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From: Sent: To: Cc: Subject: (SPF Sant Publique - FOD Volksgezondheid) mercredi, 8 novembre 2023 15:14 - FOD Volksgezondheid) RE: HFO 1234ZE supply problems Dear Mr. Thanks for the update. I really appreciate. Concluding, we will have to wait for the final version of the agreed text before being able to act (in case this is required). Regarding the advice about the EU PFAS restriction Proposal that was published in February/March, we have provided our comments on this proposal text in July during the consultation round that ended on the 25th of September. Now it's waiting for the outcome and the advices of the RAC and SEAC. We are also in close contact with Honeywell. Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: A > Verzonden: woensdag 8 november 2023 11:34 Aan: CC: be> Onderwerp: RE: HFO 1234ZE supply problems Dear Mr. Indeed, it gets clearer now. We are still awaiting the end version of the agreed text to have a clearer view on the new measures to come. And you are right that a prohibition will be set in place for technical aerosols as of 2030. Your product falls under that category. Exemptions could be granted if there is a clear demonstration that there is no alternatives to the product and that the lack of it would create a security problem for the EU (or the Member States). The procedure to request such exemption is not yet defined by the Committee but I guess it will not defer much from the one we have now. The Company (or sector) must submit a file that describes the situation, the risk, the lack of alternative and a demonstration that any covered F-gas is the only solution. Updates will also be required after the derogation is granted (if so). It also has to demonstrate that research or development is ongoing to find an alternative. From my experience, the file needs to be strong and well documented. But this is what we do now, and the future may differ. May I also advise you to follow closely the current request by some MS to include PFAS in the scope of the REACH regulation as many F-gasses (including HFO) may fall under those restrictions too. I'm not directly involved in this but this may be of importance for you. 1 So, for the time being, it is maybe better to wait for the publication of the new F-gas regulation. It should occur in the beginning of 2024. I hope this helps. Sincerely Avenue Galile / Galileelaan, 5 box 2 1210 Bruxelles BELGIUM www.health.belgium.be From: Sent: lundi, 6 novembre 2023 17:06 To: Subject: RE: HFO 1234ZE supply problems Dear Mis Any update? Your feedback will be highly appreciated. Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: Verzonden: dinsdag 17 oktober 2023 14:20 Aan: Onderwerp: RE: HFO 1234ZE supply problems Dear Mis Last week I was informed there was an F-Gas announcement (links below) mainly confirming the consumption of hydrofluorocarbons (HFCs) will be completely phased out by 2050. There was also news for aerosols where HFO1243ze will be banned from 2030 in technical aerosol applications (statement below) with possible exemptions to the ban when safety concerns are involved. Fluorinated gases and ozone depleting substances: Council and Parliament reach agreement - Consilium (europa.eu) Deal reached on reducing fluorinated gas emissions in the EU | News | European Parliament (europa.eu) 2 Please find attached also a Honeywell document with a summary of the recent F-Gas Regulations announced last week and the proposed ban of Technical Aerosols in 2030. I would require more details to be given to fully understand, but I guess that our technical aerosolized products `Aircraft Insecticides' would fall under the scope of an exemption on the ban when safety concerns are involved. It's of an utmost importance that aircraft disinsection products, which are also subject of the EU BPR, are nonflammable and fulfil the technical requirements of the space spraying application method. Main question for us at this moment: what will be the pathway to obtain an exemption subject to safety requirements so we can continue to use HFO to manufacture technical aerosols like aircraft insecticides? Any information yet available on this subject? Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: Verzonden: dinsdag 10 oktober 2023 17:30 Aan: Onderwerp: RE: HFO 1234ZE supply problems Dear Mis Any further update yet about the ongoing discussion about the proposition to amend/adapt the EU F-Gases regulation? Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: Verzonden: dinsdag 25 juli 2023 15:48 Aan: CC: Onderwerp: RE: HFO 1234ZE supply problems De The F-Gar New Regulation is still under negotiations. Sincerely yours. Federal Public Service Health, Food Chain Safety and Environment - BELGIUM 3 Galile-07 Avenue Galile, 5/2 ert B-1210 Brussels BELGIUM From: Sent: mercredi, 19 juillet 2023 10:49 To: be> Subject: RE: HFO 1234ZE supply problems Dear Mis Any further update yet about the ongoing discussion about the proposition to amend/adapt the EU F-Gases regulation? Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: > Verzonden: maandag 15 mei 2023 17:03 Aan: Onderwerp: RE: HFO 1234ZE supply problems The one million questions. ;o) Nothing can be said but the intention is that all is finalized in 23 and put into force in January 24 ! From: > Sent: lundi, 15 mai 2023 16:55 To: Subject: RE: HFO 1234ZE supply problems Dear m Thanks for the update. When can we expect an outcome of the ongoing discussions? Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions 4 The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: be> Verzonden: maandag 15 mei 2023 12:02 Aan: CC: Onderwerp: RE: HFO 1234ZE supply problems Dear Mr. , About your first questions, I see in Annex II some HFO (HFC-1234**, 1336 and 1233**) So if you are using them, you may be under the controlled uses. Then the amendment you found are the one proposed by the Parliament for the Trilogue. I know the procedure is a bit complicated but now, the Commission, the Council (through the Presidency) and the Parliament will sit together to discuss a compromise. So until this is over, there is no certaintny of the outcome. I do agree that an exemption may be needed but this would be assessed against the official version when it will be published. No date defined yet, this will depend of the discussions. And please note also that Mr Dehaen has been replaced by Evi Chielens (in CC) for the front office contacts. Sincerely Federal Public Service Health, Food Chain Safety and Environment - BELGIUM From: D Sent: jeudi, 11 mai 2023 17:18 To: be> Subject: RE: HFO 1234ZE supply problems Dear mr Thanks for the feedback. In the meantime, I've performed some extra research and came up with the following information. We are specifically interested into the future of HFO-molecules that are used as a propellant gas for the production of non-flammable technical aerosols. Via the website of the F-Gas Regulation, I came up with the official documents of the Commission proposal on fluorinated greenhouse gases. First of all, Article 2 `Scope' is introduced and clearly states: 5 Looking at the chemicals mentioned in Annex I, II and II (Annexes to the proposal), there seem no HFO-molecules to be included! As a consequence, we can conclude that the HFO-molecules are not in the scope of the Commission proposal on fluorinated greenhouse gases. Can you confirm my conclusion/statement is correct? Secondly, I found the following document: REPORT on the proposal for a regulation of the European Parliament and of the Council on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 | A9-0048/2023 | European Parliament (europa.eu) which includes some extra amendments compared to the Commission proposal on fluorinated greenhouse gases. This Report on the proposal includes some interesting parts for technical aerosols: - Amendment 16: Proposal for a regulation - Recital 13: - Amendment 145: Proposal for a regulation - Annex IV - table: Addition of 20a 6 The Annex IV 20(a) amendment is included into the Report on the proposal, but not in the official documents of the Proposal => very important discrepancy which confuses me. If this amendment (20a) would be installed, it would apply to "fluorinated greenhouse gases" as defined in Article 2(Scope) which I already explained above. Anyway, there are currently no alternatives for HFO 1234ze to manufacture a safe and non-flammable technical aerosol like aircraft disinsection products. Therefore, an exemption will be justified. Thanks for the feedback in advance Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: A Verzonden: maandag 8 mei 2023 14:33 Aan: Onderwerp: RE: HFO 1234ZE supply problems Geachte Heer Ja ik bevestigd dat de HFOs onder de controle van de verordening zullen vallen. Tot nu toe kunnen we niet meer dan de voorstel van de Commissie en de positie van de Raad en het Parlement kennen, maar de einduitkomst kennen we nog niet. Wanneer een eindversie zal beslists worden plannen we (BE) de informatie te verspreiden en verklaren ook de inhoud van de nieuwe teksten. U kan deze voostellen op het Internet vinden. Federal Public Service Health, Food Chain Safety and Environment - BELGIUM From: Sent: vendredi, 28 avril 2023 11:31 To: be> 7 Subject: RE: HFO 1234ZE supply problems Importance: High Geachte H Wij werden vandaag genformeerd dat de HFO-molecules nu ook in de scope van de F-Gases regulation zouden worden opgenomen mbt een ban vanaf 2030. Is deze informatie correct? Is hieromtrent enige informatie beschikbaar? Alvast bedankt voor de feedback. Vriendelijke groeten, Best regards, Cordialement R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: Verzonden: woensdag 29 juni 2022 17:13 Aan: Onderwerp: RE: HFO 1234ZE supply problems Dear Mr. , First of all, please keep in mind this is only a guess, no confirmation. And I will keep you posted of any evolution. My position would be to clearly and firmly oppose such derogation should it be asked. Sincerely. From: Sent: mardi, 28 juin 2022 14:10 To: Subject: RE: HFO 1234ZE supply problems Dear mr Please keep us posted, because if France would grant an exemption or derogation to our competitors, this would have huge consequences. Moreover, I don't quite understand what our competitors would do with an exemption. Their product dossier under the EU Biocidal Products regulation has been adapted and the formulation that was authorised is based on HFO. It's not because they obtain an exemption to re-use HFC 134a, that this would be allowed under the EU BPR. Best regards, R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. 8 Van: be> Verzonden: dinsdag 28 juni 2022 10:19 Aan: Onderwerp: RE: HFO 1234ZE supply problems Yes, af course (and sorry for the delay in replying, I was abroad for a mission). My colleague from France asked me if you are also facing the same problem. And I guess they would ask implicitely if Aero-Sense would submit a request for derogation. But this is a guess only. I've just sent this question to them. Sincerely yours. From: Sent: dimanche, 19 juin 2022 12:58 To: Subject: RE: HFO 1234ZE supply problems Dear Mr. W Honeywell has some issues with deliveries of HFO in Europe. Can I ask for the reason of this question? Best regards, R&D - Quality General Terms and Conditions The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. Van: Verzonden: zaterdag 18 juni 2022 21:06 Aan: Onderwerp: HFO 1234ZE supply problems Hello, I would like to know if you have any problems with the supply of HFO for insecticides at the moment. Thank you in advance. Federal Public Service Health, Food Chain Safety and Environment - BELGIUM 9