A guide to synthetic greenhouse gas
activities in the New Zealand
Emissions Trading Scheme: 2013
This report may be cited as:
Ministry for the Environment. 2013. A guide to synthetic greenhouse gas activities in the New
Zealand Emissions Trading Scheme: 2013. Wellington: Ministry for the Environment.
Published in January 2013 by the
Ministry for the Environment
Manatū Mō Te Taiao
PO Box 10362, Wellington 6143, New Zealand
ISBN: 978-0-478-37296-0 (electronic)
Publication number: ME 1108
© Crown copyright New Zealand 2013
This document is available on the Ministry for the Environment’s website:
www.mfe.govt.nz
Contents
1
Overview
1
2
Registering as a participant
3
3
About the regulations
4
4
Importing bulk perfluorocarbons (PFCs) and hydrofluorocarbons
(HFCs)
5
5
Exporting HFC or PFC in bulk or in goods and motor vehicles
7
6
Manufacturing HFC or PFC in New Zealand
10
7
Destroying HFC or PFC in New Zealand
12
8
Large users of sulphur hexafluoride (SF6)
14
9
Record keeping and references
15
A guide to synthetic greenhouse gas activities in the NZ ETS: 2013
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1
Overview
Regulations for reporting synthetic greenhouse gas (SGG) emissions under the New Zealand
Emissions Trading Scheme (NZ ETS) came into force from 1 January 2011. The Climate Change
(Emissions Trading and Other Matters) Amendment Act 2012 made a number of changes to
these obligations. This guide outlines the obligations for SGGs in the NZ ETS.
SGGs include sulphur hexafluoride (SF6), perfluorocarbons (PFCs) and hydrofluorocarbons
(HFCs).
Persons who manufacture or import HFC or PFC in bulk are required to participate in the NZ
ETS. These participants are required to collect certain data to calculate and report on the
greenhouse gas emissions associated with certain activities from 1 January 2013. The details of
these obligations are set out in the Climate Change (Stationary Energy and Industrial
Processes) Regulations 2009.
Persons who use SF6 in operating electrical equipment, and who are above the prescribed
threshold, are required to participate in the NZ ETS. These participants are required to collect
certain data to calculate and report on the greenhouse gas emissions associated with certain
activities from 1 January 2013. The details of these calculation methods are set out in the
Climate Change (Stationary Energy and Industrial Processes) Amendment Regulations 2012.
The details of the prescribed threshold are set out in the Climate Change (General Exemptions)
Amendment Order (No 2) 2012.
Persons who destroy or export HFC or PFC, either in bulk or in equipment, and who meet the
eligibility criteria can choose to participate in the NZ ETS. The calculation of emissions
‘removed’ from those activities must be carried out in accordance with the Climate Change
(Other Removal Activities) Regulations 2009 and Climate Change (Other Removal Activities)
Amendment Regulations 2012.
Persons who import HFC or PFC in goods and motor vehicles will be covered under a levy
starting 1 July 2013. Guidance on how to comply with the levy will be available by 1 July 2013.
This guide is intended to help people who import, manufacture, export, or destroy SGGs in the
tasks of:

registering as participants

making use of the available lead time to develop systems and to minimise future NZ ETS
costs by improving the accuracy of emissions reporting

meeting the mandatory reporting and surrender obligations these regulations will place
on SGG importers, users and manufacturers.
This guide is intended as general guidance only and is not legal advice. For more detailed
information you should read the Act and the regulations referred to in this guide. For
information about your specific legal obligations, please consult your legal advisors.
A guide to synthetic greenhouse gas activities in the NZ ETS: 2013
1
Under the transition phase measures, participants are only required to surrender one emission
unit (or awarded for removal activities) for every two whole tonne of emissions.1
‘Import’ and ‘importation’ have the same meanings and applications as set out in section 2(1)
of the Customs and Excise Act 1996. The importer of synthetic greenhouse gases is the person
by whom goods are imported, or for whom goods are imported. This includes the consignee of
goods and a person who is or becomes the owner of, or entitled to the possession of, or
beneficially interested in, any goods on or at any time after their importation and before they
have ceased to be subject to the control of the New Zealand Customs Service. If you are
unsure about who the importer is, it is your responsibility to seek legal advice.
1
Section 63(1) of the Act.
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2
Registering as a participant
All NZ ETS reporting is done through the New Zealand Emission Unit Register (NZEUR)
operated by the Environmental Protection Authority (EPA). Further guidance on emissions
reporting is available on the NZEUR website at www.eur.govt.nz.
Importers and manufacturers of HFC and PFC, and large users of SF6, operating at 1 January
2013 are mandatory participants and need to register as participants in the NZ ETS by 31
January 2013.
People who export or destroy HFC or PFC are voluntary participants and, if intending to earn
emission units for this activity, should also register as participants.
To register as a participant you must first gain access to the system by registering as a user and
opening a holding account. Your account will be used for surrendering and receiving emission
units. Once you have opened an account you can register as a participant. If you will be
involved in more than one activity you can use a single holding account for all activities.
1. Register as a user
To register as a user go to the New Zealand Emission Unit Register (NZEUR) website at
www.eur.govt.nz and follow the steps under ‘Join now’. You will need a username and a
password.
2. Open an account
Once the user registration is approved, log on using the username and password and use the
online application form to open an account. Once you have entered the required details, you
will be emailed an account holder declaration form which needs to be signed and returned to
the EPA. Your account will not be opened until the EPA has received this form.
3. Register as a participant
After opening an account, register as a participant by completing an online participant
notification form at www.eur.govt.nz. It is a good idea to fill in the account holder declaration
form and the participant notification at the same time as the required signatures may be the
same.
Registering is a simple process.
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3
About the regulations
Regulations affecting SGG NZ ETS participants are in three parts:
1. Climate Change (Stationary Energy and Industrial Processes) Regulations 2009 and Climate
Change (Stationary Energy and Industrial Processes) Amendment Regulations 2012
These regulations set out the methods and other requirements for determining emissions from
importing or manufacturing HFC and PFC in bulk. These regulations also set out the SF6
emissions and reporting obligations for users of SF6.
2. Climate Change (Other Removals) Regulations 2009 and Climate Change (Stationary Energy
and Industrial Processes) Amendment Regulations 2012.
These regulations provide for the determination of emissions removed from New Zealand
through exporting or destroying SGG. The regulations also identify the eligibility criteria for the
emissions to be counted as removed.
3. Climate Change (General Exemptions) Order 2009 and Climate Change (General
Exemptions) Amendment Order (No 2) 2012
These regulations set out the situations where a person is exempt from obligations under the
NZ ETS, such as the large user threshold for SF6.
The amendment regulations and orders will come into effect March 2013. Once in effect these
amendment regulations will become outdated and the new parts will be included in the
principle regulations. All regulations and orders can be found at www.legislation.govt.nz.
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4
Importing bulk HFC and PFC
Climate Change (Stationary Energy and Industrial Processes) Regulations 2009: 44G to 44N
Climate Change (Stationary Energy and Industrial Processes) Amendment Regulations 2012:
Schedule 2A
All calculations of emissions from importing HFC and PFC are done on the basis that the
emissions are accounted for in the year the activity occurs. Therefore, calculation methods
estimate the total emissions that will occur when the gas is released.
Emissions for any bulk HFC and PFC import activity are calculated as:
E = A × GWP/1000
Where
– ‘E’ is emissions of each class of gas. If there are imports or exports of more than one
class the calculation may need to be repeated several times
– ‘A’ is the mass of a class of synthetic greenhouse gas imported in bulk in the year, in
kilograms
– ‘GWP’ is the global warming potential of the:
o class of gas, as defined in table 2 of schedule 2A of the Climate Change
(Stationary Energy and Industrial Processes) Amendment Regulations 2012 or
o single HFC or PFC, as defined in table 1 of the Climate Change (Stationary
Energy and Industrial Processes) Amendment Regulations 2012 or
o by application of regulation 44R in the Climate Change (Stationary Energy and
Industrial Processes) Regulations 2009.
Table 2 of schedule 2A of the amendment regulations list classes by the ASHRAE 34-2007
Standard and provides GWP figures for commonly imported mixes of HFC or PFC.
Where a mix of HFC or PFC imported is not listed in table 2 of schedule 2A, regulation 44R
requires a person to use the following formula to determine the GWP of the class of gas:
GWP = ∑ (A × B)
This means the overall GWP for the class is a function of the fraction of each HFC or PFC in the
mass of the mix (‘A’) multiplied by its GWP (‘B’). The GWP used must be from the Climate
Change (Stationary Energy and Industrial Processes) Amendment Regulations 2012.
Importers of HFC and PFC in bulk are required to collect information on the constituents and
the total kilograms of each class of HFC or PFC imported in each year, as recorded at the
customs point. Importers could get this information from:

sales and purchase documentation

customs documentation

measurements by supplier, purchaser or customer.
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Examples:
1) Person AB imported 35 kg of HFC227a in the year:
E = A × GWP/1000
So E = 35 × 3220/1000 = 113
2) Person CD exported 2000 kg of R134a in the year:
E = 2000 × 1300/1000 = 2600
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5
Exporting HFC or PFC in bulk, goods and motor
vehicles
Climate Change (Other Removal Activities) Regulations 2009: 9 to 16
Climate Change (Other Removal Activities) Amendment Regulations 2012: 22, Schedule
Reporting actual emissions removed
This chapter explains the methodology for calculating emissions from exporting HFC or PFC in
bulk, or in goods and motor vehicles containing HFC or PFC.
Removal emissions from exporting HFC or PFC can be calculated by using the following
equation:
E = ∑ (A × B × GWP / 1000)
Where
– ‘E’ is emissions of each class of HFC or PFC. If there are exports of more than one class
the calculation may need to be repeated several times
– ‘A’ is the total number of units of each type of pre-charged equipment exported in the
year by the person
– ‘B’ is the mass of a class of HFC or PFC exported in the type of pre-charge equipment in
the year, in kilograms
– ‘GWP’ is the global warming potential of the:
o class of gas, defined in table 2 of the schedule of the Climate Change (Other
Removal Activities) Amendment Regulations 2012 or
o single HFC or PFC, as defined in table 1 of the Climate Change (Stationary
Energy and Industrial Processes) Amendment Regulations 2012 or
o by application of regulation 21 in the Climate Change (Stationary Energy and
Industrial Processes) Regulations 2009.
Further detail on the application of regulation 21 and the schedules can be found in chapter 4.
Information that is required to be collected:
Information to be collected
The total number of units of each type of
pre-charged equipment exported by the person
in the year (or other period for exports) as
recorded at the customs point.
Possible sources
Sales documentation
Customs documentation
The HFC or PFC charge in grams in each type of
pre-charged equipment exported by the person
in the year (or other period for exports).
Sales and purchase documentation
Customs documentation
Measurements by supplier, purchaser or
customer
Nameplate information
Manufacturer information
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The constituents of the class of HFCs or PFCs in
each type of pre-charged equipment exported
by the person in the year or other period (for
quarterly returns).
Sales and purchase documentation
Customs documentation
Measurements by supplier, purchaser or
customer
Nameplate information
Manufacturer information
Example:
Person EF exported 2000 small appliances of type G, and 200 larger appliances of type H.
E = ∑ (A × B × GWP/1000)
Type
Number of
units (A)
Gas charge
(B) in kgs
Class
GWP
Removals
Type G
2000
0.08
R404a
3260
521
Type H
200
1.2
R134a
1300
312
Total
833
Option for those reporting emissions for motor vehicles
Default HFC charge sizes for cars, vans, utes, trucks, buses and off-engine refrigerated trucks
and trailers can be used to calculate the removal emissions. The default charges are provided
in table 3 of Schedule 2A of the Climate Change (Other Removals) Regulations 2009. Other
vehicle types (such as tractors) cannot use those default values and the person carrying out
the activity will need to determine the actual charge size.
Motor vehicle importers and exporters can use the following methods:
1. the default charge method or
2. the actual charge method or
3. a combination of the two.
The default charge method allows a person to use default values for the mass of the HFC
charge. The actual charge method is the same as the method explained in chapter 6 and
requires measuring and recording the mass of the SGG charge in the category of motor vehicle.
The equation is therefore:
E = ∑ (A × B × GWP / 1000)
Where
– ‘E’ is emissions of each class of gas. If there are imports or exports of more than one
class the calculation may need to be repeated several times
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–
–
–
‘A’ is the total number of units of each type of motor vehicle containing SGG imported
or exported in the year by the person
‘B’ is the mass of a class of HFC or PFC exported in the type of motor vehicle in the
year or the default charge for the type of pre-charge equipment in the year, in
kilograms
‘GWP’ is the global warming potential of the:
o class of gas, defined in table 2 of the schedule of the Climate Change (Other
Removal Activities) Amendment Regulations 2012 or
o single HFC or PFC, as defined in table 1 of the Climate Change (Stationary
Energy and Industrial Processes) Amendment Regulations 2012 or
o by application of regulation 21 in the Climate Change (Stationary Energy and
Industrial Processes) Regulations 2009.
Further detail on the application of regulation 44R and the schedules can be found in
chapter 5.
Information that is required to be collected for all reporting:
Information to be collected
The total number of units of each type of motor
vehicle imported or exported by the person in
the year (or other period for exports), as
recorded at the customs point.
Possible sources
Sales and purchase documentation
Customs documentation
The constituents of the class of HFC in each type
of motor vehicle imported or exported by the
person in the year (or other period for exports).
Sales and purchase documentation
Customs documentation
Measurements by supplier, purchaser or
customer
Nameplate information
Manufacturer information
Example:
Person AB exported 1500 cars and uses the default method
E = ∑(A × B × GWP/1000)
 E = 1500 × 700 × 1300/1000 = 1365
Criteria for all export of HFC or PFC
Participants must meet the following criteria to be eligible for applying for emission units:

the person exporting either bulk HFC/PFC or HFC/PFC contained in goods is a manager of a
product stewardship scheme accredited under the Waste Minimisation Act 2008, or

all the components of the bulk HFC/PFC exported (or if the HFC/PFC was imported in
goods, the goods themselves) were imported after 31 December 2012.
Provided the above criteria are met, participants can apply for units within 20 working days of
the following quarterly dates:



31 March
30 June
30 September.
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6
Manufacturing gas in New Zealand
The Climate Change (Stationary Energy and Industrial Processes) Regulations 2009 provide
methods to determine emissions from manufacturing HFC or PFC in New Zealand if this activity
occurs in the future. The equation for determining the emissions from manufacturing HFC or
PFC is:
E = (A + B + C) × GWP/1000
Where
–
–
–
–
–
‘E’ is emissions for the particular class of HFC or PFC. If there is more than one class of
HFC or PFC manufactured then the calculation will need to be repeated and total
emissions calculated by summing the results
‘A’ is the mass of the class of HFC or PFC manufactured at the facility in the year, in
kilograms
‘B’ is the mass of the class of HFC or PFC emitted during manufacturing at the facility in
the year, in kilograms
‘C’ is the mass of the class of HFC or PFC emitted during handling at the facility in the
year, in kilograms
‘GWP’ is the global warming potential of the:
o class of gas, as defined in table 2 of schedule 2A of the Climate Change
(Stationary Energy and Industrial Processes) Amendment Regulations 2012, or
o single HFC or PFC, as defined in table 1 of the Climate Change (Stationary
Energy and Industrial Processes) Amendment Regulations 2012, or
o by application of regulation 44R in the Climate Change (Stationary Energy and
Industrial Processes) Regulations 2009.
Further detail on the application of regulation 44R and the schedules can be found in
chapter 4.
Information that is required to be collected is:
Information to be collected
Mass of each class of HFC or PFC manufactured by the
facility in the year, in kilograms.
Possible sources
Sales documentation
Manufacturing information
Mass of each class of HFC or PFC emitted during
manufacture by the facility in the year, in kilograms.
Manufacturing and other systems
monitoring
Mass of each class of HFC or PFC emitted during handling
by the facility in the year, in kilograms.
Manufacturing and other systems
monitoring
The constituents of each class of HFC or PFC
manufactured or emitted during the year.
Chemical analysis
Manufacturing information
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Example:
Person GH manufactured 11,250 kg of HFC134a in New Zealand in the year. In that process,
there were 0.2 kg of HFC134a emissions from manufacture, and 0.05 kg of HFC134a emissions
from handling.
E = (A + B + C) × GWP/1000
=> E = (11250 + 0.2 + 0.05) × 1430/1000 = 16088
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7
Destroying gas in New Zealand
The Climate Change (Other Removal) Regulations 2009 provide methods to determine
emissions from destroying HFC and PFC in New Zealand. The equation for determining
emissions removed through the destruction of HFC or PFC is:
R = (( ∑ (A × B)) × C – D) × GWP/1000
Where
–
–
–
–
–
–
‘R’ is the removals for the class of HFC or PFC destroyed. If there is more than one
class of HFC or PFC destroyed, then the calculation will need to be repeated and
total removals calculated by summing the results
‘A’ is the mass of the batch of chemicals containing the HFC or PFC submitted to
the destruction facility, in kilograms
‘B’ is the fraction by mass of the class of HFC or PFC in the relevant batch of
chemicals
‘C’ is the destruction efficiency factor for the class of HFC or PFC at the destruction
facility
‘D’ is the estimate of handling losses of the class of HFC or PFC in the batch of
chemicals, in kilograms
‘GWP’ is the global warming potential of the:
o class of gas, defined in table 2 of the schedule of the Climate Change (Other
Removal Activities) Amendment Regulations 2012, or
o single HFC or PFC, as defined in table 1 of the Climate Change (Stationary
Energy and Industrial Processes) Amendment Regulations 2012, or
o by application of regulation 21 in the Climate Change (Stationary Energy and
Industrial Processes) Regulations 2009.
Information that is required to be collected is:
Information to be collected
Mass of chemicals in each batch of chemicals containing
the class of HFC or PFC submitted by the person to the
destruction facility in the year, in kilograms.
Possible sources
Sales and purchase documentation
Systems monitoring information
The percentage by mass of the class of HFC or PFC in each
batch of chemicals.
Chemical analysis
The constituents of each class of HFC or PFC destroyed at
the facility during the year.
Chemical analysis
The destruction efficiency factor for the class of HFC or
PFC at the destruction facility.
Chemical analysis
Equipment manufacturer
information
Systems monitoring information
Mass of each class of HFC or PFC emitted during handling
by the facility in the year, in kilograms.
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Example:
Person IJK destroys synthetic greenhouse gases. In the year, it was recorded that four batches
of chemicals were destroyed with varying chemical compositions:
Class of
SGG
R143A
Batch Mass of Mass of Destruction
batch kg class in efficiency
batch by
%
Losses
of class
kg
GWP
of class
Total
destroyed
R134a
1
15000
11%
99%
2
1300
R134a
2
15000
5%
99%
1
1300
R134a
3
15000
21%
99%
1
1300
R134a
4
15000
9%
99%
2
1300
R152A
1
15000
4%
95%
0
140
R152A
4
15000
4%
95%
0
140
R125
1
15000
2%
99%
0
2800
R125
3
15000
5%
99%
0
2800
R125
4
15000
9%
99%
1
2800
6650
R143A
2
15000
1%
98%
0
3800
558.6
Total
8873
160
16241
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Large users of sulphur hexafluoride (SF6)
The equation for determining emissions for users of SF6 can be determined by following these
steps:
Step 1: Determine ‘M’.
 M: the total SF6 used to install and maintain all electrical switchgear in
operation during the year.
Step 2: A = ∑ (F – P) for all equipment that was newly installed.
 F: Nameplate capacity of any new electrical switchgear in operation
that is filled with SF6.
 P: Total pre-charged SF6 quantity, if any of the filled electrical
switchgear in operation was partially pre-charged before installation.
Step 3: B = ∑ (F – Q) for all equipment that was retired.
 F: Nameplate capacity of any retired electrical switchgear that is filled
with SF6.
 Q: Total SF6 remaining in equipment upon its removal from operation.
Step 4: Actual Emissions = (GWP×(M-A+B))
1000
For the exact formula, which summarises the above four-step process, please refer to clause 4
of the Climate Change (Stationary Energy and Industrial Processes) Amendment Regulations
2012.
If a person has less than 1 tonne of SF6 contained in all their operating electrical equipment,
then they are exempt from any obligation under the NZ ETS. Effectively this means only large
users of SF6 are required to report and surrender units for SF6 emissions relating to the
operation of electrical equipment.
This exemption is set out in the Climate Change (General Exemptions) Amendment Order (No
2) 2012.
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9
Record keeping and references
Participants must retain sufficient records to enable the EPA to verify the emissions they
report in their emissions return. Records must be retained for a period of at least seven years
after the end of the year to which they relate. This includes any records relating to removal
activities.
References
The Climate Change Response Act 2002 and related regulations and amendment regulations
are all available at www.legislation.govt.nz
Web links and additional guidance on SGGs: http://www.climatechange.govt.nz/emissionstrading-scheme/participating/synthetic-gases/
An independent report from CRL Energy provides further technical background:
http://www.climatechange.govt.nz/consultation/synthetic-gases/methods-for-synthetic-gasregulations/
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