Document NexvG00dY0x9eQZLnbx76Y04p

From: Sent: To: PF Sante Publique - FOD Volksgezondheid) Secretariat EPEE Global < @epeeglobal.org> vendredi, 8 septembre 2023 14:04 Cc: Subject: Follow Up Flag: Flag Status: i RE: Letter : F-gas Regulation Revision Follow up Flagged Dear Mr As a follow-up to our mail of yesterday regarding the F-gas Regulation revision and the upcoming ENVI Working party on the 12th of September, we would like to re-emphasise again our key concerns as the representatives of the RACHP industry. We cannot accept any full F-gas bans on any application within our scope of products, namely bans 11, 12, 13, 15, 17, and 18 within Annex IV as well as relating to chillers: A full F-gas ban will result in an ineffective policy -- essentially shooting ourselves in the foot as we strive for lower emissions and energy independence. We must embrace an energy efficiency and safety-first principle, increasing Ecodesign requirements to support EU and global efficiency goals, while sustaining the Green Deal and Net Zero Industrial Act. The F-Gas Regulation revision is a separate process from REACH restriction process. The ongoing process on a potential PFAS restriction should be tackled in a dedicated proposal that is currently being examined by the European Chemicals Agency (ECHA). We would also like to highlight that concerns about PFAS contained in some F-gas refrigerants are not appropriate to this revision. Recent findings from the UNEP 2022 Assessment Report of the Environmental Effects Assessment Panel (EEAP) to the Montreal Protoco' concluded that no harm is anticipated even when assessing the growing use as replacement of ozone depleting substances. Furthermore, no impact assessment was undertaken on any full F gas bans, nor on the proposed Bans 17/18 with a GWP150. We wish to ensure to keep the GWP 150 but in the case of Ban 18 above 12kW, we require GWP 750 and for Ban 17 above 12kW, we also require GWP 750. We approve the approach for a HFC consumption phase down to zero by 2050 with the condition of a review clause for uses that still would require HFCs. We trust that the above concerns will be considered during your meeting, and we thank you for your attention. Kind regards, Director General EPEE 1 From: Secretariat EPEE Global Sent: Thursday, 7 September 2023 11:48 To: . Cc: Subject: Letter : F-gas Regulation Revision Importance: High Dear M 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 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 2 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 @epeeglobal.org, Tel: +32 496 86 61 87. Sincerely, irector General European Partnership for Energy and the Environment 1 2022 Assessment Report of the Environmental Effects Assessment Panel Report: "the accumulated amount ofTFA 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. 3 Attachments: EPEE member factory map 4  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. 5