Environment Matters

The gas industry has fewer obvious environmental problems to solve than some parts of the chemical industry but all organisations have some effect on the environment through the natural resources they consume to make and distribute the products they sell.

BCGA member companies are very aware of their environmental responsibilities.  Within BCGA, environment matters are the responsibility of Technical Sub-Committee (TSC) 8. Members can access information on TSC8 via the ‘Members’ area.

Environmental policy is devolved in the UK. The national environment Regulators publish their own environmental guidance. Click the links below to read more on their respective websites.

Significant environmental topics which affect the gases industry

It should be noted that UK environmental policy is generally aligned with Europe and references are made to both UK and European legislation.

Climate Change and Carbon Management

Climate Change Levy (CCL)

The UK Climate Change Levy (CCL) is a tax on industrial electricity, gas and oil usage. BCGA has a Climate Change Agreement (CCA) under the CCL, which has been in place since 2005, covering operators of Air Separation Units (ASU’s) in the UK.

CCA’s are applicable to industry sectors recognised to be ‘Energy Intensive’ by the Department for Business, Energy and Industrial Strategy (BEIS) that may, by ‘negotiated agreement’, gain partial relief from the CCL in return for progressively improving their energy efficiency in accordance with closely defined targets. CCA’s are extremely complex and further detail can be found on the BEIS website.

Streamlined Energy and Carbon Reporting (SECR)

Streamlined Energy and Carbon Reporting (SECR) is a new requirement from 2019 under The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. This replaces, but is not the same as, the carbon reduction commitment reporting.

This impacts large (large = 2 of: Balance sheet >£18 m, Turnover >£36 m, Employees >250) unquoted companies & Limited Liability Partnerships (LLP) >40 MWh energy use from financial years starting after 1 April 2019 and so the first time a report is due under SECR will be after April 2020. This information needs to be included in the Directors Report and the report may cover a group of companies. Processes are already in place for checking Company Reports via Company’s House.

What must you report?

  • UK total energy use (at least electricity, gas and transport)
  • Scope 1 (fuel used) and 2 (energy bought) emissions including stating methodology
  • Greenhouse gas (GHG) intensity (e.g. tCO2/£ turnover)
  • Commentary on energy efficiency actions taken. This should be: ‘meaningful, informative and consistent with the size of the business’ but if commercially sensitive this can be withheld (but must be explained). There will be no requirement to report specifically on actions identified via the ESOS audit process, but this can be used as the basis of the narrative if the company qualified for and complied with ESOS.
  • After the first year the previous year’s data must be included

Find out more on SECR.

Carbon Footprinting and Carbon Neutrality

An increasingly common practice is to assess and state the carbon consumption of businesses and of individual products. The Department for Environment, Food and Retail Affairs (DEFRA) provide a general guide to Carbon Footprinting.

The European Industrial Gases Association (EIGA) has published specific guidance on this for the gases industry. Refer to EIGA 167Methodology to establish a “product carbon footprint”.

EU Emissions Trading Scheme (EU ETS)

From the 1 January 2013 hydrogen and carbon monoxide plants producing >25 tonnes/day of hydrogen production come under the EU ETS, more information is available from EIGA.

Industrial Pollution Control – Environmental Permitting Regulations (EPR) and Integrated Emissions Directive (IED)

There are several gas industry processes which are covered by specific environmental permits; these are hydrogen and carbon monoxide production, acetylene, nitrous oxide or electronics gases production.

Air separation units and air gas filling plants, including mixtures, are not subject to the EPR permitting regime. Air separation units do often operate on sites regulated by the Environment Agency under EPR. The BCGA has worked with the Environment Agency to establish that no separate permit is needed for the gas company operation, provided that certain conditions are met. Refer to BCGA GN 21Environmental Guidelines for Air Separation Plant and Equipment on sites regulated under EPR/PPC.

EIGA Technical Bulletin 20Baseline reports for Industrial Emissions Directive sites, provides information on the applicability of the Industrial Emissions Directive (IED) to industrial gases processes.

Gas cylinders in the waste stream

Gas cylinders and other transportable pressure vessels are fully reusable, recyclable and can have a long life time. However gas cylinders do turn up at waste transfer and disposal sites and BCGA has produced guidance to manage the associated risks, refer to BCGA L 2, The safe handling of gas cylinders at waste facilities. Additional information on managing the recovery of cylinders from waste sites or the disposal of cylinders can be found on the Cylinder Recovery & Disposal webpage.

Packaging Producer Responsibility Regulations

Gas suppliers have obligations under the Packaging Producer Responsibility Regulations. The Packaging (Essential Requirements) (Amendment) Regulations 2013 included for the first time, amongst others, ‘Refillable steel cylinders used for various kinds of gas, excluding fire extinguishers‘. Advice is available from the Environment AgencyBCGA GN 28Packaging waste within the industrial gases industry, provides specific advice.

Regulations covering waste can be found on the website of the Environment Agency (or the Environment Agencies within your jurisdiction, NetRegs is a useful source of information).

Plastic Packaging Tax

The Plastic Packaging Tax may affect companies who have manufactured or imported 10 or more tonnes of plastic packaging since 1 April 2022.  Given the various nuances of the application of this tax which is administered by HMRC, reference should be made directly to  the government website: Plastic Packaging Tax – GOV.UK (www.gov.uk).  A key feature of this taxation program is the need for participants to compile auditable evidence packs.

Fluorinated Gases (F Gas) and Ozone Depleting Substances (ODS)

The supply and use of F gas and ODS are regulated by EU and UK legislation. In the UK The Fluorinated Greenhouse Gases Regulations apply.  DEFRA provides useful guidance.

From 1 January 2015 the use of all HCFC’s as refrigerants for service and maintenance has been prohibited. A number of fluorinated products including refrigerants with a high global warning potential (GWP) are being phased out. From 1 January 2020 no more virgin product above 2500 GWP will be supplied but note that the Regulations are complex and require review by competent persons.

There are a range of replacement refrigerants being supplied. These may have different properties to the existing refrigerant, for example, some are flammable. The changeover from one product to another will require a thorough design review to ensure continued safety and reliable operation.

There are specialist recovery cylinders available from gas suppliers for the return of waste F gases and ODS gases, refer to BCGA TIS 41Cylinders provided for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia.

EIGA 192Fluorinated gases management, provides advice and guidance. Comprehensive guidance on the F-Gas regulation has been provided on behalf of DEFRA by Gluckman Consulting.

Energy Efficiency

Energy Savings Opportunity Scheme

The UK Government has established the Energy Savings Opportunity Scheme (ESOS) to enable compliance with The Energy Savings Opportunity Scheme Regulations. ESOS is an energy assessment scheme that is mandatory for organisations in the UK that meet the qualification criteria. The Environment Agency is the UK scheme administrator.

The Department for Energy Security and Net Zero and the Environment Agency provide guidance on ESOS.

Organisations that qualify for ESOS must carry out ESOS assessments every 4 years. These assessments are audits of the energy used by their buildings, industrial processes and transport to identify cost-effective energy saving measures. Organisations must then notify the Environment Agency by a set deadline that they have complied with their ESOS obligations.

The most recent qualification date – the date on which organisations must determine whether they qualify for the scheme in that phase – is the 31st December 2022. By the 5th June 2024, you must notify the Environment Agency (as the scheme administrator) that you have complied with the scheme.

BCGA has prepared a Briefing Note to provide further guidance. EIGA provide additional information on energy efficiency in their Technical Bulletin 15Energy Efficiency: compliance with legal requirements and best practices.

Science based carbon reporting targets

Organisations are encouraged to set science-based emissions reduction targets and there is a focus on these Science Based Targets. “Science-based targets provide a clearly-defined pathway for companies and financial institutions to reduce greenhouse gas (GHG) emissions, helping prevent the worst impacts of climate change and future-proof business growth. Targets are considered ‘science-based’ if they are in line with what the latest climate science says is necessary to meet the goals of the Paris Agreement – limiting global warming to 1.5°C above pre-industrial levels.”[SBTi]. The BCGA supports and encourages it members to participate but appreciates it is an individual company’s decision as to what to include, how to proceed, and which consultancies to partner with.

Energy Performance of Buildings Directive (EPBD)

The Energy Performance of Buildings Directive makes it a legal requirement that an accredited inspector undertakes a mandatory Energy Efficiency Inspection, at least once every 5 years, on any air conditioning system over 12 kW total capacity.

These inspections are designed to ensure the system is suitable for the intended purpose and is operating correctly and efficiently. The regulations are enforced by Trading Standards and carry fines for non-compliance.

It is not mandatory to act on the recommendations of the Air Conditioning Energy Efficiency Inspection, however the findings often highlight energy saving opportunities which easily outweigh the cost of the inspection and remedial works.

In the UK, the Chartered Institution of Building Services Engineers (CIBSETM44 is used as the guidance for air conditioning inspections.

There is a government managed register for TM44 non-domestic accredited energy assessors.

Government Consultations

BCGA regularly responds to Government consultations, many on environmental matters. If you would like to contribute to current consultations contact the BCGA Office.



GN21 Environmental guidelines for air separation plant and equipment on sites regulated under EPR / PPC. Revision 3: 2023

08/11/2023 Guidance Notes GN21

Provides guidance on how BCGA members, who operate air separation units, can assist their customers to comply with The Environmental Permitting (England and Wales) Regulations (EPR) and The Pollution Prevention and Control (Scotland) Regulations (PPC).

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GN28 Packaging waste within the industrial gases industry. Revision 2: 2023

09/11/2023 Guidance Notes GN28

Provides advice on the obligations necessary when procuring refillable steel gas cylinders for companies to comply with the Producer Responsibility Obligations (Packaging Waste) Regulations and the Packaging (Essential Requirements) Regulations.

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L2 The safe handling of gas cylinders at waste facilities. Revision 6: 2016

11/05/2016 Leaflets L2

Provides guidance on the safe and appropriate actions that should be taken to manage gas cylinders at a waste facility. This includes establishing that a cylinder is in a safe condition, any contents are identified and that there is a legal right to carry out any disposal activity.

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TIS41 Cylinders provided for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia. 2019

26/07/2019 Technical Information Sheets TIS41

Provides information on the use of recovery cylinders for the return of waste ozone depleting substances, fluorinated gases and anhydrous ammonia either for preparation for re-use or for disposal, and identifies the appropriate environmental waste duty of care process.

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PP02 Recommendation for environmental guidelines to permit hydrogen plants producing up to 2 tonnes per day. 2018

24/10/2018 Position Papers PP02

Hydrogen production, at any scale, requires a permit under legislation. This Position Paper will be used by BCGA to discuss with the Regulatory Authorities a more practical approach to permitting where hydrogen production is only at a scale of up to 2 tonnes per day.

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BCGA publish several publications providing advice on environment matters. All BCGA publications are accessible via the publications page. The following are of interest as they relate to environment matters.