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Update on the F-gas proposal: a wide range of opinions and positions

14 November 2022

Two significant events have highlighted the diverse opinions about the F-gas proposal. Following the publication of the European Commission’s proposal to revise the F-gas Regulation earlier this year, EFCTC organized a successful event to exchange views on the proposed changes to the Regulation. Also in October, the Rapporteur (MEP Bas Eickhout) of the Committee on the Environment, Public Health and Food Safety, published the ENVI draft amendments with measures that go further than the Commission proposal. This has already generated a detailed joint statement by industry trade associations, expressing concern (reported below). A special issue of Industria and Formazione Magazine includes 3 articles about the F-gas proposal, from the European Commission, EPEE and AREA.

Hosted at the European Parliament by MEP Stelios Kympouropoulos, Shadow Rapporteur on the F-gas Regulation file, the event brought together European policymakers, F-gases manufacturers and downstream users who discussed implications of proposed revisions to the F-gas Regulation, the vital use of refrigerant gases in household energy-saving applications and medical devices as well as the challenges faced due to illegal trade of hydrofluorocarbons (HFCs) into the European Union (EU). MEP Stelios Kympouropoulos, opened the event and set out his position and ambition for the revision, stating: “F-gases are essential for many applications in our lives, including life-saving healthcare devices. Revisions to the F-gas Regulation should not be taken lightly. A holistic approach that focuses on technical feasibility, energy efficiency, and takes into account patients’ access to safe and reliable technologies is vital.” The Cooling Post reported EPEE’s comments at the event including this by Folker Franz, former EPEE’s director general “We don’t see how you can move to fully natural refrigerant heat pumps as early as 2027 as this commission proposal will do. This is a discussion we need to come up with a realistic schedule with a realistic timeline of how fast this refrigerant transition can take place in order to have a proper energy transition in heating and cooling.” Read the Cooling Post article and the EFCTC press release for highlights of the event.

 

The draft ENVI report by the Rapporteur (MEP Bas Eickhout) of the Committee on the Environment, Public Health and Food Safety contains measures that go further than the Commission proposal in a document of 113 amendments. In the explanatory statement, the rapporteur proposes to accelerate the HFC consumption phase-down in line with what is currently technologically feasible, adds prohibitions for sectors for which, according to various studies, including the preparatory study for this proposal, it is technologically and economically feasible to move to F-gas free solutions, including a proposal to move several (sub)sectors, such as refrigeration, air conditioning, heat pumps and switchgear, to F-gas free alternatives, commenting that the rapporteur is aware of the concerns of several stakeholders regarding these prohibitions. An article about this is in LaRPF.

A detailed joint industry statement in response to draft ENVI report explains that the co-signatories share the EU’s Green Deal ambition to accelerate the transition towards climate neutrality by 2050. “To achieve this goal, a careful balance needs to be struck between reducing emissions from HFCs (used as refrigerants in RACHP equipment) and reducing emissions by installing more heat pumps. The amendments put forward by the Rapporteur would jeopardize energy saving targets and strengthen the European dependence on fossil fuel sources in the next years.” In conclusion the statement adds “Against that background, we call on Members of European Parliament to strongly reject the proposed amendments on the HFC phase down path as well as Annex IV bans on key technologies, particularly heat pumps. A realistic approach in these provisions would be of primary importance to mitigate the climate change and energy crisis in Europe.” The complete statement is available here and is reported in Cooling Post.

The joint industry statement is signed by the European contractors group AREA and manufacturing associations ASERCOM, EPEE, EHPA and Eurovent, the Spanish air conditioning association AFEC, the Japanese Business Council in Europe (JBCE) and Japanese AC and refrigeration body JRAIA.

 

Articles about the F-gas proposal in the special issue of Industria and Formazione Magazine:

Bente Tranholm Schwarz, deputy Head of Unit in the Directorate General for Climate Action in the European Commission, sets out why upgrading the F-gas Regulation is a must, and the implications for availability of HFCs in the medium and longer term. “The proposal already provides a very good indication of what is coming, namely that HFCs will become extremely scarce in the EU very soon and that within the next few years new products and equipment should only contain F-gases where no alternative can be used. Stakeholders are therefore advised to start making changes to align with the F-gas Regulation 3.0 as soon as possible. Don’t lose out by delaying: this is a great opportunity to seize a first mover advantage in a growing market in the EU and elsewhere.”

The EPEE article The Future of F-Gas Refrigerants in Europe explains that Europe is simultaneously facing a climate change ‘emergency’ and a geo-political challenge of rapidly decreasing its reliance on imported fossil fuels. Two fundamental strategic questions where a massive rollout of heat pumps is seen by policy makers as large part of the solution. However, the latest modelling by EPEE raises serious questions on whether there will in fact be sufficient HFC refrigerants available to make the heat pump rollout a reality. EPEE comments that a deeper analysis of the EU Proposal for the revision of the F-Gas Regulation with the HFC modelling has enabled to understand the proposed HFC phase-down is ‘de facto’ an HFC phase-out by 2027, that risks to seriously jeopardize an accelerated and comprehensive heat pump roll out in the EU, expected to achieve, as soon as possible, the independence from fossil fuel imports.

AREA in its article Proposal for a Revision of the F-Gas Regulation, sets out its position in detail and explains that “Despite the Regulation’s proven success, the proposal for a revision substantially toughens two of its core provisions – the phase-down scheme and the placing on the market prohibitions – with the stated goal of further accelerating the market penetration of alternatives, and in particular natural refrigerants. Yet, the proposal ignores the actual ability of the RACHP contracting sector to cope with such a surge. More worryingly, it fails to ensure that equipment working with alternative refrigerants can only be handled by competent contractors, thereby leaving the door wide open to widespread safety hazards and energy inefficient equipment.”

 

Trade associations

EPEE represents the refrigeration, air conditioning and heat pump industry in Europe., EPEE’s membership is composed of over 50 companies as well as national and international associations from three continents (Europe, North America, Asia). https://epeeglobal.org/

AREA is the European association of refrigeration, air conditioning and heat pump contractors, representing 13,000 companies. http://area-eur.be/

ASERCOM Association of European Refrigeration Component Manufacturers, Start - ASERCOM

EHPA European Heat Pump Association – Renewable energy (ehpa.org)

Eurovent, Eurovent | Europe’s Industry Association for Indoor Climate, Process Cooling, and Food Cold Chain Technologies

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