UK ACRIB, representing key trade and professional institutes has prepared a draft response to the EU Commission’s Consultation on the F-Gas Regulation Review, to highlight the most effective policy measures based effectiveness in the UK to date.  Before a final answer is delivered to the Commission ACRIB would appreciate comments from the wider industry.

Commenting in its draft upon the F-Gas Regulation Review Consultation, UK ACRIB would encourage the EU Commission to focus firstly on

  • Improving legislation, compliance and enforcement in all countries;
  • acknowledging the evidence that demonstrates containment is working, and that regulations need only technical adjustment and inclusion of additional requirements to make further savings;
  • reassuring businesses that they should continue to invest in compliance and containment.

While early indications are that F gas emissions in the UK have decreased in the last 2-3 years, ACRIB is concerned that a number of Member States have failed to introduce national legislation within the required timescales or have achieved a too low level of enforcement, undermining the potential of the Regulation to achieve the necessary emissions reductions. It is therefore asking the Commission to be more vigilant in ensuring that full compliance is met by all Member States.
ACRIB considers that the key policy options necessary to achieve this are:

  1. The introduction of single national mandatory individual registration and company certification scheme members.
  2. Refrigerant suppliers to be responsible for ensuring that only appropriately certified individuals can be supplied with F-Gas refrigerants.
  3. An awareness campaign aimed at equipment operators covering enforcement in combination with a ‘non-compliant’ operator reporting service.
  4. Member states to report to the Commission on compliance levels and to ensure more robust auditing of all company and individual certification authorities.
  5. More active enforcement and increased policing of operators’ legal obligations under the Regulation to take place.

ACRIB comments that the EU Commission's consultation should focus on extending the existing regulations, which need to be more thoroughly applied across Europe. Sending out a message that an F-Gas phase down is imminent is therefore undermining actions to maximize compliance with the F-Gas Regulation to achieve emissions reductions.

Finally in order not to compromise energy efficiency and increase inadvertently indirect emissions (which make up more than 80 % of the sector’s contribution to global warming), ACRIB considers that F-Gas stakeholders should be free to select the best refrigerant, taking into account efficiency, safety, technical feasibility and containment issues. Forcing the use of certain as yet unproven refrigerant options could compromise any of these criteria with serious consequences.