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The Clean Cooling Coalition Reacts to the EU F-Gas Proposal

The European Commission released its amended proposals for the EU Regulation on fluorinated greenhouse gases (f-gases) and ozone depleting substances (ODS) on Tuesday, 5 April 2022.

The Clean Cooling Coalition welcomes the release of these two proposals that are set to steer the path towards the uptake of climate friendly and efficient solutions in Refrigeration, Air Conditioning, and Heat Pump (RACHP) sectors.  

According to the European Commission’s press release, the amendments in the EU F-Gas proposal intend to save the equivalent of 40 million tons of carbon dioxide (CO2) emissions by 2030, beyond the expected reduction under current legislation, reaching total additional savings equivalent to 310 million tons of CO2 by 2050. 

The Coalition members welcome some improvements of the proposal; however, the members believe that there is still room for greater ambition.

The Coalition welcomes the addition of bans in the stationary split air conditioning and split heat pump sectors. These prohibitions will drive the uptake of climate-aligned equipment, such as systems running with natural refrigerants. These natural refrigerants-based systems not only boast high energy performances, but also negligible direct emissions. 

The Coalition also welcomes the further tightening of the HFCs phase down schedule, as well as the alignment of the EU HFCs phase down with the provisions of the Kigali Amendment to the Montreal Protocol. As the production and use of these substances will be reduced, the Coalition is pleased to see in the current EU F-Gas proposal an extension to training and certification programmes on alternatives to f-gases, to streamline the safe handling of natural refrigerants.

Moreover, the addition of 20-year Global Warming Potential (GWP) values alongside the 100-year GWP values will better inform users of f-gases of their short-term effect on climate change.

Finally, the Coalition supports further action to regulate trade of fluorinated substances, with the aim to stop their smuggling.

Nevertheless, the members of the Coalition regret the lack of ambition of the EU F-Gas proposal on other aspects. Given the climate emergency we live in, swift and prompt action on global warming agents such as HFCs contributes to keep the temperature increase within bearable levels, and Europe should lead the path towards the global switch to natural alternatives across all sectors.

The Coalition feels that the current proposal is a lost chance to drive innovation and secure EU leadership worldwide. An increasing number of EU-based manufacturers and end users have already successfully adopted RACHP solutions with natural refrigerants, and ask for higher policy ambition in this space.

More bans, and tighter ones, should be designed across the different sub-sectors, to allow for innovation with natural refrigerants. For instance, the lack of bans in the transport refrigeration sector is worrisome, as the sector is experiencing growth and has high leakage rates. In addition, transport refrigeration systems charged with natural refrigerants are a reality today.

The Coalition members also believe that the exemptions granted at points 14 and 15 of the EU F-Gas proposal are not technologically necessary, as products relying on alternatives to fluorinated greenhouse gases are present on the EU market.

The Coalition also regrets that the current proposal is a missed opportunity to target the carbon intensity of fluorinated refrigerants production, both within and outside the EU. Not only these substances require more energy to be produced than their natural counterparts, but also imported substances should be manufactured in line with the applying EU environmental standards.

Finally, the members are worried by the EU F-Gas proposal’s lack of specific reference to the work undergoing in the context of the poly- and perfluoroalkyl substances (PFASs) Restriction Intention under the EU Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

The Clean Cooling Coalition looks forward to engaging in the policy making debate in the coming months to shape an ambitious EU F-Gas Regulation.