Summary

The Clean Cooling Coalition is made up of progressive European companies from the HVAC&R industry who believe that the most effective way to achieve the EU’s climate neutrality goals by 2050 lies in the quick reduction of F-Gas usage and the scaling up natural refrigerant-based solutions.

In this document, we would like to reiterate the points we most strongly feel need to be addressed in the Commission’s review of the current F-Gas Regulation.

If one takes into account that alternative technologies were available already a decade ago, we can unfortunately conclude that we have lost a decade of possible ambition.

Our position can be summarised by the following three conclusions:

1) The European Climate Law creates a legal obligation to be climate-neutral by 2050 as set out in the European Green Deal. This, in turn, forces the EU’s F-gas Regulation to be even more ambitious this decade — though recognised as an effective regulation, this regulation in its current form no longer reflects market reality.

2) Commercially viable efficient alternative solutions exist today, are already on the market, and are in growing demand. Yet many industry segments remain untouched. The EU must increase its ambition to phase-out f-gases combined with segment specific bans. This will provide the market certainty for new entrants and solutions, thereby fostering European innovation and maintaining global HVAC&R leadership.

3) A holistic approach must be taken in analysing HFCs, HFOs and HFO blends. 100 Year GWP is not enough. There is increasing evidence of health, safety and life-cycle impacts from this generation of synthetic refrigerants.

Bans & Exemptions

With the Green New Deal’s requirement of carbon neutrality, it is clear that an accelerated phase down of F-gases is required, driven by more ambitious sectoral HFC bans — for all HVAC&R sectors, including those not previously addressed in the current F-Gas Regulation (2015).

Findings indicate that HFC bans are the most effective measure driving the industry towards long-term sustainable technologies, avoiding costly and unnecessary intermediary steps. ¹

In the sectors where the F-Gas Regulation has implemented bans on HFCs, the industry has indicated much stronger growth in the availability of HFC-free technologies over the last five years as well as a greater shift in R&D investments and employment with regard to this type of product.

New technological developments mean that several sectoral exemptions from the F-Gas Regulation are no longer necessary as alternative technologies have already penetrated the market and will increase by the time the new version of the regulation comes into force. As was previously the case last decade.

Recommendations:

– New bans for sectors in which energy efficient commercially viable solutions are widely available should start from 1st January 2024.

– Bans for sectors in which energy efficient solutions are available but currently lack the market certainty to generate volume demand, such as air conditioning and heat pumps, bans should begin from 2025.

– There are two exemptions which are no longer needed because technologies using alternatives already exist and are being sold and implemented: for low temperature refrigeration below -50℃ and for transport refrigeration.

Maximum GWP

Following a comprehensive review of each sub-sector, the Commission-funded Preparatory Study (2011) and the Commission-published Impact Assessment (2012) concluded that the transition to safe and energy-efficient alternatives relying on natural and low-GWP technologies available at the time was both cost-effective and feasible in most sub-sectors by 2020.

Recommendation:

– Set a maximum GWP of 50 for all sectors. This allows for a faster transition to lower GWP refrigerants.

GWP20 & GWP100

The 100-year GWP underestimates the impact of refrigerants in the short term. i.e. in reality. Considering the fact that the EU’s climate goals are set for the next 30 years, the 20-year GWP of refrigerants must also be considered, for their real impact on climate to be reflected in regulations.

Recommendation:

– The 20 year GWP or ‘real GWP’ needs to be added alongside 100 year when calculating ‘real impact’ of refrigerants. This is necessary for policymakers and the public to understand the urgency with which F-Gases must be treated. Considering the legal climate target is set for 2050, it also makes sense to have a GWP that more closely matches this timeline.

Taxes, Incentives, & Training

The current mandatory training and certification for HVAC&R equipment under the F-Gas Regulation addresses only fluorinated refrigerants and does not consider the safe handling of HFC replacements, such as natural refrigerants like CO2, ammonia, hydrocarbons, air, and water.

Given an increasing market share of natural refrigerant-based technologies in Europe and the growing complexity of components and new system solutions, including mandatory training for natural refrigerant and technologies in certification programmes is key to improve the uptake of natural refrigerants and to mitigate the risks of working with such equipment.

Furthermore, considering that HFOs are also flammable, the training offered on these refrigerants should also be applicable for hydrocarbons.

Recommendation:

– Although HFC taxes are a Member State prerogative, we believe that the EU can help by sharing knowledge and coordinating between Member States in terms of best practices on HFC taxes, which need to reflect the ‘EU polluter pays’ principle.

– In addition Member States can share best practices on incentives for alternatives like natural refrigerants, which can help offset the upfront costs of these technologies as they enter new segments. Once price parity (linked to volume of sales) is achieved they would no longer be needed.

– Extend existing certification, to include compulsory training on toxic, flammable, and high-pressure refrigerants.

– The Commission should create a public awareness campaign to inform the public and industry of F-Gases, their issues, and the natural refrigerant based alternatives.

HFOs

Although HFOs have lower GWPs, a study from by Refolution Industriekälte GmbH, a Karlsruhe, Germany-based consulting and engineering firm focused on sustainable refrigeration warns that HFOs, such as R1234yf used in the automotive industry, break down into trifluoroacetic acid (TFA) within two weeks, which, in large quantities, could potentially cause acid rain. The study concluded that TFA is expected to become concentrated in terminal sinks due to it being highly persistent. This should be of particular concern for the EU as this problem will be localised, creating localised TFA concentrations.

The risk, therefore, increases as the emissions from HFOs to the environment increase. Furthermore, the report states that “long-term exposure with low concentrations [of TFA] showed elevated ALT [alanine transaminase]-concentrations and indicate that TFA in drinking water can potentially damage the liver and have other impacts, for example on the hormone system,“ in particular thyroid function.

Another factor to consider is that many of the new HFO blends are patented, fixing the price quite high and limiting commercial availability.

Lastly, the use of HFOs should take into account their life-cycle GWP. This includes the emissions associated with their manufacturing as well as their effects in the atmosphere and their degradation into other harmful substances. Though in theory f-gases are not meant to exist in closed systems, leaks are all too common, forcing us to take into consideration their whole lifecycle impact.

Recommendation:

– We caution against the use of synthetic HFO refrigerants or HFO-blends as their impact on the environment is still being studied.

– The EU precautionary principle needs to be applied when examining the use of HFOs, especially in light of the most recent research findings.

– We urge for a health and safety study on HFOs to be carried out by the Commission in conjunction with the REACH agency in Helsinki.

About the Clean Cooling Coalition

The Clean Cooling Coalition is made up of progressive European companies from the HVAC&R industry that believe that the most effective way to achieve the EU’s carbon neutrality goals by 2050 lies in further the quick reduction of F-Gas usage and the scaling up natural refrigerant-based solutions.