Dear Madam, Dear Sir,
In view of the announced COREPER I meeting this Wednesday April 5th to discuss the F-Gas Regulation Revision, our industry alliance is extremely concerned that the adopted European Parliament Report and the recently published Swedish Presidency compromise text, dated 31st March, are insufficient in building a successful, pragmatic and implementable Regulation. Such proposals would jeopardise the REPowerEU targets on heat pump deployments and slow down the energy transition.
Whilst we support this revision to further phase down higher global warming potential HFCs, and our industry supports new technologies -- already using alternative fluorinated and non-fluorinated options (as it is already the case in stationary refrigeration applications) -- we call on decision makers to focus on:
Make it right: with granular bans, sufficient quotas, and realistic timelines
Make it precise: unclear bans, unclear definitions, and unclear applications will lead to legislation that is not enforceable
Make it real: by really adjusting the laws to market realities of product development times, safety concerns and a skilled workforce
Make it consistent: do not create a programmed obsolescence
In conclusion, without addressing these very serious concerns, there will be the risk of increased illegal imports of HFCs, lower investments in EU manufacturing, considerable burdens on members states for market surveillance, and most worrying – a continued dependence on gas-fired boilers due to lack of affordable and diverse heat pump solutions (not all heat pumps are monobloc types installed outdoors).
We, the undersigned, are fully committed to EU carbon neutrality by 2050 and represent the industries that will deliver on decarbonising buildings through innovative heating, cooling, refrigeration, and foam insulation solutions, as well as rolling out REPowerEU.
On behalf of the alliance, we thank you for your attention and consideration. We would very much appreciate the opportunity to meet and discuss these points in the coming weeks to provide sound and factual information to inform your negotiations.
Please do not hesitate to contact us.
With kind regards,
The undersigned organisations