Document jmzNYY1yEzGD7kmLGDynN8x9O

A possible PFAS REACH Restriction of F-gases 30 Sept 2021 Agenda 1) EPEE Introduction 2) The FGas Regulation Revision 3) The role of FGases to achieve climate neutrality goals 4) A PFAS REACH restriction? 5) EndofLife measures for FGases 6) Q&A session EPEE - the Voice of RACHP in Europe 1. Full Value Chain of Refrigeration, Air Conditioning and Heat Pump Industry 2. Small - medium - large companies 3. National and sectoral associations 4. Over 200,000 direct employees, over 30bn turnover in Europe 5. Main activities: Promote Decarbonisation of Heating & Cooling Ensure responsible management of all types of Refrigerants Advise on Ecodesign and labelling The FGas Regulation Revision Fgases: why they matter and what are about Fgases are essential to daily life: in industrial, commercial and residential refrigeration, airconditioning systems and heat pumps, as well as in hospitals and fire protection, and several other applications. HFCs were developed in the 1990s to replace the ozone depleting substances (CFCs and HCFCs), which were phasedout globally. This process was carried out under the Montreal Protocol and further level of ambition in the phase down of HFCs is established under the Kigali Amendment, at the international level. Today, Fgases are ozonefriendly, very energy efficient and safe for users and the public thanks to their low toxicity level and nonflammability. In addition, HFOs have a very short atmospheric lifetime and ultralow GWP (Global Warming Potential) values, typically below 10 (i.e. significantly reduced compared to conventional (saturated) HFCs The Key principles of the FGas regulation The EU is taking regulatory action to control Fgases, as part of its policy to combat climate change The objective of the FGas Regulation is to reduce emissions of Fgases by addressing: Life cycle assessment: The containment, use, recovery and destruction of Fgases The control of certain uses of the gases The application of `placing on the market' prohibitions on certain products and equipment Identification: The labelling and disposal of products and equipment containing those gases Compliance: The reporting of information on those gases The training and certification of personnel and companies involved in activities covered under this Regulation Data from the European Environmental Agency (EEA) For 2019, the first compliance year of the HFC phase-down under the Montreal Protocol, the HFC consumption of the EU-28 amounts to only 45 % of the permitted amount. 85% Note: there are scope and counting differences between F gas regulation and Montreal Protocol. (do not compare based on the % of the phase down steps) This is explained in detail in table A.4.2 of the EEA report Priorities for the FGas Regulation Revision The HFC phasedown is the strongest and most successful instrument to drive the move towards lower GWP technologies. Safety Energy Efficiency Affordability Leakage control Addresses energy efficiency, safety and emission reduction Can be further improved with electronic logbooks and extended to all types of refrigerants Recovery Recycling Reclaim (RRR) Contributes to emission control throughout the life cycle and can be further improved by extending it to all types of refrigerants Enforcement Needs to be further improved to ensure harmonised implementation across EU, a level playing field for all actors and to prevent illegal trade Enforce ment Leakage control HFC phase down Certifi cation RRR The Role of FGases to achieve climate neutrality goals The FGas Regulation works! Relative reduction in % 2018 vs. 2015 FGases CO2 CH4 N2O 0% 2% 4% 6% 8% FGases CO2 CH4 N2O FGases achieved highest relative emission reductions (in CO2eq) since 2015 Since 2015, FGas emissions have started to fall as a result of the EU`s FGas Regulation + MAC Directive. By 2030, the European Commission expects 65% FGas emission reductions compared to 2014. The FGas Regulation foresees a review process which has started very recently. Major steps include: 1. Evaluation of the effectiveness of the Regulation 2. Elaboration of a draft proposal by the European Commission 3. The European Parliament, the European Council and the European Commission need to agree on a final revised version. First round of stakehodler feedback: >20 Industry associations agree that the focus needs to be on better enforcement and implementation, illegal trade, alignment with Kigali, training and certification for nonfluorinated refrigerants, safety and energy efficiency. https://www.eea.europa.eu/themes/climate/eugreenhousegasinventory A PFAS REACH Restriction? What do we know today A European broad definition of PFAS has now been released, that should apply to all sectors including Fgases. Competent Authorities should take into account the existing risk management measures in place and the fact that the ongoing revision of the FGas Regulation offers an opportunity for strenghtening its successful measures (with a particular focus on `End of Life' measures and the prevention of emissions) Several existing regulatory measures are already addressing Fgases, in addition to the F Gas Regulation, in relation to the protection of health and the environment: Other measures are established in the Ecodesign + General Product Safety Directive, Low Voltage Directive, ATEX Workplace Directive and the Industrial Emissions Directive, as well as the Pressure Equipment Directive, Machinery Directive, Seveso III Directive, national building codes, and EN378, EN60335240, EN60335289. EN 13313/pr, EN ISO 22712 Standard on competence of personnel. What do we know today Fgases are still essential for the functionality of society and alternatives cannot offer the same level of safety, costeffieciency and affordability of use. Refrigerant's choice depends on many different factors and still mainly depends on technology and application, as well as location, site conditions, including climate conditions. In the complex RACHP sector, what is applicable for one segment cannot be considered by default applicable for another. An example is for the low temperature applications (below 50C), which are required to store material for medical or biochemical use. For such applications, for example, there is still no viable alternative to replace FGases and the consequences would be dramatic. The market moves towards alternatives whenever this is possible from a safety, energy efficiency and affordability perspective. A REACH restriction on PFASs would immediately heavily impact on this choice and on the functioning of society. PFAS Fgases covered under REACH would disregard the existing measures of the FGas regulation to prevent emissions and risk to be disproportionate and raise double regulations concerns. Low GWP HFCs and HFOs refrigerants are essential to achieve the EU climate neutrality goal and tackle the needs of society in relation to the Heating and Cooling sector! Modelling to get the priorities right Indicative graph for Europe, not finalised yet EPEE modelling, in cooperation with UNEP and Gluckman Consulting, shows the relative importance of energy related emissions versus refrigerant related emissions and the huge abatement potential of heat pumps (mitigating emissions related to fossil fuel technologies in heating) 15 EndofLife (`EoL') measures for Fgases A simplified overview of the waste stream The FGas Regulation prohibits the intentional release of FGases and stipulates mandatory recovery at EoL and when RACHP equipment is serviced or converted to another refrigerant (retrofit). Adequate waste management is therefore an important and wellestablished element of the RACHP sector. Prevention of emissions of Fgases Fgases are used in closed systems and recovered at the endoflife (EoL). The Fgas Regulation specifies a robust recovery mechanism for all substances within scope, including the prevention of emissions, the precautions to limit emissions to the greatest extent possible during production, transport, and storage, as well as at the recovery, recycling, reclaim (RRR), destruction and disposal phase. Leakage control is of key importance for reducing emissions, ensuring safety, and maintaining energy efficiency. For the EoL of equipment containing refrigerants (e.g. domestic refrigerators, air conditioning systems in cars etc.) a dedicated waste stream management is also required under the WEEE Directive and the ELV Directive. EPEE supports additional measures to be strengthened in order to address environmental concerns in the FGas Regulation, also through the training and certification requirements, leakage control and prevention of emissions. If Fgases are contained, they cannot impact the environment. 5 Key takeaways HFCs are under control due to the phase down established in the Fgas Regulation The low GWP substitutes are in the focus of REACH Alternatives can be used in some cases, but NOT in all applications. Considering the numerous challenges to address climate change mitigations: heat pumps are pivotal. The main new heat pump platforms are using low GWP Fgases. THEREFORE, It is impossible to comply to climate targets unless low GWP Fgases are considered. Q&A session Contact details Policy Director 46 Avenue des Arts 1000 Brussels, Belgium email: @epeeglobal.org Web: www.epeeglobal.org Twitter: @EPEESecretariat