Document 1k5vXDZwkv63eVZNedo1O15m

EFCTC work on the proposed REACH restriction To FPP4EU Collaboration Platform 15 June 2022 The European Chemical Industry Council, AISBL - Rue Belliard, 40 1040 Brussels - Belgium Transparency Register n6487914232390 Outline 1. About us 2. Fgases and their uses 3. HFCs, HFOs, and nonfluorinated refrigerants: differences 4. How Fgases are regulated 5. Why are Fgases used? 6. EU Action on PFAS - Target - Why Fgases are different and should not be restricted under REACH 7. Reviewed Fgas Regulation proposal 8. What about TFA? 9. Practical examples of potential impacts of a ban on Fgases 10. What EFCTC is doing - Cooperation and reach out - Independent SocioEconomic Analysis (SEA) 11. EFCTC position and messages 2 1. About EFCTC The European FluoroCarbons Technical Committee is a sector group of the European Chemical Industry Council (Cefic) and represents the companies Arkema, Chemours, Daikin Chemicals, Honeywell and Koura. 3 2. What are FGases and what are they used for 4 3. HFCs, HFOs, and nonfluorinated refrigerants: differences Fluorinated gases Different generations developed Safe to use, as they are nontoxic and generally non flammable Currently most used Fgases are: HFCs and HCFCs higher GWP; phased down under ODS and Fgas Regulations HFOs and HCFOs very low GWP; Containment/reporting included in new Fgas; suitable substitutes for HFCs Nonfluorinated refrigerants Substances with low GWP (01) Safety issues in terms of flammability, pressure and toxicity Production linked to fossil fuel production Examples: CO2 (R774), NH3 (R717), Hydrocarbons: Isobutane (R600a) and Propane (R290) Note: no one size fits all: each application might require a different gas or blend based on their properties and safety in use 5 4. How Fgases are regulated Source: Danfoss DKRCC.PB.000.W3.22 The use of Fgases has been already successfully regulated for several years 6 5. Why Fgases are used? Fgases can confer energy efficiency and safety when used in properly designed and operated equipment. They play a key role in decarbonising critical European industries relying on heating and cooling technology. Ref. https://www.fluorocarbons.org/applications/ 7 6. EU Action on PFAS Target PFAS in the scope of the RMOA* prepared by the 5 initiating countries have the following structural formula (dated 23 February 2022) and definition: PFAS are defined as substances that contain at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom (without any H/Cl/Br/I atom attached to it). Meaning: fluorinated substances that contain at least one aliphatic carbon atom that is both, saturated and fully fluorinated, i.e. any chemical with at least one perfluorinated methyl group (CF3) or at least one perfluorinated methylene group (CF2), including branched fluoroalkyl groups and substances containing ether linkages fluoropolymers and side chain fluorinated polymers. The majority of F-gases fall into the current scope *Regulatory Management Option Analysis (RMOA) is an assessments of regulatory needs 8 6. EU Action on PFAS Why Fgases are different and should not be restricted under REACH 1. Different chemical properties Fgases: Do not persist and degrade completely in the atmosphere The degradation processes for Fgas are well known Many only create nonpersistent degradation products that occur naturally. A small group breakdown to produce very small concentrations of a naturally occurring inert and nonbioaccumulative substance called trifluoroacetic acid (TFA), which is persistent Fgas Reg is currently under revision EFCTC Website, TFA as an atmospheric breakdown product 2. Already successfully managed by Fgas Reg (517/2014) & MAC Dir (70/156/EEC) Aims at reducing Fgas emissions by two thirds of 2010 levels by 2030 Quota system Limiting and phasing down the total amount of the most important Fgases Banning the use of Fgases in some new types of applications Preventing/containing emissions of Fgases from existing equipment MAC Directive prohibits the use of Fgases with a GWP 150 in new types of cars and vans introduced from 2011, and in all new cars and vans produced from 2017 EFCTC Position Paper "Published evidence supports very low yields of TFA from most HFOs and HCFOs", 9 August 2021 9 7. Reviewed Fgas Regulation proposal Steps in the right direction Enhanced control of placing HFCs on the market, effective vetting of all companies Reinforced legal provisions facilitating improved border control and enforcement against illegal trade Improved containment measures, endoflife treatment Alignment with international agreements (Kigali Amendment to the Montreal Protocol) Room for improvement Further engagement with value chain to understand impact of phase down More frequent mandatory leakage controls Mandatory reclamations Better containment provisions can address the persistency concerns for PFAS 10 8. What about TFA? Global effects of TFA from HFCs and HFOs have been studied extensively1: The Environmental Effects Assessment Panel (EEAP) of the UN Environment Programme (UNEP) provides a comprehensive summary (2021) for Trifluoroacetic acid (TFA) and points out that most PFAS have different properties from TFA2. - Trifluoroacetic acid continues to be found in the environment, including in remote regions, although not at concentrations likely to have adverse toxicological consequences 3,4. - Current concentrations of TFA salts and related compounds in soil and surface waters do not present risks of adverse effects in aquatic and terrestrial plants and animals. - Humans could be exposed to TFA via drinking water and food but there is no evidence to date of adverse effects on health - TFA salts are of low acute toxicity to mammals under conditions relevant to environmental exposure. - There are multiple sources of TFA: Industrial processes and as a transformation product of pharmaceutical and agricultural products. TFA is also a transformation product of hydrofluorocarbon refrigerants in the atmosphere Revision of FGas Reg offers a good opportunity to minimise emissions of Fgases and hence reduce the quantities of TFA generated from their breakdown. 1: Neale, R. E., Barnes, P. W., Robson, T. M., Neale, P. J., Williamson, C. E., Zepp, R. G., et al. (2021). Environmental effects of stratospheric ozone depletion, UV radiation, and interactions with climate change: UNEP Environmental Effects Assessment Panel, Update 2020. Photochemical & Photobiological Sciences. https://doi.org/10.1007/s4363002000001x. See sections 7.8 to 7.11 for Trifluoroacetic acid (TFA). 2. https://ozone.unep.org/science/assessment/eeap 3. David, L. M.; Barth, M.; HglundIsaksson, L.; Purohit, P.; Velders, G. J. M.; Glaser, S.; Ravishankara, A. R. Trifluoroacetic acid deposition from emissions of HFO1234yf in India, China, and the Middle East Atmos. Chem. Phys., 2021. 4. Lindley, A.; McCulloch, A.; Vink, T. Contribution of Hydrofluorocarbons (HFCs) and HydrofluoroOlefins (HFOs) Atmospheric Breakdown Products to Acidification ("Acid Rain") in the EU at Present and in the Future. Open J. Air Pollut., 2019, 8, 8195. 11 9. Practical examples of potential impacts of a ban on Fgases Without careful consideration and design of any restriction there are potentially huge changes to everyday life for people living inside, and even possibly outside, the EEA. For example: - Obsolesce of hundreds of millions of existing Refrigeration, Air conditioning and Heat Pump systems including car, van and truck Air Conditioning systems when maintenance or servicing is required due to unavailability of refrigerants. - Existing standards, regulations and codes impose constraints on location and charge size for all refrigerants, constraining systems and performance in the absence of Fgases. Some current designs are impractical without Fgases. - Energy efficient solutions for refrigeration, air conditioning and heat pump systems could be limited. - Safe operation could be compromised without FGas (mild or no flammability, nontoxic). 12 10. What EFCTC is doing Cooperation and reach out Liaising with downstream users and associations to provide support in understanding the possible restriction. - EPEE, EHPA, APPLiA, EHI and others Cooperation with authorities - European Commission, Member States, European Chemicals Agency 13 10. What EFCTC is doing Independent SocioEconomic Analysis (SEA) Socioeconomic assessment on the impact of a possible ban on Fgases and of the contribution certain fluorinated gases (Fgases) to the economy and wider society Several downstream users and associations have joined the effort We aim at providing the authorities with complete set of information on Fgases Our SEA will be used to support a response to the European Chemicals Agency's (ECHA) consultation on a new proposal to restrict PFAS that includes Fgases The extent of this restriction is yet to be entirely defined and can still change along the consultation process 14 10. What EFCTC is doing Independent SocioEconomic Analysis (SEA) Objectives of the SEA: Provide an overview of the direct and attributable economic contribution of the Fgas industry, with support from members of EFCTC Outline economic and societal benefits generated along the downstream value chain from the use of Fgases in various critical applications or sectors; your production is one of such critical applications of Fgases Identify alternatives to Fgas in various critical applications and their costs compared to the current situation with the use of Fgases, thanks to your contribution to this consultation Data gathering/literature review of relevant market & PFAS Mapping of substances/ mixtures to priority uses Stakeholder Consultation (Survey & Interviews) Volume & Sales Assessment Economic Assessment to the Economy & Society Economic Assessment of F-gases by use 15 11. EFCTC position and messages `PFAS' is a big universe of thousands of chemicals. Certain Fgases (HFC, HFO and HCFO) are a category in `PFAS', but do not share the same chemical properties or uses with other categories of PFAS. Subgrouping in PFAS must be made for better hazard and risk assessment as well as assessment of the needs for a REACH restriction. EFCTC believes that concerns with Fgas could be, and are being, addressed in a different manner, and that Fgas should not be covered by a global REACH Restriction to avoid any conflict with other legislation, i.e. FGas Regulation. Fgases contribute to EU Green Deal achievements and decarbonisation goals. 16 11. EFCTC position and messages FGases are already successfully managed by the Fgas Regulation currently undergoing a review process to strengthen the containment provisions EFCTC calls for a sensible and sustainable regulatory approach Double regulation of Fgases would put an excessive burden on downstream users and the uncertainty would put innovation at risk Green Deal and decarbonisation goals difficult to achieve EFCTC encourages authorities to engage in dialogues with downstream users to better understand the possible repercussions on the sector 17 Questions? Contacts: Elisa Consoli, @cefic.be EFCTC Secretariat EFCTC newsletter: Home - Fluorocarbons STAY INFORMED Subscribe to our monthly newsletter and stay on top of the latest developments. Previous newsletters consent to the storage of my data according to the Privacy Policy I'm not a robot eCAP--CHA. Fri.,' 'ens ii tidsbwas EFCTC 18 Thank you. About Cefic Cefic, the European Chemical Industry Council, founded in 1972, is the voice of large, medium and small chemical companies across Europe, which provide 1.1 million jobs and account for 15% of world chemicals production. Cefic members form one of the most active networks of the business community, complemented by partnerships with industry associations representing various sectors in the value chain. A full list of our members is available on the Cefic website. Cefic is an active member of the International Council of Chemical Associations (ICCA), which represents chemical manufacturers and producers all over the world and seeks to strengthen existing cooperation with global organisations such as UNEP and the OECD to improve chemicals management worldwide The European Chemical Industry Council, AISBL - Rue Belliard, 40 1040 Brussels - Belgium Transparency Register n6487914232390 REACH Restriction process Ongoing Q1 2023 By Q1 2024 202425 MidJanuary 2023 20