EU F-GAS DEBATE: Initial reactions of associations and NGO on draft Regulation

By Klara Skačanová, Oct 08, 2012, 16:33 3 minute reading

Several associations such as the European Partnership for Energy and the Environment (EPEE) and the Air Conditioning and Refrigeration European Association (AREA) as well as NGO Environmental Investigation Agency (EIA) have given their first feedback to the early draft of the EU F-Gas Regulation. summarises their reactions and invites other stakeholders to participate in the discussion.

The leaked F-Gas proposal seen by many has brought about some discussions and first reactions to some of its provisions. The proposal is still in hands of the European Commission and by the time it is officially presented within few weeks, it is expected that certain parts of it will have changed.

EPEE welcomes phase-down

Brussels-based trade association EPEE has welcomed the phase-down principle, which will set a cap on annual consumption of HFCs: “The big advantage of a phase down is that you can spread the cost and not suddenly be faced with the massive costs linked to a ban,” said Andrea Voigt, EPEE director. “We don’t see the necessity of adding any bans on top of a phase-down,” stressed Andrea Voigt.

Nevertheless, in recent position paper EPEE supports a phase-down scenario “of 30% consumption reduction by 2020 and a potential 60 to 65% consumption reduction by 2030” compared to 2010 levels, while the European Commission draft proposal foresees a more ambitious 79% reduction by 2030 level compared to 2008-2011 levels.

EIA would like to see more bans

On the other hand, NGOs like EIA have repeatedly reminded that bans are not “sudden” in nature in the sense that they do not apply as of tomorrow, but rather set clear timelines that give industry certainty for their investments.

“The Commission’s own analysis shows that most sectors can ban HFCs in new equipment by 2020 or earlier and there is therefore no reason not to propose bans in all these sectors. There are many more low-hanging fruits to be picked”, said EIA Senior Campaigner Clare Perry.

“We welcome the draft proposal as a step in the right direction but it clearly doesn’t go far enough and could easily be seriously diluted if the lobbyists currently working behind the scenes for the HFC industry get their way”.

AREA pleased with ban on pre-charging equipment

According to the draft Regulation, the Commission plans to introduce a ban on pre-charging of equipment with HFCs before its first installation whether it is imported or manufactured in Europe so as to keep the integrity of the phase-down mechanism.

“A ban on pre-charging equipment is actually our concept”, said Graeme Fox, president of AREA. “We’ve been concerned about a number of cases across Europe where people have bought cheap split type units through retail outlets or over the internet, and installed them with absolutely no qualifications or competence. Our members have reported call-outs to put these installations right because they have not been installed properly and all the gas has been lost. So we want to make sure that we can close up the loophole by putting restrictions on the sales route, and stopping pre-charged equipment from getting in,” he added.

Some industry stakeholders have raised their concern that a ban on the supply of pre-charged equipment with HFCs would mean that companies that manufacture these products for internal and external EU market would need to establish two production lines. Others have also expressed the concern that on site charging could actually lead to increased emissions due to bad practices. However, the Commission has highlighted in the draft F-Gas Regulation that this requirement is necessary for the sake of keeping the integrity of the phase-down scheme since monitoring the amount of HFCs in pre-charged equipment would be rather difficult.

Let us know what you think

We are especially interested to hear the views of the heating and cooling industry as well as your individual standpoints on this important piece of legislation and its provisions. If you would like to participate in this 'EU F-Gas debate' series, please let us know for example:
  • What are your views on introducing bans on HFCs in certain sectors as reported in article 'EU F-GAS DEBATE: Draft Regulation gets tougher on HFCs'?
  • In which other sectors do you think there are (or will be within a certain period) energy efficient and cost-effective alternatives to HFCs?
  • What are the strong points or your concerns with regards to the provisions of the draft Regulation?

Send us your thoughts at or call us +32 3 230 3700.


By Klara Skačanová

Oct 08, 2012, 16:33

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