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Trilogue on the revision of the EU F-gas Regulation: state of play

With the adoption on April 5 of the Council of the EU’s position on the revision of the EU F-gas Regulation, following the European Parliament’s ambitious vote on the regulation on March 30, the next and final step in the process of updating the regulation is set to take place.

In this phase, the Council, the Parliament and the European Commission will engage in rounds of negotiations – called a trilogue – to finalize the revised EU F-gas Regulation with the objective of securing a deal by summer. These entities have all adopted their positions (which can be consulted at the links provided in this paragraph).

The parties are now aiming to have the new regulation enter into force in January 2024.

Mainstreaming NatRefs

All three of the positions adopted include mainstreaming natural refrigerants in Europe. Broad support is clear across the three texts.

The European Parliament goes even further, asking in Amendment 67 for the “certification for natural alternatives, including their characteristics and benefits compared to the use of fluorinated greenhouse gases, and their safe handling during installation, servicing, maintenance, repair and decommissioning.” The Council and the Commission support this mainstreaming provision too.

HFC phase down and system bans

Policymakers will still need to iron out differences relating to the HFC phase down and bans of refrigeration systems.

The Commission and Council propose to phase down HFCs, not ultimately eliminate them as the Parliament proposes. The Parliament in fact considers the use of HFCs to be inconsistent with the objective of climate neutrality by 2050 and is calling for a phase out of HFCs as of 2050 due to the possibility today of switching to refrigerants that don’t consume HFC quotas.

Caption: Different HFC phase down according to the schedules proposed

EU F-gas trilogue

The Parliament has clearly conveyed its position that new systems in stationary refrigeration can be served without fluorinated gases, asking for a complete decoupling of f-gases in bans 11 and 12 and adding a ban (14a) on new stationary refrigeration equipment that contains, or whose functioning relies upon, fluorinated greenhouse gases as of January 1, 2027. The Parliament also supports a ban (23b) on new mini, displacement and centrifugal chillers that contain, or whose functioning relies upon, fluorinated gases as of January 1, 2027.

The Parliament also believes that new mobile systems need to transition away from f-gases as these systems were largely untouched in the previous version of the legislation. The Parliament suggests that transport refrigeration can move to natural refrigerants by the end of this decade, prohibiting the use of f-gases in new transport refrigeration systems in vans and ships as of January 1, 2027, and in trucks, trailers and reefer containers as of January 1, 2029. In addition, the Parliament welcomed the addition of a ban (23a) on all f-gases used in new mobile air-conditioning in passenger and cargo ships, buses, trams and trains as of January 1, 2029.

The Commission and Council have taken more conservative stances on these bans, generally calling for delays and higher-than-technologically-feasible GWP limits.

Heat pumps

Heat pumps have long been front and center in the political debate surrounding the revision of the F-gas Regulation.

The Parliament would welcome a complete phase out of fluorinated greenhouse gases in ban 17 as of January 1, 2026, due to the maturity of alternatives in this technology. On split systems (ban 18), the Parliament, aware of the issues related to low GWP f-gases that are or that degrade into PFAS, is seeking to decouple this sector as well from all fluorinated gases where technology allows it today.

To this end, it suggests that the placing on the market of new equipment as of January 1, 2028, comply with the following bans:

  • F-gases in single split systems, including fixed double duct systems, containing less than 3kg of fluorinated greenhouse gases listed in Annex I (a).
  • F-gases in split systems of a rated capacity of up to and including 12kW/3.4TR, except when required to meet safety standards (b).
  • F-gases with a GWP above 750 in split systems of a rated capacity of more than 12kW and up to 200kW/56.9TR (c).
  • F-gases in split systems of a rated capacity of more than 200kW/56.9TR (ca).

The Commission and the Council are also taking more conservative stances on these provisions.

Next F-gas Regulation

There seems to be general consensus among the three institutions that this will not be the last revision of the EU F-gas Regulation. The Parliament proposes that the Commission “continuously monitor technological and market developments in relation to the use of fluorinated greenhouse gases and their natural alternatives in the Union,” granting it the power to strengthen the bans “where it finds evidence of the emergence or acceleration of the use of low GWP fluorinated greenhouse gases or of natural alternatives.”

The Parliament also links the revision of the EU F-gas Regulation to the REACH Restriction of PFAS, asking that the Commission assess the need to revise the EU F-gas “no later than three months following the adoption of the revised REACH Regulation,” to check alignment with “potential new restrictions of the use of PFAS.”

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