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Joint industry letter ahead of F-gas trilogue negotiations

Policy papers 25 Apr 2023

Dear Madam, Dear Sir,

In view of the upcoming interinstitutional negotiations on the F-gas Regulation Revision, we would like you to consider key concerns related to the adopted European Parliament Report.

We support the revision to further phase down higher global warming potential HFCs, and note our industry already uses alternative fluorinated and non-fluorinated options (e.g. as it is already the case in stationary refrigeration applications). We now call on decision makers to address the following critical issues with the amendments noted below:

• Banning all F-gases inside the timelines proposed by the EP will remove currently available and efficient heating solutions from the market. It is not realistic to assume that the potential application of non-fluorinated refrigerants such as propane in some heat pump solutions can be simply “extrapolated” to all types of heat pumps. (The same reasoning has been applied to thermal insulating foams). Although safeguard clauses such as “exempt when needed to meet safety requirements” are proposed for some bans, there was no impact assessment done to evaluate in how many cases these exemptions would apply. In addition, new refrigerants require upskilling to install and maintain equipment safely and efficiently. Today, only around 10% of technicians are trained to work with non-fluorinated alternatives. The current proposals provide insufficient time for technician training and assumes alternative refrigerants can be used in all applications, creating considerable safety risks. Finally, it is important that regulations not overlap, and in this case it should not be mixed with the REACH process, as not all HFOs are PFAS.

  • AMs 145, 153cp1, 157cp1, 153cp2 and 153cp4 (amendments on the product bans)
  • AMs 4 and 22: amendments on PFAS in the recitals
  • AM 139: amendment on the Article 35 (Review)

• Legal certainty and market surveillance can only work if the product bans are properly defined in an unambiguous and granular language. Many product bans lack specificity and do not grasp the diversity and complexity of the sectors. As a result, several product bans are not executable from a safety, efficiency, affordability, and timing perspective.

• AMs 145, 153cp1, 157cp1, 153cp2 and 153cp4 (amendments on the product bans)

• An export ban would create job losses for EU based factories. A ban on exports will not improve the climate on a global scale, which is the intention of the amendment, since it will benefit only the production and export in other parts of the world. It would also undermine the goals of the Net Zero Industry Act by preventing the export of heat pumps, an extremely efficient technology.

• AM 79

• The phase down and quota ‘buffer’ foreseen for heat pumps would not work in practice and would be extremely disruptive to market practices. The proposal does not consider actual sector needs and underestimates the quota necessary.

• AM 101 (Article 17 Determination of reference values and allocation of quotas for placing hydrofluorocarbons on the market)

We would like to highlight that the European Parliament Report also contains positive ambition for the sector:

  • While quota readjustment mentioned above is unrealistic in terms of practical implementation, the Parliament’s proposal is favourable to the Council’s, which imposes a cap on the amount of quota that can be added. Sufficient quota are essential for the servicing of existing equipment, for the “REPowerEU” growth of heat pumps and for EU-based factory investments.
  • Extension of the certification and of the training programmes to all the refrigerants

• AMs 65, 69, 70 and 71 (Article 10 Certification and Training)

• Extended Producer Responsibility

• AM 58

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 – the continued burning of fossil fuels to provide needed heating due to insufficient heat pump and other solutions. A lack of affordable and diverse options will seriously challenge the goal of carbon neutrality by 2050 for the European Union and each individual member state.

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 direct you to our joint industry proposals offered last month with 12 leading European associations and global partners. Furthermore, we intend to invite you to an information session to further explain these issues and address any questions you may have. In the meantime, 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.

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