Document LJ5b9jVMjjqgqDYy6176g8ZX5

From: Sent: To: (SPF Sante Publique - FOD Volksgezondheid) Secretariat EPEE Global < @epeeglobal.org> mercredi, 27 septembre 2023 13:55 Cc: Subject: Importance: Letter : F-gas Regulation Revision High Dear Mr. In light of the announced COREPER I meeting scheduled for this Friday, September 29th, to discuss the F-gas Regulation Revision, the European Partnership for Energy and the Environment (EPEE) and its 40+ members, employing more than 200,000 people in 22 European countries, is extremely concerned by the European Parliament's proposal regarding full F-gas prohibitions for several product categories, especially small splits below 12kW. This proposal would hinder building a successful, pragmatic and implementable Regulation and access to affordable, safe and energy efficient technologies for European consumers. EPEE members manufacture products using both fluorinated and non-fluorinated refrigerants, often referred to as "natural" refrigerants. We have consistently provided feedback and support during the current revision of the F-gas Regulation to support the EU's sustainability goals and ensure that a practical and sustainable regulation is adopted. However, we are increasingly concerned that our collective goal and efforts are now in jeopardy. We believe that the proposed full product bans on all types of F-gases (which include HFCs as well as ultra-low GWP HFOs and their blends) risk undermining our efforts to lower emissions and achieve energy independence for several reasons: Adding full F-gas bans in Annex IV without a proper impact assessment would put a halt on manufacturer innovation and research & development, and is not justifiable. A ban cannot be compensated by pushing the ban dates to a distant future with a review clause in 2030. The review would merely be a report by the EU Commission with no guarantee that a legislative proposal would be formulated and accepted by the co-legislators in due course. Such process would leave the industry in uncertainty for several years, before and after 2030. We therefore ask that an impact assessment be completed prior to any full F-gas ban, similar to the review clauses foreseen in other sectors such as mobile applications. It is asking industry to invest millions on uncertainties and comply with poor regulation. Full F-gas bans would ban HFO refrigerants and their blends, which have equally low GWP impacts as non-fluorinated refrigerants and are not part of the global Montreal Protocol HFC phase down. A full ban is unjustifiable and discriminatory under WTO trade rules. HFOs and their blends will be essential to meet the HFC phase down goals, together with other options such as non-fluorinated and reclaimed refrigerants. No one option can solve the HFC phase down challenge on its own. While non-fluorinated refrigerants are also a part of the solution, they have limitations in terms of safety, energy efficiency, affordability, and suitability for all market needs. Even when exemptions for such reasons are foreseen, it must be taken into account that the availability of virgin HFCs will drastically reduce due to the quota system. 1  The goals to reduce HFCs and emissions, give more tools to customers, and combat illegal trade has already been reached in the negotiations. Now, negotiators are going beyond their initial mandate. What began as a well-meaning regulation has become political and dogmatic -- disregarding all scientific fact and logic. We strongly urge the decision-makers to oppose a full F-gas ban and to promote an energy efficiency-and safety-first approach to support EU and global climate goals, while aligning with the Green Deal and Net Zero Industry Act. In the air conditioner, heat pump, rooftop, and chiller markets, limiting options to "natural refrigerants only" will hinder widespread decarbonization. This may leave many EU citizens who lack space for a propane heat pump with no choice but to opt for fossil fuel heating combined with low efficiency portable air conditioners. Our industry is committed to deploying millions of heat pumps (and has been investing a lot to do so), both with and without F-gases, to meet our efficiency goals. We urge you to reject any plan to ban all F-gases under Annex IV and to maintain appropriate GWP limits as a viable solution for the RACHP sector. We appreciate your consideration of our concerns and look forward to a constructive dialogue on this critical matter. Sincerely, Director General EPEE -- European Partnership for Energy and the Environment The Voice of the Refrigeration, Air Conditioning and Heat Pump Industry in Europe Avenue des Arts, 44, B-1000 Brussels EU Transparency Register Nr. 22276738915-67 Email: @epeeglobal.org Website: www.epeeglobal.org Follow us on Twitter @EPEESecretariat From: Secretariat EPEE Global Sent: Thursday, 7 September 2023 11:48 To: a Subject: Letter : F-gas Regulation Revision Importance: High Dear Mr ear Mr. All the member companies and associations of the European Partnership for Energy and the Environment (EPEE) are fully committed to EU carbon neutrality by 2050 and represent the industries that will deliver on decarbonising buildings and cold chains through innovative heating, cooling, and refrigeration solutions. Our members employ more than 200,000 people in 22 European countries across more than 100 factories and R&D centres (see map below), representing substantial investments in the Europeanindustrial fabric. EPEE members manufacture products 2 that use both fluorinated and non- fluorinated (so-called "natural") refrigerants, and we have consistently provided feedback andguidance on the current revision of the Fgas Regulation to support the EU's sustainability goalsand ensure that workable and pragmatic legislation is adopted. However, this goal is now in jeopardy, as negotiations in the final round of the trilogues revolvearound the incorrect assumption that F-gas refrigerants are simple to replace. A full F-gas ban (HFCs and ultra-low GWP HFOs) as proposed by the European Parliament is totally contradictory to the Commission's original proposal. A full F-gas ban will result in an ineffective policy - essentially shooting ourselves in the foot aswe strive for lower emissions and energy independence. We must embrace an energy efficiencyand safety-first principle, increasing Ecodesign requirements to support EU and global efficiency goals, while sustaining the Green Deal and Net Zero Industrial Act. We would also like to highlight that concerns about PFAS contained in some F-gas refrigerantsare not appropriate to this revision. Recent findings from the UNEP 2022 Assessment Report of the Environmental Effects Assessment Panel (EEAP) to the Montreal Protocol concluded that no harm is anticipated even when assessing the growing use as replacement of ozone depletingsubstances.1 Some believe that all F-gases can simply be replaced with so-called "natural" refrigerants. Whilenon-fluorinated refrigerants are part of the solution to an HFC phase down and are already being used by our members, they also come with caveats on safety and affordability, meaningthey cannot fulfil all market needs of member states. They also demand more consideration with regards to space. Taking the example of residential heat pumps, mainly detached homes with gardens will be able to `easily' use non-F-gas refrigerants. There is a particular concern in the air conditioner, heat pump, rooftop and chiller markets, where a restriction to "natural refrigerants" only would result in less widespread decarbonization of heating in homes and commercial and industrial spaces. Indeed we risk creating a predicament in which many may be forced to keep or install an inefficient fossil fuel appliance rather than an efficient and climatefriendly system. Our industry is committed to rolling out the millions of heat pumps required to achieve our efficiency goals, with and without F-gases. Weeks remain to create a clear, balanced, and workable F-gas revision. Now is the time to be realistic: We caution that the revision must notrestrict innovation in such a manner that future alternatives would not be allowed simply because they contain fluorine. We urge you not to ban all F-gases under Annex IV and to maintain appropriate GWP limits as a solution for the RACHP sector in the future. In attachment you can find the ambitious and feasible joint industry alliance proposal. On behalf of EPEE, I thank you for your attention and consideration. Should you require furtherinformation please do not hesitate to contact me at Tel: 3 Sincerely, , Director General European Partnership for Energy and the Environment 1 2022 Assessment Report of the Environmental Effects Assessment Panel Report: "the accumulated amount of TFA is expected to increase because of the planned replacement of ozone depleting substances with short-livedfluorinated chemicals. However, based on projected future use of these precursors of TFA, no harm is anticipated." Page 25. -- 4 Attachments: EPEE member factory map 5  Joint industry alliance proposal ABOUT EPEE: The European Partnership for Energy and the Environment (EPEE) represents the refrigeration, air-conditioning and heat pump industry in Europe. Founded in the year 2000, EPEE supports safe, environmentally, and economically viable technologies with the objective of promoting a better understanding of the sector in the EU and contributing to the development of effective European policies. Please see our website (www.epeeglobal.org) for further Information. 6