Document mB1GVXwQj8yx6eO59d6kjwGb

RACHP Equipment & PFAS Classified as Business Date OUR PRODUCTS Air-Conditioners Heat Pumps Refrigeration From less than 1 kW up to couple hundred kW With different technologies as "split" types and "self contained" types 2 Classified as Business WHERE OUR PRODUCTS ARE USED Home refrigeration Vaccine storage Transport refrigeration Sports facilities Grocery stores Offices and schools Homes Hospitals 3 Classified as Business OUR MEMBERS EPEE's membership is comprised of 46 member companies and national associations across Europe realising a turnover of over 30 billion Euros and employing more than 200,000 people in Europe. Our member companies manufacture most of their products in the EU. 4 Classified as Business Role of RACHP sector in society Cooling and heating are fundamental needs for society: Refrigeration Reduces food loss and thereby reduces CO2 emissions. Ensures safe and affordable food supplies. Safe transport of vaccines and medicine. Comfort and industrial cooling Necessary for health protection and productivity in homes, hospitals, offices and process industry. Comfort and industrial heating Heat pumps reduce dependency on fossil fuels, but also support DHC networks and recover waste heat. Classified as Business Emissions of the sector: example from the model +5 650 Classified as Business EPEE assumptions: Rapidly growing heat pump stock (REPowerEU) Range of different lowerGWP refrigerants used Since 2012, EPEE has developed a powerful HFC Outlook EU Model tool, in recent years in partnership with UNEP: Assesses the best pathways towards achieving the Kigali Amendment. Gives data on the placing on the market and on the emissions of all types of refrigerants, including CO2 emissions based on system efficiency. 6 Interplay between PFAS and other files Energy Efficiency First Principle: "taking utmost account of cost efficient energy efficiency measures in shaping energy policy and making relevant investment decisions." Socalled "natural refrigerants" cannot always guarantee the same level of: safety energy efficiency affordability Energy efficiency Fgas Regulation Revision UPFAS REACH Restriction Proposal Fgas Regulation: Further pushes the HFC Phase Down and transitions towards HFOs and nonfluorinated alternatives The two first Fgas Regulations are in place since 2006/2014 and are considered to be very successful. Date of implementation: 2024 UPFAS REACH Restriction: Proposal to restrict the use of PFAS including Fgases and equipment using fluoropolymers Classified as Business Date of implementation: 2028 The Fgas Regulation Regulates the use of fluorinated gases, as the transposition of the 1987 Montreal Protocol and the 2016 Kigali Amendment. The first two Regulations already led to significant decrease in emissions. The third one, to be fully adopted in March 2024, will contain: stricter containment measures for HFCs, HFOs and blends full Fgas product bans after 2030 for several product categories with review of their feasibility by 2030. full phase out of virgin HFCs by 2050 with a review clause in 2040 This Regulation has a similar purpose as the PFAS Restriction proposal, as it also reduces environmental release and impact. Classified as Business Emissions of the sector: low leakage rates Emissions and leakage rates vary between products but are generally low. Many small equipment types are factorybuilt sealed systems, with low operational leakage rate - below 1% per year. More graphs and data are available in the full submission of EPEE. 9 Classified as Business Degradation products of Fgases One of the reasons for the inclusion of Fgases is the partial degradation into trifluoroacetic acid (TFA), however many independent experts and scientists consider TFA to be of low concern for human health and the environment: EEAP, 2022: "all PFAS should not be grouped together, persistence alone is not sufficient for grouping PFAS for the purposes of assessing human health risk" "based on projected future use of these precursors of TFA [including HFC/HFO], no harm is anticipated" Classified as Business Emissions from refrigerants defined as PFAS Outcome: The emissions of PFAS refrigerants are decreasing year by year which indicates progress in reducing environmental impact. 2020 2025 2030 2035 R125 10.016 8.503 4.809 2.654 R134a 19.071 16.099 9.703 4.301 HFCs R143a R227ea 3.653 200 2.424 169 187 81 20 R245fa 72 R R1233z 365MFC d(E) 114 1 15 29 43 HFOs R 1234yf R1234z e(E) 1.546 94 3.617 384 6.022 670 8.686 999 R 1336mz z 0 6 12 17 Total [tons] 34.766 31.218 21.512 16.720 From 2020 to 2035, the emissions will decrease by more than two. Classified as Business Granularity of applications The use of Fgases is diversified across RACHP applications, with specific products having specific characteristics that influence the choice of refrigerants. A broad restriction would: Impede the optimal refrigerant choice for new equipment Lead to premature obsolescence Generate unnecessary waste Hamper the recovery and reclamation of refrigerants Classified as Business Use of fluoropolymers Fluoropolymers are essential for the functionality and tightness of RACHP products, with unique characteristics: Sealing to prevent the release of refrigerant into atmosphere Temperature and pressure resistance facing differentials from 50C to 175C and from near vacuum conditions up to 120 bar Persistence and chemical inertness in aggressive environment Unique electrical properties, like the low dielectric constant that does not break down when subjected to important electric fields Low friction that enables components to be more sustainable and require fewer repairs Today there is no viable alternative that can fulfill all the same criteria. Classified as Business Lack of alternatives to fluoropolymers Two possibilities: A return to previously used components, which were replaced for efficiency/safety reasons (e.g. lead) Development and implementation of innovative components. The unlimited derogation included in the Proposal for "national safety standards and building codes" does not cover fluoropolymers, making it counterintuitive as equipment will not properly function without fluoropolymers. Internal estimation of time for developing alternatives to fluoropolymers, based on industry experience. 14 Classified as Business LEaPcEkEoref caoltmermnaetnivdeastitoonfsluoropolymers For Fgases: Full timeunlimited derogation for Fgases used in RACHP applications, with a review clause 10 years after the EIF to assess efficiency/availability of alternatives, but also for: Maintenance and refilling Reclamation and recycling of refrigerants Exports of precharged equipment A reconsideration of the concentration limits as the current value proposed may jeopardize the efforts to recover, reclaim and reuse refrigerants. For fluoropolymers: Full timeunlimited derogation for fluoropolymers used in RACHP applications, with a review clause 10 years after the EIF to assess availability and viability of alternatives, but also for: Spare parts, waste treatment and exports A reconsideration of concentration thresholds to not hamper the circularity of components. 15 Classified as Business Thank you for your attention! Contact: EPEE @epeeglobal.org * 16 EPEE Classified as Business