Zealand, as is evident in surveys from a selection of importers (with a very small proportion of R407C and no current evidence of R134a)
5
.
CRL Energy recommends that each of the 5 current AC and heat pump equipment import categories above be split into 4 single phase cooling capacity categories and each of those into one refrigerant category with HFCs and one without.
The summary of proposed categories and refrigerant amounts is presented in Appendix A and the justification of individual refrigerant charge amounts for each class is discussed in
Appendix B.
5 The GWP for R410A is 1730, R407C is 12% lower and 25% lower for R134a (CRL Energy 2010).
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Three phase equipment
The situation for three phase AC equipment (mainly for large commercial and industrial sites) is different. There are fewer importers and much fewer units: MEPS sales figures totalled 831 units for the year ended March 2011 compared with 106,000 single phase units
6
(EECA
2011). Chiller equipment has a particularly wide range of refrigerant charges: between 10kg and 2000kg according to IPCC (2006) and Residential and Commercial AC is also considered widely ranging from 0.5kg to 100kg.
Given the wide range of refrigerant charges for the small proportion of units above 50kW cooling capacity, it would be unreasonable to have several 10kW steps above this level.
Therefore, it would be necessary to levy such equipment on a per kilogram basis for each refrigerant. The question is whether all three phase equipment should be treated in the same way (requiring a single import class) or whether an extra 4 import classes could usefully and fairly be developed: <20kW, 20-30kW, 30-40kW and 40-50kW (as well as the individually assessed >50kW one).
There would inevitably be winners and losers with any application of default refrigerant charges so individual levy assessment is a fairer system. However, the differences are likely to be minor and individual assessment would have extra administration costs that importing companies would assess together with the relative value of the levy
7
. Preparing tables of refrigerant levies for Customs authorities and applying them should not be significantly different in terms of government administration costs whether there are five kW import classes or whether individual refrigerant quantities are declared.
There is a more significant fairness issue regarding different shipping methods used by different manufacturers. Temperzone (2011) notes that its equipment exports would be significantly disadvantaged if an overly prescriptive approach was taken for exports and imports: the company installs only a holding charge of 1kg per compressor for its models
>27kW. The current legislation for SGG removals covers the export issue and there is insufficient information to assess whether this would be a significant import issue.
On balance, CRL Energy assesses that just two pairs of import categories (whole units and parts, with and without HFCs) for three phase AC equipment would be the fairest and most practical solution. The requirement to declare refrigerant charge quantities is inevitable for larger equipment (>50kW) and should not result in significant extra transaction costs for importers or for Customs authorities.
CRL Energy recommends that there be two new import categories for three phase AC equipment units (whole units and parts) and each of those split into one refrigerant category with HFCs and one without. Importers should be required to declare refrigerant amounts for levy purposes.
The summary of proposed categories is presented in Appendix A and individual refrigerant charge amounts are discussed in Appendix B.
6 Most of these units are split systems and so consist of two pieces of equipment for import statistics.
7 A 25kW unit (typically worth tens of thousands of dollars) containing say 10kg R410A would be levied $216 if $12.50/tCO
2 e was applied as the effective price cap in 2013 for SGGs (because just 1 NZU is likely to be required for every 2 tonnes CO
2 e emitted). Market prices are currently less than half the price cap.
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The Working Tariff Document currently uses the following refrigerator and freezer import classifications 8 :

8418.10.00.02 Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, less than 200l gross internal capacity

8418.10.00.05 Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 200l and over but less than 300l gross internal capacity

8418.10.00.07 Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 300l and over but less than 400l gross internal capacity

8418.10.00.11 Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 400l and over but less than 500l gross internal capacity

8418.10.00.14 Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 500l and over gross internal capacity

8418.21.00.01 Refrigerators; for household use, compression type, less than 200l gross internal capacity

8418.21.00.03 Refrigerators; for household use, compression type, 200l and over but less than 300l gross internal capacity

8418.21.00.05 Refrigerators; for household use, compression type, 300l and over but less than 400l gross internal capacity

8418.21.00.07 Refrigerators; for household use, compression type, 400l and over but less than 500l gross internal capacity

8418.21.00.12 Refrigerators; for household use, compression type, 500l and over gross internal capacity

8418.30.00.02 Freezers; of the chest type, not exceeding 800l capacity, less than 300l gross internal capacity

8418.30.00.05 Freezers; of the chest type, not exceeding 800l capacity, 300l and over gross internal capacity

8418.40.00.02 Freezers; of the upright type, not exceeding 900l capacity, less than
200l gross internal capacity

8418.40.00.05 Freezers; of the upright type, not exceeding 900l capacity, 200l and over gross internal capacity
Note that only refrigerators are described as for household use. Presumably, combined refrigerator/freezers and freezers could be for commercial, scientific and medical use (as well as household) and so there may be some confusion for importers with the next Commercial
Refrigeration section.
CRL Energy considers for inventory and levying purposes, these size splits are sufficient.
DSEWPaC (2011) summaries of 2010 imports of “domestic refrigerators and freezers” containing HFCs are almost entirely R134a: 1.7% of the 600,000 units contained R410A,
0.7% contained R407C and 0.02% were R404A. CRL Energy’s surveys since 2004 are much
8 Other categories not relevant here in 8418.10 and 8418.29 are for non-compression equipment.
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less comprehensive but have shown the only HFC to be R134a. This is considered sufficient evidence to treat all HFCs in this sector as HFC-134a for inventory and levying purposes.
CRL Energy recommends that each of these 14 current refrigerator and freezer equipment import categories above be split into one refrigerant category with HFCs and one without.
The summary of proposed categories and refrigerant amounts is presented in Appendix A and the justification of individual refrigerant charge amounts for each class is discussed in
Appendix B.
The Working Tariff Document currently uses the following commercial refrigeration and other AC equipment import classifications:

8418.50.00.01 Furniture incorporating refrigerating equipment; for storage and display, other than refrigerators for household use (chests, cabinets, display counters, show-cases and the like)

8418.50.00.09 Furniture incorporating freezing, or refrigerating and freezing, equipment; for storage and display, n.e.c. in item no. 8418.1, 8418.3 or 8418.4 (chests, cabinets, display counters, show-cases and the like)

8418.61.00.10 Heat pumps; other than air conditioning machines of heading no. 8415

8418.69.00.00 Refrigerating or freezing equipment; n.e.c. in heading no. 8418
This set of categories covers a wide range of equipment (as demonstrated below) and is of limited use for inventory or levying purposes. By specifying some of the most common equipment types in proposed new categories, the usefulness for inventory and levying information will be improved and so become a fairer basis for levies as an Emissions Trading
Scheme alternative.
8418.50.00.01 includes refrigerated display cabinets, bar and pharmaceutical fridges, bottle coolers, display coolers, water coolers, espresso coolers, drinks displays, wine chillers and several wrongly classified refrigerator/freezers (that should be in the next category).
8418.50.00.09 includes various types of freezers and refrigerator/freezers, ice cream cabinets, and several wrongly classified refrigerators, refrigerated display cabinets, pizza chillers and wine coolers (that should be in the preceding category).
1500 remote cabinets (EECA 2011) were imported or manufactured in NZ uncharged until installation in supermarket and other systems. The imported ones would have been recorded in the two categories above.
8418.61.00.10 includes air to water and water source heat pumps, swimming pool heat pumps and wrongly classified ice cream makers, water chillers and condensers.
8418.69.00.00 includes water coolers, cooler boxes, medical, mini and bar fridges, beer servers, blast chillers, blood storage cabinets, drink dispenser chillers, cool room base units, commercial kitchen fridges, ice and ice cream makers, fruit juice machines, oil coolers for
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aircraft, excavators and tractors, refrigerated transport units and parts, commercial pizza maker tables and wrongly classified heat pumps and pizza warming bags(!).
Analysis of the 2011 import statistics data for these 4 categories (Customs 2011) showed around 9000, 6700
9
, 1600 and 25,000 units respectively. From the sometimes limited descriptions, CRL Energy assessed how each category might be re-distributed into a wider set of categories:

8418.50.00.01 for refrigerated cooling (or chilling) display cabinets would have contained around 3900 units,

8418.50.00.09 2800 units for freezing display cabinets,

8418.61.00.10 2300 units for various types of heat pumps,

16,100 ice and ice cream makers,

4000 small refrigerators and freezers (including about 200 identified as for scientific or medical purposes),

2800 refrigerated beverage vending machines,

2200 water coolers,

300 refrigerated transport units,

8000 units for the other refrigerated equipment category 8418.69.00.00.
The availability of a category for commercial, portable, scientific or medical refrigerators or freezers (with five volume categories) might have considerably reduced the 8000 units in the
“other” category, although there is a risk that equipment from the first two categories will be mis-reported in the new categories or in the “other” category, especially if the default refrigerant amounts and levies are lower.
DSEWPaC (2011) summaries of 2010 imports of “commercial refrigerated cabinets” containing HFCs were almost entirely R134a (74%) and R404A (25%). For ice and ice cream makers, the similar proportions were 91% and 9% respectively. For refrigerated beverage vending machines (together with post-mix drinks dispensers and water coolers), the similar proportions were 58% and 42% respectively. In the absence of comprehensive NZ data, CRL
Energy considers it reasonable to assume that if equipment in these categories contain HFCs, the refrigerant charge is assumed to be either R134a or R404A for inventory and levying purposes.
CRL Energy recommends that new sets of import categories be created for:
 commercial, portable, scientific or medical refrigerators or freezers (five volume categories),
 ice and ice cream makers and
 refrigerated beverage vending machines.
For these and for the current 8418.50.00.01, 8418.50.00.09 and 8418.69.00.00 categories, each set should have one refrigerant category with HFCs, one with HFC-134a only and one without HFCs (assumed to be R404A).
The summary of proposed categories and refrigerant amounts is presented in Appendix A and the justification of individual refrigerant charge amounts for each class is discussed in
Appendix B.
9 This figure was estimated from 2010 data to fill an information gap. The 2011 data was close to complete, being from January to mid-December.
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Water coolers
DSEWPaC (2011) summaries of 2010 imports of “water coolers” containing HFCs are not differentiated from those of refrigerated beverage vending machines and post-mix drinks dispensers. There is very little NZ data, so CRL Energy has followed advice from an industry expert (Miller 2012) that for office sized water coolers, R134a is likely to be the only the refrigerant and the charge is likely to be very small (around 50 grams). It is unknown whether this category would include larger units but the refrigerant amounts are likely to be of low significance for inventory and levying purposes.
CRL Energy recommends that a new water cooler category be created and split into one refrigerant category with HFCs and one without.
Refrigerated transport
Although refrigerated truck/trailer imports are relatively low in numbers, they contain some of the largest refrigerant charges. DSEWPaC (2011) import data shows that vehicle powered truck refrigerators using R134a are their most numerous category (5600units in 2010) with very low quarterly average refrigerant charges (around 0.08kg). This class also includes less than 100 R404A, R407C and R507A units (0.7, 24, 12kg averages respectively). In the selfpowered truck or trailer refrigerator class, the largest import numbers are for R404A (1000 units) with a 7kg average refrigerant charge, then R134a (110 units, 8kg) and R410A (<20 units, 40kg).
In New Zealand, it is likely that vehicle powered truck refrigerators are not captured in import statistics. The 300 imported refrigerated transport units identified in 2011 is in accord with industry estimates (two main importers) used for inventory purposes. They have advised average refrigerant charges of 10kg R404A (mainly) for up to 120 trailer unit imports annually, 6kg R404A (mainly) for up to 150 self-powered units and 2.5kg R404A or R134a for up to 200 ‘off-engine’ or vehicle powered units.
Two sets of categories could be proposed to cover the smaller and larger units but the
Australian figures suggest the range of refrigerant charges is so wide that default amounts selected on this very limited information would inevitably be very unfair to some importers.
With only two importers responsible for almost all the larger units, CRL Energy considers it would not be difficult for them to declare the refrigerant charge amounts for levy assessment.
There is no information on the number of importers of the smaller vehicle powered units but a requirement to declare the refrigerant charge amounts is likely to be more fair than using a default charge that may be 10 to 100 times larger than the actual amount.
CRL Energy considers that with the Australian evidence showing mainly R134a and R404A imports in this sector (and no evidence of other HFC mixtures in NZ), it would be reasonable to split this reporting category into three for levy purposes: one for no HFCs (some are not pre-charged), one for R134a and one for other HFCs (treated as R404A).
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CRL Energy has suggested a broad definition for refrigerated transport equipment to include trucks, trailers, rail, containers and marine vessels. The definition may need to be narrowed to deal with high volumes of container and vessel traffic in particular.
CRL Energy recommends that a new set of import categories be created for refrigerated transport units: one refrigerant category with HFCs, one with HFC-134a only and one without HFCs. Importers should be required to declare refrigerant amounts for levy purposes.
Other heat pumps
This 8418.61.00.10 category appears out of place alongside all the other refrigeration equipment in 8418, but it would also be out of place in 8415, which is for AC equipment.
DSEWPaC (2011) summaries of 2010 imports of “water cooled packaged AC” and for “heat pumps other than split system AC”. There were 5200 units in the first category containing
HFCs and 89% were R410A while 9% were R417A (and refrigerant charges were similar to those of AC units). There were just 190 units in the second category containing HFCs and
57% were R410A with the remainder R407C, but there was a wide range of quarterly average refrigerant charges: 1.5 to 18kg). CRL Energy considers it is reasonable to treat single phase units in the same way as for the AC units in 8415: four classes based on cooling capacity and all assumed to contain R410A (and any three phase units based on individual refrigerant charges).
CRL Energy recommends that 8418.61.00.10 be treated the same as 8415 AC equipment import categories: split into 4 single phase cooling capacity categories and each of those into one refrigerant category with HFCs and one without. Any three phase units would also be treated in the same way based on individual refrigerant charges.
8479.89.00.41 Machines and mechanical appliances; dehumidifiers has been used for inventory purposes and according to major importer De Longhi (2011), the import statistics are probably a reasonable reflection of the market. Based on their market experience, CRL
Energy has assumed for inventory purposes an average refrigerant charge of 150 grams and
70% use HFC refrigerant (solely R134a).
CRL Energy recommends that 8479.89.00.41
be split into one refrigerant category with
HFCs and one without.
8424 has been used to monitor ozone depleting substances phased out for use in fire extinguishers. Import statistics do not provide numbers of units, only cost including insurance and freight. While three of these categories show zero or low total value from
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2005-2010, 8424.10.00.08 “Fire extinguishers; charged with substances n.e.c. in item no.
8424.10.00” has ranged from $2M to $5M and 8424.10.00.19 “Fire extinguishers; not charged” has steadily increased from <$1M to $3M.
There appear to be no other categories, so it is assumed no distinction is made between portable fire extinguishers and major fire protection systems. Web searches for evidence of
HFC use in portable fire extinguishers revealed nothing except the use of Novec 1230, a fully fluorinated analog of ethyl isopropyl ketone (not HFC).
FM-200 (HFC-227ea) is used in a number of fire protection systems in New Zealand and
CRL Energy obtains import quantities for inventory purposes from the two main importers.
The manufacturers of FM-200 (Chemetron 2012) say it is stored as a liquid in steel containers and super-pressurised with nitrogen to 360psig to increase its discharge flow characteristics.
Website photos show a variety of storage container sizes and a company representative
(Chubb 2012) confirmed that most FM-200 is imported in bulk cylinders with a small proportion in bottles attached to smaller units for say boating purposes. Therefore, CRL
Energy considers it unlikely that default HFC charges or levies could be applied to imported equipment. It is assumed for the inventory (CRL Energy 2011) there are insignificant amounts entering the country from smaller equipment importers but there is no good evidence for this.
Adding an extra category to 8424 for fire extinguishers containing HFCs would be useful for a completeness check for inventory purposes, but only if the measure was in kilograms.
Default HFC charges would not be appropriate but levies could be applied on an individual basis if there is a requirement to declare charge quantities.
CRL Energy recommends that a HFC category should be added to the 8424 section. This would be useful for inventory purposes and to identify minor importers and it could provide the basis for a levying alternative.
The summary of proposed categories and levy rates per kilogram is presented in Appendix A.
The only categories available for aerosol can imports appear to be 7311.00.00.00 “Containers for compressed or liquefied gas, of iron or steel” and 7613.00.00.00 “Aluminium; containers for compressed or liquefied gas”. Steel aerosol can import quantities have ranged from 2100 to 4500 tonnes for 2005 to 2010 (and aluminium ones from 70 to 180 tonnes). If the average gross weight was as low as 0.2kg, these figures would be equivalent to 10-20 million units.
The Aerosol Association of Australia/NZ (2011) has estimated the level of aerosol imports into NZ has been steady at about 20M units for about 10 years. Average gross weights are unknown but it is unlikely that they would vary enough to explain the major annual fluctuations in total gross weight from 2005-2010.
The Aerosol Assn has no data on the proportion of imports that might contain HFCs as a product (mainly blower sprays for electronic equipment) or as a propellant in fire sensitive situations (such as aviation insecticides and underground mining situations). CRL Energy
CRL Energy Limited
Page 15 of 32

(2011) knows of two importers of HFCs in blower sprays but none of those using HFCs as propellants. On that basis it is very approximately assumed for the inventory that 1% of the aerosol can imports contain HFCs. Further characterisation of HFC imports would require access to Customs data on individual importers.
Until there is a better understanding of the range of products containing HFCs, it would be inappropriate to propose default HFC charges. Nevertheless, it would be helpful for inventory and importer identification purposes to split each of these categories into those containing HFCs and those without.
CRL Energy recommends that HFC categories should be added to the 7311 and 7613 sections for aerosol cans. This would be useful for inventory purposes and to identify importers and it could provide the basis for a levying alternative.
The summary of proposed categories and levy rates per kilogram is presented in Appendix A.
The author is very grateful to the numerous survey respondents and others who have given information and advice that have contributed to this report. Patrick McInerney of Australia’s
Department of Sustainability, Environment, Water, Population and Communities (and his team) deserve a particular mention for their very helpful provision of quarterly summary statistics for all the HFC equipment imported into Australia in 2010.
Aerosol Association of Australia/NZ (2011) Personal communication with Philip Fleming regarding aerosol imports from 2002 to 2010.
Australian Customs (2012) Customs Tariff Schedule 3, www.customs.gov.au/webdata/resources/files/HT84BW2012.pdf
Chemetron (2012) www.kiddecanada.com/utcfs/ws-463/Assets/Chemetron%20FM-
200%20Literature.pdf
Chubb (2012) Personal communication with Chris Griffiths about Chubb NZ’s experience of fire protection equipment imported into NZ.
CRL Energy (2010) Methods for Synthetic Greenhouse Gases Regulations, report to the
Ministry for the Environment.
CRL Energy (2011) Inventory of HFC, SF
6
and Other Industrial Process Emissions for New
Zealand 2010, report to the Ministry for the Environment.
CRL Energy Limited
Page 16 of 32

Customs (2011) Personal communication with Saba Vallipuram regarding summaries of refrigeration and AC equipment imported into NZ.
De Longhi (2011) Personal communication with Kevin Laycock regarding De Longhi’s overview of the dehumidifier equipment sector.
DSEWPaC (2011) Personal communication with Patrick McInerney of Australia’s
Department of Sustainability, Environment, Water, Population and Communities Ozone Team regarding quarterly summary statistics provided for all HFC equipment imported into
Australia in 2010.
DSEWPaC (2012) Guide to common types of products imported as pre-charged equipment and gas quantities. www.environment.gov.au/atmosphere/ozone/licences/faq.html
EECA (2011) Personal communication with Ed Winter regarding EECA’s provision of
MEPS sales information summaries for AC and refrigeration unit types and sizes gathered from its surveys from 2004 to 2011.
European Union Customs (2011) Combined Nomenclature on the Common Customs Tariff http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:282:0001:0912:EN:PDF
Eurovent (2012) Eurovent Market Intelligence https://www.eurovent-marketintelligence.eu/
IPCC (2006) 2006 IPCC Guidelines for National Greenhouse Gas Inventories,
Intergovernmental Panel on Climate Change. www.ipcc-nggip.iges.or.jp
Miller P. (2007) Personal communication on Arrow Refrigeration’s assessment of the overall stand-alone commercial cabinet sector.
Miller P. (2012) Personal communication updating Arrow Refrigeration’s assessment of the overall stand-alone commercial cabinet sector.
Skope (2011) Personal communication updating Skope Industries 2006 summary of their manufactured and imported stand-alone commercial refrigeration cabinets.
Temperzone (2011) Personal communication with John Curran providing technical data on
Temperzone Ltd AC equipment models and overall advice on the AC sector.
USEPA (2012) Imports and exports of pre-charged equipment and closed-cell foams containing fluorinated GHGs, Subpart QQ, Mandatory Reporting of Greenhouse Gases, www.epa.gov/climatechange/emissions/downloads/infosheets/ImportsExportsFluorinatedGH
Gs.pdf
CRL Energy Limited
Page 17 of 32

This Appendix sets out the proposed category changes for the Working Tariff Document to identify equipment containing HFCs. Default refrigerant types and charges have been estimated for each HFC category on the basis of the available information (detailed in
Appendix B). For some categories, there is insufficient information and/or there is too wide a range of potential refrigerant charges for a default value, so any levy would have to be based on the equipment’s actual refrigerant charge.
For comparison of relative levy calculations for each equipment type, the refrigerant charge has been multiplied by the Global Warming Potential for the HFC type (or mixture of HFCs)
(CRL Energy 2010) and an indicative market price for CO
2
equivalent. No decisions have been made on levy prices so these dollar values would only be relevant if the levy price was set at $12.50/tCO
2 e , which may be the effective price cap in 2013 for SGGs, based on the ETS Review Panel recommendations (because just 1 NZU is likely to be required for every 2 tonnes CO
2
equivalent emitted). Market prices are currently less than half the price cap.
The proposed lettering and new numbering are for indicative purposes only. If they are accepted, the Customs Service would change them so that they are in accord with the NZ
Harmonized System Classification.
PROPOSED CATEGORIES Assumed
HFC
R410A
Average
Charge
1000
CO
2 equivalent
1.73
Indicative
Levy per
Unit
$21.63 8415.10.10.00A Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity less than or equal to 4kW, containing hydrofluorocarbons
8415.10.10.00B Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity less than or equal to 4kW, not containing hydrofluorocarbons
8415.10.10.00C Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity greater than 4kW and less than or equal to 7kW, containing hydrofluorocarbons
8415.10.10.00D Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity greater than 4kW and less than or equal to 7kW, not containing hydrofluorocarbons
8415.10.10.00E Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity greater than 7kW and less than or equal to 10kW, containing hydrofluorocarbons
R410A
R410A
1500
2500
2.595
4.325
$32.44
$54.06
CRL Energy Limited
Page 18 of 32

PROPOSED CATEGORIES Assumed
HFC
8415.10.10.00F Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity greater than 7kW and less than or equal to 10kW, not containing hydrofluorocarbons
8415.10.10.00G Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity greater than 10kW, containing hydrofluorocarbons
8415.10.10.00H Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, single phase, of cooling capacity greater than 10kW, not containing hydrofluorocarbons
8415.10.10.00I Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, three phase, containing hydrofluorocarbons
8415.10.10.00J Air conditioning machines; comprising a motordriven fan and elements for changing the temperature and humidity, window or wall types, self-contained or split-system, three phase, not containing hydrofluorocarbons
8415.81.00.10A Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity less than or equal to 4kW, containing hydrofluorocarbons
8415.81.00.10B Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity less than or equal to 4kW, not containing hydrofluorocarbons
8415.81.00.10C Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity greater than 4kW and less than or equal to 7kW, containing hydrofluorocarbons
8415.81.00.10D Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity greater than 4kW and less than or equal to 7kW, not containing hydrofluorocarbons
8415.81.00.10E Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity greater than 7kW and less than or equal to 10kW, containing hydrofluorocarbons
8415.81.00.10F Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity greater than 7kW and less than or equal to 10kW, not containing hydrofluorocarbons
R410A
R410A
R410A
R410A
R410A
Average
Charge
(grams)
CO
2 equivalent
(tonnes)
Indicative
Levy per
Unit
3500
1000
1500
2500
6.055
1.73 tonnes per kg
1.73
2.595
4.325
$75.69
$21.63
$32.44
$54.06
CRL Energy Limited
Page 19 of 32

PROPOSED CATEGORIES
8415.81.00.10G Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity greater than 10kW, containing hydrofluorocarbons
8415.81.00.10H Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), single phase, of cooling capacity greater than 10kW, not containing hydrofluorocarbons
8415.81.00.10I Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), three phase, containing hydrofluorocarbons
8415.81.00.10J Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle
(reversible heat pumps), three phase, not containing hydrofluorocarbons
8415.82.10.00A Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity less than or equal to 4kW, containing hydrofluorocarbons
8415.82.10.00B Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity less than or equal to 4kW, not containing hydrofluorocarbons
8415.82.10.00C Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity greater than
4kW and less than or equal to 7kW, containing hydrofluorocarbons
8415.82.10.00D Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity greater than
4kW and less than or equal to 7kW, not containing hydrofluorocarbons
8415.82.10.00E Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity greater than
7kW and less than or equal to 10kW, containing hydrofluorocarbons
8415.82.10.00F Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity greater than
7kW and less than or equal to 10kW, not containing hydrofluorocarbons
8415.82.10.00G Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity greater than
10kW, containing hydrofluorocarbons
8415.82.10.00H Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, single phase, of cooling capacity greater than
10kW, not containing hydrofluorocarbons
Assumed
HFC
R410A
Average
Charge
(grams)
3500
CO
2 equivalent
(tonnes)
6.055
Indicative
Levy per
Unit
$75.69
R410A
R410A
R410A
R410A
R410A
1000
1500
2500
3500
1.73 tonnes per kg
1.73
2.595
4.325
6.055
$21.63
$32.44
$54.06
$75.69
CRL Energy Limited
Page 20 of 32

PROPOSED CATEGORIES Assumed
HFC
8415.82.10.00I Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, three phase, containing hydrofluorocarbons
8415.82.10.00J Air conditioning machines; containing a motor driven fan, other than window or wall types, incorporating a refrigerating unit, three phase, not containing hydrofluorocarbons
8415.90.00.00A Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity less than or equal to 4kW, containing hydrofluorocarbons
8415.90.00.00B Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity less than or equal to 4kW, not containing hydrofluorocarbons
8415.90.00.00C Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity greater than 4kW and less than or equal to 7kW, containing hydrofluorocarbons
8415.90.00.00D Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity greater than 4kW and less than or equal to 7kW, not containing hydrofluorocarbons
8415.90.00.00E Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity greater than 7kW and less than or equal to 10kW, containing hydrofluorocarbons
8415.90.00.00F Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity greater than 7kW and less than or equal to 10kW, not containing hydrofluorocarbons
8415.90.00.00G Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity greater than 10kW, containing hydrofluorocarbons
8415.90.00.00H Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for single phase units of cooling capacity greater than 10kW, not containing hydrofluorocarbons
8415.90.00.00I Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for three phase units, containing hydrofluorocarbons
8415.90.00.00J Air conditioning machines; with motor driven fan and elements for temperature control, parts thereof, for three phase units, not containing hydrofluorocarbons
8418.10.00.02A Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, less than 200l gross internal capacity, containing hydrofluorocarbons
8418.10.00.02B Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, less than 200l gross internal capacity, not containing hydrofluorocarbons
8418.10.00.05A Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 200l and over but less than 300l gross internal capacity, containing hydrofluorocarbons
R410A
R410A
R410A
R410A
R410A
R410A
HFC-134a
HFC-134a
Average
Charge
(grams)
CO
2 equivalent
(tonnes)
1.73 tonnes per kg
Indicative
Levy per
Unit
1000
1500
2500
3500
100
110
1.73
2.595
4.325
6.055
1.73 tonnes per kg
0.13
0.143
$21.63
$32.44
$54.06
$75.69
$1.63
$1.79
CRL Energy Limited
Page 21 of 32

PROPOSED CATEGORIES Assumed
HFC
Average
Charge
(grams)
CO
2 equivalent
(tonnes)
Indicative
Levy per
Unit
8418.10.00.05B Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 200l and over but less than 300l gross internal capacity, not containing hydrofluorocarbons
8418.10.00.07A Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 300l and over but less than 400l gross internal capacity, containing hydrofluorocarbons
8418.10.00.07B Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 300l and over but less than 400l gross internal capacity, not containing hydrofluorocarbons
8418.10.00.11A Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 400l and over but less than 500l gross internal capacity, containing hydrofluorocarbons
8418.10.00.11B Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 400l and over but less than 500l gross internal capacity, not containing hydrofluorocarbons
8418.10.00.14A Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 500l and over gross internal capacity, containing hydrofluorocarbons
8418.10.00.14B Refrigerators and freezers; combined refrigerator freezers, fitted with separate external doors, compression type, 500l and over gross internal capacity, not containing hydrofluorocarbons
8418.21.00.01A Refrigerators; for household use, compression type, less than 200l gross internal capacity, containing hydrofluorocarbons
8418.21.00.01B Refrigerators; for household use, compression type, less than 200l gross internal capacity, not containing hydrofluorocarbons
8418.21.00.03A Refrigerators; for household use, compression type, 200l and over but less than 300l gross internal capacity, containing hydrofluorocarbons
8418.21.00.03B Refrigerators; for household use, compression type, 200l and over but less than 300l gross internal capacity, not containing hydrofluorocarbons
8418.21.00.05A Refrigerators; for household use, compression type, 300l and over but less than 400l gross internal capacity, containing hydrofluorocarbons
8418.21.00.05B Refrigerators; for household use, compression type, 300l and over but less than 400l gross internal capacity, not containing hydrofluorocarbons
8418.21.00.07A Refrigerators; for household use, compression type, 400l and over but less than 500l gross internal capacity, containing hydrofluorocarbons
8418.21.00.07B Refrigerators; for household use, compression type, 400l and over but less than 500l gross internal capacity, not containing hydrofluorocarbons
8418.21.00.12A Refrigerators; for household use, compression type, 500l and over gross internal capacity, containing hydrofluorocarbons
CRL Energy Limited
HFC-134a
HFC-134a
HFC-134a
HFC-134a
HFC-134a
HFC-134a
HFC-134a
HFC-134a
120
130
150
70
90
100
110
130
0.156
0.169
0.195
0.091
0.117
0.13
0.143
0.169
$1.95
$2.11
$2.44
$1.14
$1.46
$1.63
$1.79
$2.11
Page 22 of 32

PROPOSED CATEGORIES Assumed
HFC
Average
Charge
(grams)
CO
2 equivalent
(tonnes)
8418.21.00.12B Refrigerators; for household use, compression type, 500l and over gross internal capacity, not containing hydrofluorocarbons
8418.30.00.02A Freezers; of the chest type, not exceeding 800l capacity, less than 300l gross internal capacity, containing hydrofluorocarbons
8418.30.00.02B Freezers; of the chest type, not exceeding 800l capacity, less than 300l gross internal capacity, not containing hydrofluorocarbons
8418.30.00.05A Freezers; of the chest type, not exceeding 800l capacity, 300l and over gross internal capacity, containing hydrofluorocarbons
8418.30.00.05B Freezers; of the chest type, not exceeding 800l capacity, 300l and over gross internal capacity, not containing hydrofluorocarbons
8418.40.00.02A Freezers; of the upright type, not exceeding 900l capacity, less than 200l gross internal capacity, containing hydrofluorocarbons
8418.40.00.02B Freezers; of the upright type, not exceeding 900l capacity, less than 200l gross internal capacity, not containing hydrofluorocarbons
8418.40.00.05A Freezers; of the upright type, not exceeding 900l capacity, 200l and over gross internal capacity, containing hydrofluorocarbons
8418.40.00.05B Freezers; of the upright type, not exceeding 900l capacity, 200l and over gross internal capacity, not containing hydrofluorocarbons
8418.50.00.01A* Furniture incorporating refrigerating equipment; for storage and display, other than refrigerators for household use (chests, cabinets, display counters, show-cases and the like), containing only HFC-134a
8418.50.00.01B Furniture incorporating refrigerating equipment; for storage and display, other than refrigerators for household use
(chests, cabinets, display counters, show-cases and the like), containing hydrofluorocarbons
8418.50.00.01C Furniture incorporating refrigerating equipment; for storage and display, other than refrigerators for household use
(chests, cabinets, display counters, show-cases and the like), not containing hydrofluorocarbons
8418.50.00.09A* Furniture incorporating freezing, or refrigerating and freezing, equipment; for storage and display, n.e.c. in item no. 8418.1, 8418.3 or 8418.4 (chests, cabinets, display counters, show-cases and the like), containing only HFC-
134a
8418.50.00.09B Furniture incorporating freezing, or refrigerating and freezing, equipment; for storage and display, n.e.c. in item no.
8418.1, 8418.3 or 8418.4 (chests, cabinets, display counters, show-cases and the like), containing hydrofluorocarbons
8418.50.00.09C Furniture incorporating freezing, or refrigerating and freezing, equipment; for storage and display, n.e.c. in item no.
8418.1, 8418.3 or 8418.4 (chests, cabinets, display counters, show-cases and the like), not containing hydrofluorocarbons
HFC-134a
HFC-134a
HFC-134a
HFC-134a
HFC-134a
R404A
400
HFC-134a 400
R404A
140
180
80
110
600
1000
0.182
0.234
0.104
0.143
0.52
1.956
0.52
3.26
Indicative
Levy per
Unit
$2.28
$2.93
$1.30
$1.79
$6.50
$24.45
$6.50
$40.75
CRL Energy Limited
Page 23 of 32

PROPOSED CATEGORIES Assumed
HFC
HFC-134a
Average
Charge
(grams)
100
CO
2 equivalent
(tonnes)
0.13
Indicative
Levy per
Unit
$1.63 8418.50.00.11A Commercial, portable, scientific or medical refrigerators or freezers, less than 200l gross internal capacity, containing only HFC-134a
8418.50.00.11B Commercial, portable, scientific or medical refrigerators or freezers, less than 200l gross internal capacity, containing hydrofluorocarbons
8418.50.00.11C Commercial, portable, scientific or medical refrigerators or freezers, less than 200l gross internal capacity, not containing hydrofluorocarbons
8418.50.00.11D Commercial, portable, scientific or medical refrigerators or freezers, 200l and over but less than 300l gross internal capacity, containing only HFC-134a
8418.50.00.11E Commercial, portable, scientific or medical refrigerators or freezers, 200l and over but less than 300l gross internal capacity, containing hydrofluorocarbons
8418.50.00.11F Commercial, portable, scientific or medical refrigerators or freezers, 200l and over but less than 300l gross internal capacity, not containing hydrofluorocarbons
8418.50.00.11G Commercial, portable, scientific or medical refrigerators or freezers, 300l and over but less than 400l gross internal capacity, containing only HFC-134a
8418.50.00.11H Commercial, portable, scientific or medical refrigerators or freezers, 300l and over but less than 400l gross internal capacity, containing hydrofluorocarbons
8418.50.00.11I Commercial, portable, scientific or medical refrigerators or freezers, 300l and over but less than 400l gross internal capacity, not containing hydrofluorocarbons
8418.50.00.11J Commercial, portable, scientific or medical refrigerators or freezers, 400l and over but less than 500l gross internal capacity, containing only HFC-134a
8418.50.00.11K Commercial, portable, scientific or medical refrigerators or freezers, 400l and over but less than 500l gross internal capacity, containing hydrofluorocarbons
8418.50.00.11L Commercial, portable, scientific or medical refrigerators or freezers, 400l and over but less than 500l gross internal capacity, not containing hydrofluorocarbons
8418.50.00.11M Commercial, portable, scientific or medical refrigerators or freezers, 500l and over gross internal capacity, containing only HFC-134a
8418.50.00.11N Commercial, portable, scientific or medical refrigerators or freezers, 500l and over gross internal capacity, containing hydrofluorocarbons
8418.50.00.11O Commercial, portable, scientific or medical refrigerators or freezers, 500l and over gross internal capacity, not containing hydrofluorocarbons
8418.50.00.12A Refrigerated beverage vending machines, containing only HFC-134a
8418.50.00.12B Refrigerated beverage vending machines, containing hydrofluorocarbons
8418.50.00.12C Refrigerated beverage vending machines, not containing hydrofluorocarbons
8418.50.00.13A Water coolers, containing hydrofluorocarbons
8418.50.00.13B Water coolers, not containing hydrofluorocarbons
R404A
HFC-134a
R404A
HFC-134a
R404A
HFC-134a
R404A
HFC-134a
R404A
HFC-134a
R404A
HFC-134a
100
110
110
120
120
130
130
150
150
200
200
50
0.326
0.143
0.359
0.156
0.391
0.169
0.424
0.195
0.489
0.26
0.652
0.065
$4.08
$1.79
$4.48
$1.95
$4.89
$2.11
$5.30
$2.44
$6.11
$3.25
$8.15
$0.81
CRL Energy Limited
Page 24 of 32

PROPOSED CATEGORIES Assumed
HFC
8418.50.00.14A Ice and ice cream making machines, containing only HFC-134a
8418.50.00.14B Ice and ice cream making machines, containing hydrofluorocarbons
8418.50.00.14C Ice and ice cream making machines, not containing hydrofluorocarbons
8418.50.00.15A Refrigerated transport equipment, including refrigeration units for trucks, trailers, rail, containers and marine vessels, containing only HFC-134a
8418.50.00.15B Refrigerated transport equipment, including refrigeration units for trucks, trailers, rail, containers and marine vessels, containing hydrofluorocarbons
8418.50.00.15C Refrigerated transport equipment, including refrigeration units for trucks, trailers, rail, containers and marine vessels, not containing hydrofluorocarbons*
8418.61.00.10A Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity less than or equal to 4kW, containing hydrofluorocarbons
8418.61.00.10B Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity less than or equal to 4kW, not containing hydrofluorocarbons
8418.61.00.10C Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity greater than 4kW and less than or equal to 7kW, containing hydrofluorocarbons
8418.61.00.10D Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity greater than 4kW and less than or equal to 7kW, not containing hydrofluorocarbons
8418.61.00.10E Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity greater than 7kW and less than or equal to 10kW, containing hydrofluorocarbons
8418.61.00.10F Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity greater than 7kW and less than or equal to 10kW, not containing hydrofluorocarbons
8418.61.00.10G Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity greater than 10kW, containing hydrofluorocarbons
8418.61.00.10H Heat pumps; other than air conditioning machines of heading no. 8415, single phase, of cooling capacity greater than 10kW, not containing hydrofluorocarbons
8418.61.00.10I Heat pumps; other than air conditioning machines of heading no. 8415, three phase, containing hydrofluorocarbons
8418.61.00.10J Heat pumps; other than air conditioning machines of heading no. 8415, three phase, not containing hydrofluorocarbons
8418.69.00.00A Refrigerating or freezing equipment; n.e.c. in heading no. 8418, containing only HFC-134a
8418.69.00.00B Refrigerating or freezing equipment; n.e.c. in heading no. 8418, containing hydrofluorocarbons
8418.69.00.00C Refrigerating or freezing equipment; n.e.c. in heading no. 8418, not containing hydrofluorocarbons
HFC-134a
R404A
HFC-134a
R404A
R410A
R410A
R410A
R410A
R410A
HFC-134a
R404A
Average
Charge
(grams)
300
CO
2 equivalent
(tonnes)
0.39
Indicative
Levy per
Unit
$4.88
300
1000
1500
2500
3500
400
600
0.978
1.3 tonnes per kg
3.26 tonnes per kg
1.73
2.595
4.325
6.055
1.73 tonnes/kg
0.52
1.956
$12.23
$21.63
$32.44
$54.06
$75.69
$6.50
$24.45
CRL Energy Limited
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PROPOSED CATEGORIES Assumed
HFC
HFC-
227ea
HFC-134a
Average
Charge
(grams)
CO
2 equivalent
(tonnes)
2.9 tonnes per kg
0.195
1.3 tonnes per kg
Indicative
Levy per
Unit
8424.10.00.08A Fire extinguishers; charged with hydrofluorocarbons
8479.89.00.41A Machines and mechanical appliances; dehumidifiers, containing hydrofluorocarbons
8479.89.00.41B Machines and mechanical appliances; dehumidifiers, not containing hydrofluorocarbons
7311.00.00.00A Containers for compressed or liquefied gas, of iron or steel, containing hydrofluorocarbons
7311.00.00.00B Containers for compressed or liquefied gas, of iron or steel, not containing hydrofluorocarbons
7613.00.00.00A Aluminium; containers for compressed or liquefied gas, containing hydrofluorocarbons
7613.00.00.00B Aluminium; containers for compressed or liquefied gas, not containing hydrofluorocarbons
HFC-134a
HFC-134a
150
1.3 tonnes per kg
* The current pair of definitions for 8418.5 have been retained, but they may need to be defined more narrowly to avoid confusion with the proposed additional categories in 8418.5. They could instead be defined as
Refrigerated Display Cooling Units and Refrigerated Display Freezing Units respectively.
** This definition is very wide but may need to be narrowed to deal with high volumes of container and vessel traffic in particular.
$2.44
CRL Energy Limited
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Air Conditioning and Heat Pump Equipment – single phase
Refrigerant charge data provided by AC equipment suppliers for CRL Energy (2011) inventory surveys over the last seven years were collated for this study. For several years some major suppliers (Fujitsu has been particularly helpful) have provided average charges for all of their models in the <4kW, 4-8kW, 8-12kW and >12kW in the window/wall, split non-ducted and split ducted single phase systems (as well as various three phase models).
Several others have provided data for individual models for one or two years (Daikin provided data on a wide range of models for 2007 and averaged data for 2010). Technical data sheets on a wide range of units were obtained from Mitsubishi Heavy Industries’ website.
With very few single phase models in the >12kW range, it is more useful (allowing more accurate estimation) to have narrower ranges: <4kW, 4-7kW, 7-10kW and >10kW.
DSEWPaC (2011) summaries of 2010 imports of stationary AC equipment containing HFCs are reported in several categories for each refrigerant type. There is no size split but the differences in quarterly average charges for each significant refrigerant are a useful measure of variability for each equipment type:
 refrigerated portable AC ranged from 0.3-0.6kg R410A (mean 0.56kg vs 0.45kg
R407C);
 packaged window AC ranged from 0.7-0.8kg R410A (mean 0.76kg vs 0.63kg R134a);
 air cooled AC ranged from 0.5-9.5kg R410A (mean 2.9kg vs 0.9kg R407C );
 water cooled AC ranged from 1.2-1.4kg R410A (mean 1.3kg );
 split system single head AC ranged from 1.7-2.0kg R410A (mean 1.7kg );
 split system multi-head AC ranged from 4.7-5.0kg R410A (mean 4.9kg );
 low pressure chillers ranged from 21-35kg R410A (mean 26kg vs 102kg R134a);
 high pressure chillers ranged from 6-93kg R410A (mean 11kg vs 253kg R134a);
 other AC ranged from 0.6-3.6kg R410A (mean 1.0kg vs 0.8kg R407C ); and
 heat pumps other than split system AC ranged from 2.8-13kg R410A (mean 3.0kg ).
Setting aside chillers and multi-head AC (probably all three phase), it can be concluded that refrigerated portable and packaged window AC have somewhat lower average refrigerant charges than packaged air cooled and water cooled systems and single head split systems and other AC. However, the widespread ranges of average charges underline the difficulties associated with setting default averages.
CRL Energy has collated the NZ information available for each of the four cooling capacity ranges. A major limitation for this exercise was the lack of sales data to appropriately weigh the averages of large against small importers and to weigh the data from importers providing detailed data for each model with those with little or no data. Despite this limitation, the assigned averages for all types of equipment in each size range present a consistent series that forms a good basis for levying purposes:
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
<4kW : 22 sets of models had a mean of 1.03kg R410A, with 95% of them
10
ranging from 0.45-1.68kg;

4-7kW : 35 sets of models had a mean of 1.57kg R410A, with 95% of them ranging from 0.77-2.38kg;

7-10kW : 27 sets of models had a mean of 2.73kg R410A, with 95% of them ranging from 1.53-3.93kg;

>10kW : 14 sets of models had a mean of 3.64kg R410A, with 95% of them ranging from 3.20-4.08kg;
For the sake of simplicity, CRL Energy considers all HFC refrigerants in the AC sector can reasonably be treated as R410A. From inventory surveys (CRL Energy 2011), there were rare examples of R407C equipment imports but responses from importers were incomplete so coverage of the AC sector was limited. Anecdotal evidence from installers suggested that
R407C imports were more common from 2000-2005, before R410A took over from the
HCFC R22 as the dominant AC refrigerant.
Air Conditioning and Heat Pump Equipment – three phase
For three phase units, Temperzone (2011) provided very helpful technical information on its wide range of mainly large commercial/industrial equipment (and the even larger Hitachi units the company distributes). Johnson Controls Australia/York supplied information on some large water chiller units (as well as its smaller single phase models). Its website technical data covers a wide range of industrial chillers containing up to 400kg of refrigerant
(in this case R134a). DSEWPaC (2011) quarterly averaged data for 2010 shows evidence of some imports of such large chillers but it is not known if there are any similar units used in
New Zealand.
Default refrigerant charges could be estimated for several cooling capacity size ranges but this would need to be done for a range of different technologies. For the reasons explained in the main text, CRL Energy assesses that just two pairs of import categories (whole units and parts, with and without HFCs) for three phase AC equipment would be the fairest and most practical solution. There would be a requirement to declare refrigerant charge quantities for levy purposes.
Household Refrigeration Equipment
Refrigerant charge data provided by refrigerator and freezer equipment suppliers for CRL
Energy (2011) inventory surveys over the last seven years were collated for this study. For several years some major suppliers (Fisher & Paykel and Electrolux/Simpson have been particularly helpful) have provided average charges for their models in the various volume categories. Several other importers have provided data for individual models for one or two years.
DSEWPaC (2011) summaries of 2010 imports of “domestic refrigerators and freezers” containing HFCs are reported for each refrigerant type. There is no size split but the differences in quarterly average charges for each significant refrigerant are a useful measure of variability. They ranged from 0.13-0.15kg R134a with a mean of 0.14kg. 98% of the HFC units contained R134a while the remainder was split between R410A and R407C.
10 Representing within two standard deviations of the mean to avoid highlighting outlying values).
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CRL Energy has collated the NZ information available for each of the equipment types and volume ranges. The only categories where there were significant differences among major importers were for chest freezers, with a range of +20% about the mean values for the two volume categories. The assigned averages for the equipment in each size range present a consistent series that forms a good basis for levying purposes.
For the sake of simplicity, CRL Energy considers all HFC refrigerants in this sector can reasonably be treated as R134a. From inventory surveys (CRL Energy 2011), there were no examples of other HFC equipment imports.
Commercial Refrigerated Chilling and Freezing Display Cabinets
For inventory purposes, CRL Energy (2011) has relied on an industry overview (Miller 2007) and on detailed data helpfully provided by Skope Industries in 2006 summarising the company’s manufactured and imported stand-alone commercial chilling and freezing cabinets. For the current study, CRL Energy obtained updated information from Miller
(2012) and Skope (2011), which has consented to publishing Figure 1 & 2 below.
The production weighted averages for Skope’s R134a and R404A cabinets were
0.47kg and
1.02kg
respectively (very close to the 2004-2005 averages of 0.44kg and 1.18kg).
However, Miller’s updated figures (2012) (including 2000 display units for frozen confectionery and a wide variety of chillers and freezers) were somewhat lower, and these are likely to be more typical of wide range of display units in the commercial refrigeration sector.
Miller’s figures for R134a units (including both chillers and freezers) averaged
0.18kg
with a range of 0.04-0.50kg. R404A units (including both chillers and freezers) averaged 0.65kg
with a range of 0.51-1.8kg. In 2007, he recommended for the wide range of equipment in the industry average charges of 0.45kg R134a and 0.30kg R404A and these have been used for inventory purposes.
In the absence of more comprehensive information, this presents a difficult situation to recommend average refrigerant charges for levying purposes. Given that 70% of Skope’s production is exported and that many smaller display units are not captured by MEPS reporting, CRL Energy has estimated averages of 0.4kg for R134a chilling and freezing units and 0.6kg for R404A chilling units, but 1.0kg for R404A freezing units . These estimates should be considered to have a moderate degree of uncertainty compared with the relatively low uncertainties for AC and household refrigeration equipment.
For comparison, DSEWPaC (2011) summaries of 2010 imports of “commercial refrigerated cabinets” containing HFCs are reported for each refrigerant type. There is no size split but the differences in quarterly average charges for each refrigerant are a useful measure of variability. They ranged from 0.23-0.41kg R134a with a mean of 0.26kg and for R404A ranged from 0.51-1.83kg with a mean of 0.64kg. The SGG import reporting website
(DSEWPaC 2012) suggests that a typical refrigerant amount in a commercial refrigerated cabinet is 1.3kg R404A while for an ice cream cabinet it is 0.5kg R404A.
CRL Energy Limited
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Figures 1&2 – Unit Refrigerant Charges for Skope Cabinets in 2011
50%
20%
15%
10%
5%
0%
45%
40%
35%
30%
25%
< 0.1 0.1 - 0.2 0.2 - 0.3 0.3 - 0.4 0.4 - 0.5 0.5 - 0.6 0.6 - 0.7 0.7 - 0.8 0.8 - 0.9 0.9 - 1.0 > 1.0
30%
25%
20%
15%
10%
5%
45%
40%
35%
0%
< 0.4 0.4 -
0.5
0.5 -
0.6
0.6 -
0.7
0.7 -
0.8
0.8 -
0.9
0.9 -
1.0
1.0 -
1.1
1.1 -
1.2
1.2 -
1.3
1.3 -
1.4
1.4 -
1.5
1.5 -
1.6
> 1.6
CRL Energy Limited
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Ice and Ice Cream Makers
With about two thirds of New Zealand’s “other refrigeration” units appearing to come under this proposed import category, it would be an important means of reducing uncertainty in assigning average refrigerant charges for levying purposes. However, there is very little information on equipment size ranges or refrigerant charges.
An importer of Hoshizaki icemakers stated the average refrigerant charge for their units was
0.23kg of R404A
11
. A web search of a range of about 20 used ice cream and ice making machines included just one ice cream maker whose technical data sheet included the refrigerant quantity of 1.02kg R404A.
DSEWPaC (2011) summaries of 2010 imports of “ice and ice cream making machines” containing HFCs are reported for each refrigerant type. They ranged from 0.08-0.20kg for
R134a (91% of units) with a mean of 0.08kg while for the remaining R404A units the range was 0.62-14kg with a mean of 1.4kg. The SGG import reporting website (DSEWPaC 2012) suggests that a typical refrigerant amount in ice makers and ice cream makers is 0.3kg
R404A.
In view of these widespread ranges for Australian equipment and practically no data for New
Zealand, CRL Energy has recommended 0.3kg for the average refrigerant charge for both
R134a and for R404A equipment.
Refrigerators and Freezers for Commercial, Portable, Scientific or Medical Use
Adopting this proposed new set of categories would account for at least 4000 smaller commercial and portable refrigerators and freezers that would otherwise be over-estimated in a general category. In the absence of better information, refrigerant charges for the five volume categories are assumed to be the same as for household combined refrigerator/freezers.
DSEWPaC (2011) summaries of 2010 imports of “commercial portable refrigerators” containing HFCs are reported for each refrigerant type. They ranged from 0.046-0.061kg for
R134a (85% of units) with a mean of 0.054kg while for R410A (12% of units) the mean was ten times higher at 0.53kg. The SGG import reporting website (DSEWPaC 2012) suggests that a typical refrigerant amount for a portable fridge is 0.07kg R134a and for a vehicle powered fridge 0.05kg R134a.
Refrigerated Beverage Vending Machines
Adopting this proposed new category would account for 2800 refrigerated beverage vending machines that would otherwise be over-estimated in a general category. There was a very limited amount of information about refrigerant charges, suggesting 0.15-0.2kg of R134a so
CRL Energy has recommended default amounts of 0.2kg of either R134a or R404A.
DSEWPaC (2011) summaries of 2010 imports of “post-mix drinks/vending machines, frozen carbonated drink machines and water coolers” containing HFCs are reported for each refrigerant type. The quarterly averages ranged from 0.10-0.39kg for R134a (58% of units)
11 Technical data on the Hoshizaki website and another for Scotsman equipment did not contain any refrigerant amounts.
CRL Energy Limited
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with a mean of 0.17kg while for R404A (42% of units) the mean was 1.1kg for this wide range of equipment types. More usefully, the SGG import reporting website (DSEWPaC
2012) suggests that a typical refrigerant amount for a vending machine is 0.3kg R134a.
Water Coolers
Adopting this proposed new category would account for 2200 refrigerated beverage vending machines that would otherwise be over-estimated in a general category. There was a very limited amount of information about refrigerant charges, suggesting about 0.04-0.1kg of
R134a so CRL Energy has recommended a default amount of 0.05kg of R134a.
Refrigerated Transport Units
Although refrigerated truck/trailer unit imports are relatively low in numbers, they contain some of the largest refrigerant charges. CRL Energy considers it would not be difficult for importers to declare the refrigerant charge amounts for levy assessment.
The Australian SGG import reporting website (DSEWPaC 2012) suggests that a typical refrigerant amount for a refrigerated delivery van (under 3.5 tonne) is 0.9kg R134a while for a larger truck (over 3.5 tonne) it is 1.6kg R134a. This would contradict the industry expert information for NZ that the main refrigerant is R404A and charges are 2.5kg and 6-10kg respectively.
Other Refrigerated Equipment
In the absence of information about other equipment remaining in this category, CRL Energy recommends the same default charges that were recommended for commercial refrigerated chillers: 0.4kg for R134a units and 0.6kg for R404A units.
Heat Pumps other than AC Equipment
CRL Energy recommends the same default charges that were suggested for single phase AC equipment, based on cooling capacity or the equivalent. Three phase equipment would be treated the same as similar AC equipment.
Fire Extinguishing Equipment
CRL Energy considers it unlikely that default HFC charges or levies could be applied to imported equipment, so there should be a requirement to declare HFC types and quantities for levy assessment.
Aerosol Cans
CRL Energy considers it unlikely that default HFC charges or levies could be applied to imported equipment, so there should be a requirement to declare HFC types and quantities for levy assessment.
CRL Energy Limited
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