Document oXJDraEROeLn7w8a2dqenm23

Ref. Ares(2024)3665462 - 22/05/2024 Some believe that all F-gases can simply be replaced with so-called refrigerants. While non-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, meaning they 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 use non-F-gas refrigerants. There is a particular concern in the air conditioner, heat pump, rooftop and chiller markets, where a restriction to only would result in less 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 climate-friendly 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 not restrict 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 further information please do not hesitate to contact me at @epeeglobal.org, Tel: +32 Sincerely, , European Partnership for Energy and the Environment -- Attachments: EPEE member factory map 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.