In response to the Commission's Have Your Say consultation, APPLiA shared its stance and views on the new proposal for a Regulation on F-Gases revising (EU) No 517/2014 published on 5 April 2022.
Unrealistic phase-down path: home appliances manufacturers are committed to provide solutions that can mitigate climate change and reduce carbon emissions. However, the efforts in the area of heating and cooling technology for buildings are at risk by the too drastic phase-down mechanism, being per se a phase-out. Therefore, we are calling on the policy-makers to at the very least not make the current phase-down under Regulation (EU) No 517/2014 more stringent until the REPowerEU objectives are achieved (2030).
➤ Contradiction with the REPowerEU’s objectives: APPLiA is perturbed to face contradictory plans between the F-Gas Regulation Proposal that would require bans of heat pumps for buildings, and the REPowerEU objectives urging the massive deployment of such technology.
➤ Propane is not a one-size-fits-all solution suitable for all applications: the new phase-down proposal is based on unrealistic assumptions of widespread use of propane for hydronic heat pumps and air-to-air heat pumps below 12 kW from 2024, as there is today only a very limited number of this product using alternatives to F-Gas, such as R290 propane.
➤ Safety as first principle: the use of R290 poses risks and constraints in terms of safety, governed by standard IEC 60335-2-40 which does not address other safety aspects of equipment during the transport, maintenance or end-of-life phases of the products.
➤ Unworkable and incoherent assumptions used for determining the new phase-down schedule: the new phase-down is based on questionable assumptions and leads to an unrealistically strict scenario leaving the market with no possibility to meet consumers’ demand for renewables and highly efficient cooling and heating technology.
New unrealistic bans impeding path towards innovation: there is a fundamental contradiction between promoting new technologies such as heat pumps for buildings and at the same time having the same products and equipment banned listed in Annex IV, points 17 and 18(b).
➤ Heat pump based technologies to heat and cool buildings are essential: heat pumps are needed to decarbonize heating and cooling while achieving energy independence vis-à-vis Russian fossil fuel.
Export of pre-charged equipment issue unsolved: the exclusion of pre-charged equipment needs to be removed from article 16(2)(c) as it heavily affects the competitiveness of our European industries.