Document 8m3Z2VgzMMzjRLR0wynEG64Z

Brussels, 25 September 2023 Comments on the Annex XV report proposing a restriction of PFAS Addressing the biggest PFAS emitters: Thanks to natural alternatives, banning F-gases should be an easy win Our network of NGOs represents more than 35 million citizens and activists across Europe concerned about climate change, environmental deterioration, and public health endangerment. The under-signed NGO organisations fully support and demand an ambitious PFAS restriction. We applaud the dossier submitters in including F-gases in the scope of this proposal. We would like to convey that a world without F-gases is not only necessary, but possible. As the biggest PFAS emitters, F-gases pose a grave danger to human health and the environment. In this submission from a network of NGOs, we emphasize that restricting fluorinated gases under the PFAS restriction is both urgent and feasible. We showcase that there is a wide availability of F-gas-free technologies which allow for a full switch to natural refrigerants, commenting on the proposed derogations. Finally, we point out the importance of robust and updated standards for the successful uptake of new technologies and the good implementation of regulations. 1. TFA and COMPLEMENTING REGULATIONS The historic use of refrigerants perfectly illustrates the issue of regrettable substitution from ozone-depleting chlorofluorocarbons and hydrochlorofluorocarbons to highly climate damaging hydrofluorocarbons to environmentally-polluting hydrofluoroolefins. Throughout this long history of F-gas substitutions, natural refrigerant gases (ammonia, carbon dioxide, hydrocarbons, air and water) have been available and able to cover all current F-gas applications. Considering that more than half of all PFAS emissions originate from F-gases while energy efficient and cost effective natural alternatives are available, F-gases must be prioritised in the PFAS restriction. They are the low-hanging fruit that need to be picked in order to minimize PFAS pollution. The F-gas industry has put forward various spurious arguments attempting to weaken F-gas restrictions. More specifically, the industry has claimed: 1 1. "F-gases should be excluded from the PFAS restriction to avoid double-regulation with the EU F-gas regulation." When the F-gas Regulation revision proposal was published in April 2022 , the European Commission emphasized that the new climate regulation would focus on climate protection and the global warming potentials of F-gases. As a result, the environmental and potential health consequences of F-gases would have to be addressed under chemical regulations like REACH. The restriction of F-gases under REACH has no overlap with the F-gas Regulation, and therefore is not a case of double-regulation, but rather an essential complementary piece of legislation. 2. "The degradation of HFOs into TFA is not a problem, since TFA is naturally occurring and not harmful at the levels of the next decades." Currently, there is a worrying trend of increasing HFO-use, accompanied by an increasing development of additional gas blends that mix F-gases to achieve lower global warming potentials. HFO 1234yf is of particular importance since it degrades to more than 99% molar yield to TFA within less than 14 days and is the basis for most HFO blends.1 The wide uptake of HFO-1234yf, for example, in air-conditioning,has already led to the widespread increase of trifluoroacetate (TFA) concentration in water bodies everywhere2. The F-gas industry claims this is not a problem because of the natural occurrence of TFA. However, this claim has been proven incorrect due to insufficient evidence, as noted by the 2021 paper by Shira Joudan.3 The F-gas industry has tried to back their argumentation on the supposed harmlessness of TFA citing a UNEP report4 which states the following (page 209): 3.6.3 Environmental persistence is one of the criteria used to identify persistent organic pollutants (POPs), such as those regulated under the purview of the Stockholm convention. Persistence alone has been suggested to be a criterion for regulatory action. The suggested threshold for this classification is a degradation half-life > 6 months. The stability of TFA and its salts indicates a half-life >> 6 months, but our opinion is that persistence should only be considered as a regulatory criterion for substances that are moderately or highly toxic and/or are bioaccumulative in organisms and/or undergo trophic magnification. TFA does not bioaccumulate nor is it toxic at the low to moderate exposures currently measured in the environment or those predicted in the distant future. 1 Behringer et al. (2021): Persistent degradation products of halogenated refrigerants and blowing agents in the environment: type, environmental concentrations, and fate with particular regard to new halogenated substitutes with log global warming potential. On behalf of the German Environment Agency. Dessau-Rolau.; 2 Cahill (2022): Increases in Trifluoroacetate Concentrations in Surface Waters over Two Decades. Environmental Science & Technology 2022 56 (13), 9428-9434, DOI: 10.1021/acs.est.2c01826; Behringer et al. (2021): Persistent degradation products of halogenated refrigerants and blowing agents in the environment: type, environmental concentrations, and fate with particular regard to new halogenated substitutes with log global warming potential. On behalf of the German Environment Agency. Dessau-Rolau.; Sturm et al. (2023): Trifluoracetat (TFA): Grundlagen fr eine effektive Minimierung schaffen - Rumliche Analyse der Eintragspfade in den Wasserkreislauf. Texte 102/2023. On behalf of the German Environment Agency. Dessau-Rolau. 3 Joudan, Shira, Amila O. De Silva, and Cora J. Young. "Insufficient evidence for the existence of natural trifluoroacetic acid." Environmental Science: Processes & Impacts 23.11 (2021): 1641-1649. 4 Environmental Effects of Stratospheric Ozone Depletion, UV Radiation, and Interactions with Climate Change 2 The evaluation of persistence in this report breaches the EU classification of chemicals in the Delegated Regulation amending the CLP regulation that implemented new hazard classes, including very persistent, very mobile (vPvM), which are in force since 20 April 2023.5 Therefore, this evaluation is irrelevant for EU regulations and should not be considered. TFA fully fulfills the vPvM criteria and is therefore clearly harmful, which automatically means that TFA precursors must be restricted harshly in order to minimize TFA pollution of water bodies. The German Environment Agency classifies TFA as a high priority substance due to high amounts in the environment and insufficient regulation, demanding immediate action from regulators to minimize TFA entries to safeguard drinking water resources against contamination.6 Therefore, restricting TFA precursors, and therefore HFOs, is of highest priority.7 The regrettable substitution of one F-gas with another resulted -- so far -- in the hole in the ozone layer, the acceleration of climate change and now the persistent pollution of our environment and drinking water resources. All while natural alternatives are available. The restriction of F-gases in the PFAS restriction is of utmost importance to break the cycle of regrettable substitution and to safeguard water resources from persistent pollution. 2. WIDE AVAILABILITY OF NATURAL ALTERNATIVES for HVACR & switchgear applications F-gas-free technology is available for every application using natural alternatives: 5 https://echa.europa.eu/new-hazard-classes-2023 6 Arp et al. (2023): A prioritization framework for PMT/vPvM Substances under REACH for registrants, regulators, researchers and the water sector. Texte | 22/2023, On behalf of the German Environment Agency. https://www.umweltbundesamt.de/en/publikationen/a-prioritization-framework-for-pmtvpvm-substances (also see related publications for more information). 7 Sturm et al. (2023): Trifluoracetat (TFA): Grundlagen fr eine effektive Minimierung schaffen - Rumliche Analyse der Eintragspfade in den Wasserkreislauf. Texte 102/2023. On behalf of the German Environment Agency. https://www.umweltbundesamt.de/publikationen/trifluoracetat-tfa-grundlagen-fuer-eine-effektive 3 The Environmental Investigation Agency (EIA) and Greenpeace manage an online global database of energy-efficient cooling technologies that do not rely on F-gases. The database showcases the breadth of available natural refrigerant alternatives for each major cooling subsector - domestic, commercial, industrial and mobile refrigeration and air conditioning and heat pumps. The database can be found at www.cooltechnologies.org EIA has also produced a report on the Pathway to Net Zero Cooling including a product list of energy-efficient natural refrigerant products for the main cooling subsectors. This report also contains contextual information on the state of the market and current emissions trajectories for each sector. The report can be found here. HEAT PUMPS DOMESTIC Split heat pumps Split system air conditioners using propane are manufactured and used in China and India in vast numbers. Furthermore, the new IEC safety standard 60335-2-40 allows for a much higher propane charge in split systems as long as various safety measures are in place. In 2022, Midea launched their propane split AC system in Europe - this model is the only domestic AC unit to be awarded the German Blue Angel environmental label. Earlier this year Haier and Clivet exhibited propane split heat pumps for European markets at a major HVAC trade fair (ISH Frankfurt). Godrej and Midea also produce propane split systems in the hundreds of thousands available on Chinese and Indian markets. Split hydronic heat pumps Standard IEC 60335-2-40 allows for the safe use of flammable refrigerants for this system architecture by enabling enhanced tightness systems to be placed indoors in a ventilated enclosure.8 Monobloc heat pumps The number of monobloc heat pumps running on propane has been steadily growing in the EU with numerous companies having already offered these systems for some years. In 2022 and 2023, many more manufacturers, including large multinationals, also announced or launched new propane monobloc ranges to their portfolios. For example, DENSO sells CO2 heat pumps and TEON sells R600a (isobutane) models. Manufacturers producing or announcing launches of propane monoblocs include but are not limited to: 8 Pers Comm. Convenor of the Working Group for safety standard IEC-60335-2-40 4 Around 400 models of air-to-water heat pumps are already included in the German BAFA subsidy list9, showcasing the wide availability of heat pumps with natural refrigerants as well as the market reaction of heat pump manufacturers (comparison: the number of R290 heat pumps grows quickly; around 175 models in April 2023, which makes for a +228% in 6 months). Not only because R290 heat pumps show a great business case, they also have the highest energy efficiency which is another important factor in reducing the overall climate and environmental impact of the products.10 The following figure shows the efficiency of R290 air-to-water heat pumps based on available models on the German market in 2022:11 Figure: Energy efficiency of air-to-water heat pumps at 55 C with different refrigerants. R290 models are highlighted with green circles. Reference: Becker et al. (2022). While air-to-water heat pumps have and will have the highest share of domestic heat pumps, also water-to-water and brine-to-water heat pumps are already available with R290. Even for in-house-installation, R290 heat pumps are possible and available with adequate safety measurements like ventilation tubes to comply with safety standards.12 9https://www.bafa.de/SharedDocs/Downloads/DE/Energie/beg_waermepumpen_pruef_effizienznachweis.pdf?__blob=publicationFile&v= 8 (September 2023) 10 For the air-to-water heat pumps in the BAFA list (reference above), the R290 models are about 7% more efficient (ETAS 55) than the F-gas models. 11 Becker et al. (2022): Hauswrmepumpen mit natrlichen Kltemitteln. On behalf of the German Environment Agency. https://www.umweltbundesamt.de/publikationen/hauswaermepumpen-natuerlichen-kaeltemitteln 12 https://hautec.eu/sole-wasser-waermepumpe-r290/ (brine), https://hautec.eu/wasser-wasser-waermepumpe/ (water) 5  COMMERCIAL AND INDUSTRIAL There are several commercial13 and industrial heat pumps up to 32 MWh available using natural refrigerants, mostly using ammonia14 and CO215. Especially for these higher power level heat pumps, technologies using natural refrigerants have significantly better energy efficiency and therefore also an economic advantage. AIR CONDITIONING DOMESTIC SPLIT SYSTEMS: see split heat pumps COMMERCIAL AND INDUSTRIAL A non-exhaustive list of natural refrigerant chiller technologies and manufacturers can be found in EIA's Pathway to Net Zero Cooling Product List.16 These include GEA, Enex, Johnson Controls, Teko, Secon, SCM Frigo and Enerblue and cover the use of CO2, propane, water and ammonia as efficient and cost effective refrigerant choices. CO2 is well-suited for chillers operating in temperate climates, especially where heat recovery can be employed to raise efficiency. Water as a refrigerant (R718) has historically been used in limited applications, but increased research has led to water being used for more general chiller applications, including cooling for industrial processes, data centres and industrial and commercial air-conditioning. Ammonia and hydrocarbons are also used in chiller applications. Most chillers using these refrigerants are located outdoors or in machinery rooms, which eases the burden of additional safety measures for handling toxicity and/or flammability. MOBILE European car manufacturer Volkswagen uses CO2 in its ID range of EVs. Mahle, Valeo and Sanden are some of the manufacturers of CO2 MAC systems for passenger cars with Sanden stating that their CO2 system increases driving range up to 50% in electric vehicles in 17 winter conditions. Currently around 400,000 cars in Europe use CO2 as MAC refrigerant, with 5.5 million anticipated to be using this technology by 2028.18 However, the majority of car manufacturers in the EU did opt to transition to HFO-1234yf when the MAC Directive came into effect. This is of concern as leakage rates in MAC systems can be as high as 125% of the original charge over 10 years,19 so the choice of refrigerant has environmental impacts beyond GWP, especially given the TFA breakdown product of HFO-1234yf. 13 e.g. https://clade-es.com/heat-pumps/clade-heat-pumps/ and https://www.engie-refrigeration.de/en/heating/thermeco2-heat-pump 14 e.g. https://www.gea.com/en/products/refrigeration-heating/heat-pumps/index.jsp?i=beverage 15 e.g. https://www.man-es.com/process-industry/campaigns/industrial-heat-pumps-and-ems#download 16 Environmental Investigation Agency, (2021). `Pathway to Net Zero Cooling Product List', page 20 and p47. Available here. 17 Environmental Investigation Agency, (2021). Pathway to Net Zero Cooling Product List, page 23. Available here. 18 Information shared at European Parliament event on natural refrigerants 25 January 2023. Further details available here. 19 Methodological Tool: Calculation of baseline, project and leakage emissions from the use of refrigerants, Clean Development Mechanism, United Nations, 2017. In Michael Ayres, Natalya Stankevich, Adam Diehl, (2020). `Mobile Cooling: Assessment of Challenges and Options', World Bank. Available here. 6 CO2 systems are also available for bus air conditioning systems. Konvekta systems using 20 CO2 have a 60% market share in Germany. Other manufacturers of CO2 bus MAC systems are Daimler, Valeo, Panasonic, BOCK and Bitzer while Aurora produces a propane heat 21 pump system which reportedly reduces energy consumption of a bus by 40%. CO2 system producers note energy efficiency improvements of up to 20%, energy consumption reductions of 40% and increased range of electric buses of up to 60%.22 F-gas-free MAC systems in trains have been used by German train operator Deutsche Bahn 23 for two decades , with CO2 heat pump systems which reduce energy consumption and provide both cooling in the summer and warming in the winter currently being tested.24 Austrian train operator BB/s test study on Liebherr's CO2 AC system for long distance trains showed a 30% energy efficiency improvement from the previous HFC system. Liebherr stated: "In the more than three-year eco2jet demonstration phase from May 2018 to August 2021, the air-conditioning system with CO2 as refrigerant proved to be a reliable and technologically mature concept. The environmentally friendly, energy-saving regular operation of an BB long-distance passenger train with this pioneering technology on board is thus guaranteed."25 Additionally, Chinese firm CRRC Dalian Locomotive Research Institute has also developed a CO2 MAC system for rail transport, whilst German company Woelfle advertises a new Heating Ventilation and air-conditioning (HVAC) system for railways using propane and water in compliance with all safety standards.26 REFRIGERATION COMMERCIAL AND INDUSTRIAL Commercial refrigeration systems using CO2 have become the norm across the EU, even in warmer southern EU climates. The so-called `CO2 equator' where CO2 systems were less efficient in warmer climates has mostly been solved with the introduction of transcritical CO2 and multi-ejectors. A 2018 study found that "...multi-ejector "CO2 only" systems can outperform R404A-, R290-, R1234ze-, R134a-, R450A- and R513A-based solutions in an average-size supermarket located in various cities below the so-called "CO2 equator". In fact, energy savings as well as reductions in environmental impact respectively up to 26.9% and 90.9% were estimated over conventional hydrofluorocarbon (HFC)-based solutions for the scenario including the AC demand." The authors concluded that use of transcritical CO2 multi-ejector systems integrated with the air-conditioning (AC) enabled the so-called `CO2 equator' to be pushed further South than Northern Africa.27 For example, in 2018, the first CO2 transcritical supermarket system was installed in Jordan, designed to provide efficient 20 Hayes (2022) `Konvekta CO2 Heat Pump Used in More than 60% of Germany's Electric Buses' R744.com News Item 26 July 2022. 21 Environmental Investigation Agency, (2021). Pathway to Net Zero Cooling Product List, page 23. 22ibid 23 https://nachhaltigkeit.deutschebahn.com/en/measures/climatesystem 24 Pilar Aleu, (March 2019). `Deutsche Bahn to grow natural-refrigerant train fleet`. Hydrocarbons21. 25 Illana Koegelenberg, (August 2022). `Austrian passenger train shows 30% energy saving with CO2 air-conditioning'. R744. Available here. 26 https://www.woelfle-gmbh.de/en/blog/cases/bahn-hv-ac/ 27 Gullo P, Tsamos KM, Hafner A, Banasiak K, Ge YT, Tassou SA, Crossing CO2 equator with the aid of multi-ejector concept: A comprehensive energy and environmental comparative study, Energy (2018), doi: 10.1016/j.energy.2018.08.205. 7 cooling with ambient temperatures reaching 32C in the summer months and recorded energy savings of 30%.28 Europe now has over 57,000 transcritical CO2 refrigeration installations (a 244% increase from 16,000 in 2018) and is now an SME manufacturing hub.29 In February, at Euroshop 2023, the largest retail trade fair in the world, of the hundreds of supermarket fridges and freezers on display, only a tiny fraction contained fluorinated gases, with every other unit utilising either CO2 or propane. Given the retail sector's commercial drive it is highly unlikely that CO2 systems would propagate to such an extent if they could not compete with conventional refrigeration systems on energy efficiency and cost substantially more to run. BELOW - 50C Even for ultra-low temperatures, F-gas free technologies for up to minus 110C are available using natural refrigerants like air30, showcasing that no PFAS are needed. TRANSPORT Transport refrigeration emissions are a small percentage of total F-gas emissions. However, transport refrigeration units typically have high leakage rates, short lifetimes and poor end of life refrigerant recovery making this a key subsector for urgent action to address F-gas emissions. Emissions from transport refrigeration systems can account for as much 40% of a vehicle's total emissions, half of which can be due to refrigerant leakage.31 Lifetime emission rates of transport refrigeration systems are the highest of all non-emissive sectors behind ship air conditioning at 25% for vans, 18% for trucks and trailers and 30% for fishing vessels.32 The European Commission's impact assessment for the F-gas Regulation revision found that CO2 and propane will be suitable for the bulk of transport refrigeration applications. 33 There are already CO2 transport refrigeration units on the market. Greencold is a British company that provides refrigerated trailers cooled with CO2 and reports 16% energy savings for refrigeration and 25% for freezing compared to a traditional HFC-404A system.34 As the natural refrigerant market develops, these systems are expected to get even smaller and more lightweight. Energy savings from these efficient natural refrigerant systems will offset the added weight. To allay safety concerns of flammable refrigerants, the use of propane in secondary systems can reduce the charge size. Austrian company pbx has developed a propane based 28 Climate & Clean Air Coalition, (November 2018). The Middle East's first CO2 supermarket reveals energy reduction of 30%. Available here. 29 ATMOsphere, (2022). Natural Refrigerants: State of Industry, page 21. Available here. 30 https://mirai-intex.com/products/closed-cycle/c2 31 Green Cooling Initiative `Global greenhouse gas emission from RAC sector' and H Stellingwerf et al (2018) `Reducing CO2 emissions in temperature-controlled road transportation using the LDVRP model', Transportation Research PartD: Transport and Environment vol 58. 32 Oko-Insitut et al (2022). Support Contract for an Evaluation and Impact Assessment for amending Regulation (EU) No 517/2014 on fluorinated greenhouse gases. Annexes. Table 2, p17. Available here. 33 Environmental Investigation Agency, (2021). `Pathway to Net Zero Cooling Product List', page 49. Available here. 34 Panasonic, `Greencold go large with Panasonic CO2 refrigerated trailer'. Available here. 8 refrigerated system for commercial electric vehicles (ecos M24).35 The refrigerant circuit is hermetically sealed and contains only 140g of propane.36 Additionally, ECOOLTEC Grosskopf Gmbh provides electrically driven transport refrigeration units for truck, semi-trailers and rigid vehicle bodies that uses a small charge of propene with CO2 in the secondary circuit.37 Furthermore, F-gas-free systems using cryogenic liquid CO2 or liquid nitrogen are offered by some of the largest manufacturers, including Air Liquide, Linde and Thermo King.38 INSULATION IN SWITCHGEAR With the anticipated phase-out of SF6 as insulation gas in switchgear within the EU F-gas regulation, an uptake of PFAS substitutes can be seen, which is entirely unnecessary considering the wide availability of alternatives based on natural origin gases. As seen in the figure below, manufacturers produce f-gas-free switchgear on all voltage levels: Figure: F-gas-free switchgear by several manufacturers on all voltage levels. Source: CIGRE, August 2022, Paris. An alliance of leading switchgear manufacturers fully supports F-gas-free technology and is in favour of the restriction of PFAS as insulation gases, and explains the importance of F-gas-free switchgear.39 Outside of this alliance but with the same intention regarding F-gas-free technology, EATON promotes F-gas-free switchgear on medium voltage level.40 In the meantime, even more switchgear manufacturers (ABB and Ormazabal)41 have F-gas-free switchgear in their portfolios (medium voltage level, primary and secondary distribution). Since some switchgear manufacturers offer PFAS as well as F-gas-free 35 For more information please visit https://www.pbx.at/en/ 36 Christina Hayes, (September 2022). `First R290Refrigeration Unit for Electric Vehicles to Launch at IAA Transportation Conference'. Hydrocarbons21. Available here. 37 For more information please visit https://ecooltec.com/en/ 38 Environmental Investigation Agency, (2021). `Pathway to Net Zero Cooling Product List', page 49. Available here. 39 https://www.switchinggearsfornetzero.com/faqs/ 40 e.g. https://www.eaton.com/de/de-de/catalog/medium-voltage-power-distribution-control-systems/xiria.html 41 https://new.abb.com/medium-voltage/switchgear/gas-insulated-switchgear/iec-gis-primar-distributi on/primegear-zx0 with "dry air" (ABB) and https://www.ormazabal.com/en-gb/ sbp.zero24 and cgm.zero24 with "industrial natural air" (Ormazabal) 9 switchgear at the moment, a clear restriction of PFAS is necessary so that these manufacturers can focus their product portfolios on natural alternatives. While not all product gaps are yet filled with SF6-free technology, switchgear manufacturers have said to close portfolio gaps with F-gas-free technologies within the time-frames of the EU F-gas regulation. No PFAS substitutes are needed as interim solutions. 3. PREVENT LOOPHOLES due to outdated standards Standards are crucial for the transition to natural refrigerants as they signal to the industry the need for change and adaptation. Despite the natural alternatives available, European companies have been delaying the switch until the standards are adopted. Consequently, they continue installing appliances containing F-gases as the sector relies on the slow pace of lengthy procedures. Outdated standards and building codes have posed significant challenges to the adoption of natural refrigerants in recent years on the grounds of safety concerns. Some progress has been achieved at international level, particularly with the revision of two key standards within the International Electrotechnical Commission (IEC), namely the IEC 60335-2-89 and IEC 60335-2-40. It is imperative that European and national standards are brought up to date to align with the revised allowable charge sizes for flammable refrigerants, as outlined in IEC 60335-2-89 and IEC 60335-2-40. Though the first of the two standards was approved in May 2019, the European adopted version, EN IEC 60335-2-89 was published at the end of 2022. In other words, it took three and a half years from the moment the international standard was approved until the European industry could confidently start applying it. The standardisation process for EN IEC 60335-2-40 is ongoing, but still it is coming too late. Furthermore, existing horizontal standards that hinder the adoption of natural refrigerants must be revised, such as the EN 378 series "Refrigerating systems and heat pumps -- Safety and environmental requirements". Because it is a horizontal standard, EN 378 must be changed to lift the block on natural refrigerants. Otherwise, installation in buildings will continue to be problematic. In addition, member states should be responsible for continuously identifying and addressing barriers created by restrictive building codes and local regulations, which prohibit the use of flammable refrigerants, including propane. Such restrictions currently exist, for example, in France and Italy. 4. DEROGATIONS For the undersigned groups, it is a top priority to change the following derogation: "Refrigerants in HVACR-equipment in buildings where national safety standards and building codes prohibit the use of alternatives; NO TIME LIMIT" 10 The time unlimited derogation could open up a loophole allowing Member States, regions or cities to introduce similar restrictions in order to continue to use climate and environmentally damaging fluorinated refrigerants. The derogation must: a) not be time unlimited as PFAS free alternatives already exist on the market and continuing to grow market share clearly showing that PFAS are not needed; b) be linked to the international standard IF maintained with a stricter time limit , and not individual city or state legislation which should be aligned with international standards; c) be more granular, if maintained, and not simply apply to all HVACR applications as the sub-sectors this term covers are numerous, and only very few do not currently have mature PFAS-free alternative technologies available on the market. 5. CONCLUSION Advocating for the prohibition of F-gases, which are major PFAS emitters, marks a crucial stride in safeguarding both human health and the environment. It represents an easily attainable goal in the broader endeavor to reduce PFAS pollution and rectify past substitution errors. Natural refrigerants are proven, energy-efficient, and cost-effective alternatives to F-gases and the substantial existence of progressive industry making these options available is telling. The moment to take decisive action is upon us, and the benefits for our planet and future generations will be immeasurable. Derogations should be carefully managed to avoid loopholes. PFAS-free alternatives exist on the market and new solutions are being developed as we speak, making time unlimited derogations unnecessary. Such decisions must be aligned with international standards and not reflect national or regional positions. Finally, the HVACR subsectors that lack mature PFAS-free alternative technologies are limited. Therefore, the derogation cannot apply to the entire sector and a granular approach is the correct path to follow. -- Deutsche Umwelthilfe (DUH) ECODES European Environmental Bureau (EEB) Environmental Investigation Agency (EIA) ZERO 2Celsius Environmental Coalition on Standards (ECOS) 11