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Joint industry letter calling on ENVI Committee to reconsider ban on F-gas

Policy papers 28 Feb 2023

In view of the ENVI Committee vote on 1 March, the undersigned industries stress that banning all F-gas without taking into account the outweighing benefits arising from the growth of heat pumps and foams would lead to inadvertent environmental, social, economic and political consequences.

The ENVI’s Compromise Amendments to Ban All Fluorinated Gases Jeopardise the EU Climate and Energy Security Goals

Signatories: Agoria, APPLiA - Home Appliance Europe, AREA, Association of European Component Manufacturers (ASERCOM), European Phenolic Foam Association (EPFA), The European Fluorocarbons Technical Committee, European Heat Pump Association (EHPA), EPEE, Eurovent, Japan Business Council in Europe (JBCE), JRAIA, SMEunited, Transfrigoroute International (TI)

We call on Parliament to adopt realistic and sustainable solutions to achieve carbon neutrality by 2050.

We, the undersigned, are fully committed to EU carbon neutrality by 2050 and represent the industries that will deliver on decarbonising buildings through innovative heating, cooling, refrigeration and foam insulation solutions.

We applaud the ambition of the F-gas regulation and fully support a revision to increase ambition and to further phase down higher global warming potential HFCs. As an industry we support new technologies and already use alternative fluorinated and non-fluorinated refrigerants (as it is already the case in many stationary refrigeration applications) and foam blowing agents in many applications.

However, we are extremely concerned with the following ENVI Amendments which are simply not practically possible. We ask that you reject those listed below, as they will undermine Europe’s carbon neutrality goals, slow down the building renovation rate and uptake of heat pumps, and risk existing equipment becoming obsolete instead of being repaired.

• Inadequate quota levels of HFCs (Annex I, Section 1), as well as limiting the availability of parts to 10 years, go against the need to encourage the repair of existing equipment, and will lead to premature obsolescence and costs for SMEs and consumers (Compromise Amendments 10, 11 and 14). The lifetime of refrigeration and heat pump equipment is much longer than 10 years.

  • The proposal will stifle the roll-out of new energy efficient and renewable-based equipment -- in particular, heat pumps. A too-steep phasedown means there will not be enough HFCs available for new heat pump installations (CA 10, 14), which require fluorinated and non-fluorinated refrigerants, depending upon the location and national safety requirements. We appreciate ENVI recognized the risk to achieving REPowerEU targets, but we do not believe it can be solved by shifting the responsibility to the EU Commission to assess heat pump needs on a yearly basis and to add quota if required. The industry, including the component supply chain, needs a stable and reliable legislative framework to allow for medium- and long-term planning.
  • Banning products simply because they contain fluorine (CA 10) is not technologically neutral and is not practical. Industry needs a diversity of fluorinated and non-fluorinated solutions to fit the wide variety of applications for the EU and export markets (CA 10, 11, 13, 14). The GWP values need to be balanced with safety, energy efficiency, applicability and affordability for end users, as well as other environmental considerations which are being assessed in the REACH regulation process. The current bans are neither balanced nor sufficiently granular.
  • The use of new solutions will require upskilling to maintain, service and install equipment safely and efficiently. Only around 10% of technicians, most of which are SMEs, are currently able to work with non-fluorinated alternatives. It is critical that they are properly trained and certified due to the safety risks involved. A too-steep phase down and early product bans do not allow time for technician training. (CA 10,14).
  • A lack of quota combined with a ban on exporting products will push manufacturing outside of the EU (CA 11, 13, 14). EU manufacturing currently exports to many countries including the UK and the MENA region, and many exports are solutions specifically designed for high temperature conditions.
  • The bank of quota authorisations is available only for imports of pre-charged equipment and will already be used to meet the REPowerEU needs in the next three years. This discourages the expansion and creation of new factories to manufacture heat pumps inside the EU and contradicts the Green Deal Industrial Plan (CA 14).

Therefore, we would ask you to reject the following compromise amendments: CA 10, CA 11, CA 13, CA 14 and CA 21, which gives the Commission permission to adapt changes to the regulation without going through the full legislative process.

We ask that you recognise the need to support REPowerEU, EU energy independence in times of economic pressure and the EU Industrial Green Deal. We also ask you to consider the phase down opinion agreed by Parliament’s ITRE Committee, which provides a pragmatic and ambitious plan for carbon neutrality by 2050.

The undersigned are committed to making every effort possible to bring about carbon neutrality by 2050. However, banning all fluorinated gases without taking into account the outweighing benefits arising from the growth of heat pumps and foams would lead to inadvertent environmental, social, economic and political consequences for Europe’s citizens and businesses.

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