Document bypqBO1bRp15Zx5yxLLVvMdN6

From: Sent: To: Cc: Subject: Attachments: Importance: PF Sant Publique - FOD Volksgezondheid) vendredi, 5 mai 2023 15:38 Fluor Gas Federal Belgian Authority (SPF Sant Publique - FOD Volksgezondheid) Publique - FOD Volksgezondheid) The new fgas is a key file for EU independence and the REPowerEU - a message from EEB eeb on fgas revision Belgio.pdf; Fluorspar-IMFORMED-Mineral-Minutev4.pdf; propane availability.png.png High Dear M Please find attached a short letter from EEB expanding two underexplored arguments around the Fgas regulation debate: 1) Fgas production is largely an extra-EU story. The EU largely imports refrigerants whose raw material (Fluorspar) is a critical one, and it is largely in the hands of China (see attachment). We think it is strategic to secure EU's independence in this sector. 2) The existing production capacity of alternative solutions (natural refrigerants) is fit for purpose to cover the whole EU need for refrigerants and foams (see graph) 3) The cost of transition might hit hard on Member States' administrations. The main source of money to cover those costs is the allocation fee, building on the "polluter pays" principle. 4) Contrary to F-gas, Illegal trade of natural refrigerants is unlikely to take place because they are too cheap to risk sanctions. For these reasons, on top of the many, well-known environmental ones, we call on you to support: Higher ambition in the phase down, as the European Parliament did. Early bans of Fgas in all applications where technology is there or will shortly be there. A ban on products that are or might become PFAS. Higher allocation fees. Stronger training provisions with clear KPIs. We would be very happy to have an exchange with you on these points and other around the Fgas regulation debate, at your earliest convenience. All the best Deputy Policy Manager for Climate & Energy European Environmental Bureau Rue des Deux glises 14-16, B-1000 Brussels Te M E www.eeb.org | twitter | facebook | linkedin The European Environmental Bureau (EEB) is Europe's largest network of environmental citizens' organisations, standing for environmental justice, sustainable development and participatory democracy. 1 EC register for interest representatives: Identification number 06798511314-27 International non-profit association - Association internationale sans but lucratif (AISBL) BCE identification number: 0415.814.848 RPM Tribunal de l'entreprise francophone de Bruxelles Our privacy policy can be found on our website 2