Four European organizations supporting the wider uptake of natural refrigerants are seeking support for a statement asking the European Commission (EC), the European Parliament and national governments to maintain an ambitious stand in their ultimate revision of the EU F-gas Regulation, particularly in regard to heat pumps.
The organizations – the Clean Cooling Coalition, Refrigerants, Naturally!, the Royal Dutch Association of Refrigeration (KNVvK) and STEK (Emission Prevention Refrigeration Technology Foundation) – released the statement at the ATMOsphere (ATMO) Europe Summit 2022, held November 15–16 in Brussels. The conference was organized by ATMOsphere, publisher of R744.com.
Dozens of companies signed the statement at the conference, and the groups invite like-minded stakeholders to sign it as well. The statement can be read below, copy/pasted in a Word document, signed by providing the name and signature of the representative, job title, company, date and location, and then scanned and emailed to any of the groups: info@cleancoolingcoalition.eu, info@refrigerantsnaturally.org, info@knvvkyoungcool.nl or info@stek.nl. The statement can also be downloaded here.
The groups are forwarding the signed statements to EU and national policy makers working on the F-gas Regulation.
The EC has submitted a proposal to increase the ambition of the current EU F-gas Regulation, part of the process in the EU that will lead to a revision of the regulation. In addition, Member of the European Parliament (MEP) Bas Eickhout has called for greater ambition than the EC’s proposal, through both bans on new refrigeration and air-conditioning equipment with fluorinated gases (HFCs and HFOs) between 2024 and 2027 and a more stringent HFC phase down.
Separately, the European Chemicals Agency (ECHA) will take up a proposal to regulate certain f-gases and one of their by-products, trifluoroacetic acid, in January.
Meanwhile, the EU has developed the REPowerEU program to accelerate the bloc’s transition away from fossil fuels toward an electrified future that includes heat pumps. However this initiative has sparked a debate about whether an ambitious F-gas Regulation would not support an accelerated heat pump rollout.
“Our companies’ business is aligned with the objectives of REPowerEU and the EU Chemical Strategy for Sustainability,” the statement says, adding, “We support the overall direction of the Commission proposal for the new EU F-gas Regulation, the amendments of the European Parliament and the work related to PFAS.” In a footnote, the statement refers in particular to the amendment proposed by Eickhout.
The statement stressed that “there is no ‘conflict’ between a phase-down of halogenated chemicals and the objectives of REPower EU, in particular those related to heat pumps.” In fact, manufacturers are already investing “at large scale” in R&D and production capacities for environmentally friendly equipment without f-gases and other halogenated chemicals, the statement adds.
Natural refrigerants, notes the statement, “are a proven, reliable, energy-efficient and technically mature option for almost all applications, capacities, sizes and temperatures. They are readily available in the EU and in the countries adopting EU ambitions. This is particularly true for heat pumps.”
The organizations say they would like to see “legislation, standards, training and certification schemes for technicians” as well as “targeted financial incentives” to support equipment with natural refrigerants or refrigerant-free technologies.
The organizations
The Clean Cooling Coalition is a coalition of European companies from the HVAC&R industry who believe that the most effective way to achieve the EU’s climate neutrality goals by 2050 lies in the quick reduction of f-gas usage and scaling up natural refrigerant-based solutions.
Refrigerants, Naturally! is an association of manufacturers, trade groups, NGOs and consultants supporting the wider uptake of natural refrigerants across the world.
The Royal Dutch Association for Refrigeration (KNVvK) is a science-based independent network for professionals working in refrigeration technology.
STEK had been designated by the Netherlands Ministry of Economic Affairs and Climate Policy in the Netherlands (VROM) since 1992 to ensure the implementation of environmental regulations in the Netherlands on leakage prevention of CFCs, HCFCs and HFCs from refrigeration and air-conditioning installations and equipment.
The Statement
(November 14, 2022)
We are a Europe-based manufacturer of refrigeration, air-conditioning or heat pump equipment or RACHP components, or an organisation representing those. We support the F-gas proposal from the EU Commission1, including amendments of the European Parliament2.
Our companies’ business is aligned with the objectives of REPowerEU3 and the EU Chemical Strategy for Sustainability4. We support the overall direction of the Commission proposal for the new EU F-gas Regulation, the amendments of the European Parliament and the work related to PFAS567.
Wherever feasible we are committed to a full phase out of halogenated refrigerants, in particular F-gases, in line with this proposal and its amendments. This commitment will serve as an accelerator for a competitive, green and sustainable EU industry detached from halogenated substances.
Natural refrigerants8 are a proven, reliable, energy efficient and technically mature option for almost all applications, capacities/sizes and temperatures, well available in the EU and in the countries adopting EU ambitions. This is particularly true for heat pumps.
We want to emphasise that manufacturers are already investing at large scale into R&D and production capacities for environmentally friendly equipment without F-gases and other halogenated chemicals. There is no “conflict” between a phase-down of halogenated chemicals and the objectives of REPower EU, in particular those related to heat pumps.
Also, investing in F-gases and related equipment is a waste of capital for manufacturers and end-users, given the long technical lifetime of such RACHP equipment, where a later conversion to natural refrigerants (retrofitting) is virtually impossible.
The new legal EU framework should strive to be forward-looking and ensure protection of current and future generations from unforeseen consequences of current and novel chemicals as refrigerant.
As example, the story of refrigerant R1234yf (HFO) applied today in many applications, including mobile air conditioning, must not be repeated: introduced as being environmentally friendly, it is recognized today as causing irreversible environmental damage (e.g. PFAS, TFA9).
In order to meet these ambitious goals, we encourage the European Commission, Members of the European Parliament and national governments to actively support the European industry on this pathway, through favourable legislation, standards, training and certification schemes for technicians, and through targeted financial incentives to support further development, demonstration and market introduction investments for equipment with natural refrigerants or refrigerant-free technologies.
Name………………………….
Function…………………….
Place……………………
Company…………………………
Signature………………….
Date…………………….
Royal Dutch Association of Refrigeration (KNVvK)\
STEK (Emission Prevention Refrigeration Technology Foundation)
Footnotes
1 The proposal for a regulation of the European Parliament and of the Council on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 (COM(2022)0150 – _C9 0142/2022 – _2022/0099(COD))
2 DRAFT REPORT on the proposal for a regulation of the European Parliament and of the Council on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 (COM(2022)0150 – _C9 0142/2022 – _2022/0099(COD)) Committee on the Environment, Public Health and Food Safety
3 Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions REPowerEU plan. (COM/2022/230 final)
4 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Chemicals Strategy for Sustainability Towards a Toxic-free Environment. (COM(2020) 667 final)
5 The proposal for a regulation of the European Parliament and of the Council on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 (COM(2022)0150 – _C9 0142/2022 – _2022/0099(COD))
6 PFAS means per- and polyfluoroalkyl substances (PFASs) are a large class of thousands of synthetic chemicals that are widely used throughout society and found in the environment.
7 More information on the work the Norwegian Chemical Agency is conducting on F-gases that are PFAS can be found at this link: https://www.environmentagency.no/news/2022/the-universal-pfas-restriction-proposal-and-f-gases/
8 Natural refrigerants are naturally occurring substances that require little processing, e.g. ammonia, carbon dioxide, hydrocarbons (pentane, (iso)butane, propane, etc.), water, air. These substances occur abundantly in nature, with fully understood and accepted short and long-term environmental effects, being environmentally benign in cumulative quantities used as refrigerant. We also support systems that work without the use of refrigerants.
9 More information can be found at the following link: https://pubchem.ncbi.nlm.nih.gov/compound/Trifluoroacetic-acid
