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German industry groups: PFAS exemptions for F-gases required for refrigeration, air conditioning and heat pumps

15 September 2023

In response to the PFAS restriction proposal, seven organisations representing the entire value chain of the German refrigeration and air conditioning industry – trade, plant engineering, manufacturers and education, have issued a joint statement and press release calling for exemptions for F-gases and other PFAS used in refrigeration, air conditioning and heat pumps. They are BIV, BTGA, Bundesfachschule, FGK, RLT-Herstellerverband, VDKF and ZVKKW and support the planned restriction of environmentally harmful PFAS chemicals wherever technically possible. The refrigeration, air conditioning and heat pump industry uses PFAS chemicals in a variety of forms and applications – including seals, construction and coating materials, electrotechnical and electronic components, and fluorinated refrigerants. In many cases, however, suitable alternatives with the same mandatory material properties are currently not available and cannot be developed as market-ready products within the time frame of the planned ban periods. Key demands are:

  • Complete exemption for fluorinated refrigerants
  • Exemptions for PFAS-containing refrigerants for existing systems for an unlimited period of time
  • Exemptions for PFAS-containing spare parts for existing plants for an unlimited period of time

The statement refers in detail to UNEP 2022 Environmental Effects Assessment Panel Report, which discusses the environmental effects of TFA (extensively reported in the EFCTC June 2023 newsletter).  It also explains that regardless of a complete exemption for F-gases from the PFAS ban, the organisations are calling for an unlimited exemption for fluorinated refrigerants for service and maintenance purposes. There are tens of millions of refrigeration, air conditioning and heat pump systems in operation in the EU. Their number will increase significantly in the coming years until the [proposed] PFAS ban comes into force due to the growing need for air conditioning and planned expansion of heat pumps. The majority (at least 90%) of the existing systems, as well as a large proportion of the new systems to be installed in the next few years use F- gases as refrigerants. The lifespan of the systems is on average 20 years; however, many systems are in operation for significantly longer. Currently, the PFAS ban proposal only provides for a temporary exemption for service and maintenance with F gases from existing systems of 13.5 years. However, service and maintenance must be guaranteed for the entire service life of the systems. On the one hand, the safe and continuous operation of refrigeration, air conditioning and heat pump systems is essential in almost all applications (data centre, hospital, blood bank, supermarket, etc.). It must therefore be ensured that immediate repairs are possible even if refrigerant leaks suddenly occur. On the other hand, converting systems with F-gases to non-fluorinated refrigerants is not possible.

The statement (in German) and press release are available at Joint statement on the planned ban on PFAS in the EU - VDKF,and Joint press release by the organisations BIV, BTGA, Bundesfachschule, FGK, RLT-Herstellerverband, VDKF and ZVKKW. This is reported in Cooling Post and Refrigeration Industry.

The EFCTC June 2023 Newsletter contained several items about the about TFA from the UNEP 2022 Assessment Report of the Environmental Effects Assessment Panel.

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