Claire Bright

Claire Bright

Monday, 10 July 2017 17:10

All about refrigerants


Reporting refrigerants under the National Greenhouse and Energy Reporting (NGER) Scheme is a quirky and sometimes confusing process. Not sure if you should be reporting your refrigerants? Not sure how to report refrigerants?

Keep reading to find out what you need to know.


Who needs to report

Reporting of refrigerants is only required for facilities which falls under specific ANZIC codes – these are:

  • Food product manufacturing services (ANZIC classification, Subdivision 11)
  • Beverage and tobacco product manufacturing (ANZIC classification, Subdivision 12)
  • Retail trade (ANZIC classification, Division G)
  • Warehousing and storage services (ANZIC classification, number 530)
  • Wholesale trade (ANZIC classification, Division F)
  • Rental, hiring and real estate services (ANZIC classification, Division L)


What to report

Refrigerant plant needs to be reported if it meets the following criteria:

  • Has a gas charge of greater than 100 kg
  • Includes a hydroflurocarbon gas listed in subsection 7A(2) of the NGER Act, and that gas has a global warming potential greater than 1000.


How to report

You can report on emissions from refrigerants either as incidental emissions, or using the methods described in the NGER Measurement Determination 2008 (the NGER Determination).

If you would like to report your refrigerants as incidentals, both the facility and the refrigerant plant, will need to meet threshold criteria for reporting incidentals. Reporting of incidentals also needs to adhere to the general principles for measuring emissions laid out in section 1.13 of the NGER Determination. This means that if you choose to report refrigerants as incidentals, the emissions report still need to be transparent, comparable, accurate and complete. Furthermore you cannot report refrigerants as incidentals if you are required to collect the information for other legislative purposes.

To report using methods 1 listed in the NGER Determination you will need to collect information about your refrigerant plant. Specifically, you will need to know:

  • The type of cooling the plant is used for (air conditioning, commercial refrigeration, or industrial refrigeration),
  • The type of refrigerant gas is sued in the plant, and
  • The gas charge of the plant.

This information can usually be found either on the plant name plate, or in maintenance records.

Figure 1 below, shows a flow chart for identifying when and how to report your refrigerants.




The traps

There are a few catches to refrigerant reporting which may trip-up the unwary.

Firstly refrigerants may be made up of a mix of gases. In such cases it may not be immediately apparent that the refrigerant needs to be reported. It is important to check the refrigerant specifications to confirm whether it contains a reportable gas.

The requirement to report plant that uses a mix of gases is based on the entire gas charge of the plant, not just the reportable component. If the gas charge of the plant is above 100 kg you must report - it doesn’t matter if the reportable component of the gas mixture is only a small portion of the total.

However, if reporting using method 1, the calculation of emissions does account for the proportion of the gas mix which is reportable. The total quantity of emissions or as known in the NGER Determinations as the Stock value, reflect the proportion of the total gas that is made up of reportable gas(es) by the individual global warming potential of those gas(es).   To calculate the volume of emissions that is reportable, the stock value is multiplied by a leakage factor as per 4.102 of the NGERs Determinations.

Lastly, it is important to note that the refrigerant gases used in your plant may change over time. Under the Montreal Protocol some types of refrigerant gases are being gradually phased out, and new ones introduced. The gas used in your refrigerant plant may be changed during servicing or maintenance, and this change will result in a change in to your emissions.  Hence, what was reported last year, may not be true this year.


Contact us

For help on reporting your refrigerants, or assistance in complying with your NGER requirements, contact Claire Bright or Ndevr Environmental on (03) 9865-1400.



Has your business exceeded its reported baseline? Are you applying for a calculated baseline? Don’t forget to book your audit - deadlines for calculated baseline audits are approaching fast!


The Safeguard Mechanism requires large greenhouse gas emitting facilities to keep their emissions equal to, or below, historic levels (known as ‘the reported baseline’). Companies who have exceeded their reported baseline for 2016-2017 are now rushing to have their emissions limit increased via an alternative ‘calculated baseline’. Applications for a calculated baseline may have a 30 July 2017 deadline.

Applications for calculated baselines must be supported by:

  • Detailed evidence that the proposed calculated baseline is accurate and relevant
  • Evidence that the facility meets the criteria to apply for a calculated baseline
  • An independent audit

The Clean Energy Regulator is closely scrutinising the basis of preparation for calculated baselines. The Regulator can refuse applications for calculated baselines at their discretion - so be prepared and have your evidence ready.

If you have exceeded your reported baseline in 2016-2017, and do not have a calculated baseline, your greenhouse gas may need to be offset using Australian Carbon Credit Units – a potentially expensive option!  


Key Dates for Calculated Baseline Applications

Year with the highest production estimate for the facility

Deadline to apply for a calculated baseline

Regulator’s decision


30 July 2017

60 days after application


31 October 2017


Further information

For more information on calculated baselines and whether they apply to you refer to our article: Safeguard Mechanism: Your guide to compliance

For help preparing your application for a calculated baseline, or to request an audit of your calculated baseline, contact us on 03 9865 1400.

Our full contact details can be found here.