POSITION PAPER – German General Administrative Regulation on the Procurement of Climate-Friendly Services (AVV Klima)

03 / 12 / 2021

03/12/202- EPEE, representing the refrigeration, air-conditioning and heat pump (RACHP) industry in Europe, welcomes the consideration of environmental protection and circular economy aspects in German federal public procurement within the framework of a general administrative regulation.

However, we consider that the ‘negative’ list of services that may not be procured by federal government departments, provided in Annex 1 of the regulation, is inconsistent with the goals of the overall procurement regulation. Indeed, the goal formulated in the AVV – to reduce the federal government’s greenhouse gas emissions – will not be supported by banning some of the appliances listed in Annex 1, but rather hindered. In addition, the ban on the procurement of
certain products will not only lead to an increase in CO2 emissions, but also to an increase in investment and life cycle costs.

The AVV ‘negative list’ also contradicts several overarching EU policy goals, most importantly the Energy Efficiency First principle. Finally, it is not in line with the EU F-gas Regulation.

The above concerns apply specifically to the inclusion of the following applications in Annex 1:
● Multi-split and VRF air conditioning systems with a rated capacity above 10 kW
● Chillers with a rated capacity above 10 kW using refrigerants with a GWP ≥150
● Refrigerators and freezers, and other stationary and mobile refrigeration and air conditioning systems, with halogenated refrigerants (if alternatives available)

EPEE would like to request a review of Annex 1 and deletion of the above-mentioned products
based on the below arguments. We would be happy to further explain this background and to
contribute to the success of the AVV Klima.

Click here to download the full Position-Paper