POSITION PAPER – Revision of the EU F-Gas Regulation

25 / 11 / 2021

25/11/2021 – EPEE has been a long-time supporter of the 2014 EU F-Gas Regulation (EU 517/2014). Delivering emission savings year after year since its entry into force, it has become the effective gold standard worldwide for reducing emissions from fluorinated greenhouse gases (F-Gases).

EPEE – representing the Refrigeration, Air Conditioning and Heat Pump Industry in Europe –
presents the following key recommendations on the revision of the EU F-Gas Regulation:

1 Strengthen key provisions to further prevent F-Gas emissions

To further improve the Regulation for effectively preventing emissions into the atmosphere, EPEE recommends to
– Extend requirements on containment and recovery to all refrigerants.
– Use electronic logbooks to move towards an EU-wide overview on leakage and recovery.
– Extend training and certification requirements to all refrigerants.
– Introduce more stringent penalties for non-compliance.
– Ensure the alignment of national measures on F-Gases with the EU single market

2 Factor in the need for F-Gases to achieve the 2030 and 2050 decarbonisation objectives

The flexible choice of a wide range of refrigerants, including HFCs, is needed for the scaling up of technologies required to achieve the European Green Deal. EPEE’s modelling work projects massive potential to reduce energy emissions with Refrigeration, Air Conditioning and Heat Pump equipment. For any adjustment of the F-Gas Regulation, the European Commission must factor in the massive CO2 abatement potential of all heat pump technologies and the “Energy Efficiency First” principle.

3 Keep the current ambitious HFC phase-down schedule and ensure freedom of choice

The Phase-Down system must remain the cornerstone of the F-Gas Regulation. Bans on specific HFCs risk paralyzing innovation and market forces. The current ambition of the phase-down steps by 2030 should not be increased and must be carefully calibrated to the European Green Deal objectives.

4 Take into account different scope and counting methods when aligning with international
commitments

In seeking alignment with the Montreal Protocol, any modification of the scope of the HFC phasedown should not create a negative impact on the accessibility and availability of HFCs for the Refrigeration, Air Conditioning and Heat Pump sector.