Document ymE4NJ2YwOGx929znYqdgL7x3

Feedback on the proposal on the restriction on the manufacture, placing on the market and use of PFAS. The European Caravan Federation (ECF) is the umbrella organisation representing the national organisations of the European Caravanning Industry. Membership of the ECF consists of 16 caravanning federations and numerous national members of the caravanning industry within the EU member states. These members are involved in the production, the sales and the use of motor caravans1 and touring caravans2, hereinafter referred to as special purpose vehicles3 (SPV), and the supply of specialist parts and services to the industry. From ECF's perspective, the proposal on the restriction of PFAS contains some requirements, as well as derogations, that are not described sufficiently to avoid ambiguities. The proposal provides some derogations for cooling and air conditioning of different types of vehicles. It is not made clear whether SPV are also included in these derogations. Although the technology of the devices in detail differs, the use in vehicles creates similar challenges for the manufacturers of the devices for use in SPV. Devices for air conditioning and refrigeration in SPV and for mobile applications should also be considered. We therefore ask for clarification and consideration in the derogations. Request for clarification We have identified the following unclarities: - Transport refrigeration - and specifically if this sub-use would include all type of transports on land, on sea and in air, and if there is any limitation on what type of good is transported and refrigerated. - Mobile Air-conditioning - and specifically if this sub-use is equal to products within the scope of the MAC-Directive or if any other mobile air conditioners would fall under the proposed derogation. - Mobile - and specifically if this would have the same understanding as in the F-gas Regulation: "normally in transit during operation". We would appreciate a clear definition to be included in the legislation and if these definitions were fully aligned with those in other relevant legislation for the products within scope. 1 Regulation (EU) 2018/858 Annex I Part A point 5.1. 2 Regulation (EU) 2018/858 Annex I Part A point 5.6. 3 Regulation (EU) 2018/858 Article 3 clause 31: vehicle of category M, N or O having specific technical features that enable it to perform a function that requires special arrangements or equipment. 1 Request for derogation We don't see that the use of refrigerant for several mobile and portable application of refrigeration and air-conditioning - other than transport refrigeration and passenger car airconditioning - have been assessed in the proposal. With reference to details below, we therefore request to add a new derogation in Table 9. RO2 - Summary table of derogations with the following suggested wording: "Refrigerants for refrigeration and air-conditioning in special purpose vehicles, and passenger cars (with the exemption of those within the scope of Directive 2006/40/EC of the European Parliament and of the Council), and in portable cooling boxes, until 6.5 years after EiF". This sub-use may be sorted in under the use sector "Applications of fluorinated gases". Justification The manufacturers of small hermetically sealed products, which are used in SPV and for mobile use, identified hydrocarbons (R600a and R290a) - classified as A3 refrigerants - as alternatives and potentially CO2 for devices with a higher power consumption. The alternatives present different challenges. For hydrocarbons, these are primarily safety concerns and the need for a thorough safety assessment. This has already been considered in the development of the proposal for other sub-uses. Leaking refrigerants could ignite and create a fire and explosion risk. For CO2 the bottleneck is the availability of components, but also the challenges related to the very high system pressure. A consultation with ECF members has shown that device manufacturers are already investigating the introduction of alternative refrigerants for the products concerned and are developing corresponding solutions. The challenges are the conditions that make devices specifically designed for use and installation in SPV different from stationary devices in the household. For most products, the changeover is still in the planning and testing phase. First and foremost is the safe use of the device. At the current time and state of development, this cannot be guaranteed. The products placed on the EU market are covered by extended producer responsibility according to the WEEE Directive and the ELV Directive. Following these directives, any refrigerants must be reclaimed and treated separately at end-of-life, and consequently the hermetically sealed devices do not produce emissions caused by the refrigerant during the time of use. Future developments and outlook: CO2 and Hydrocarbons The major challenge with CO2 in devices specially designed for SPV is the significantly higher system pressure that both possesses safety risks and risk of lost performance because of the 2 ECF European Caravan Federation high input power needed. The higher system pressure will also increase weight of the components. A lower efficiency and a higher weight will inadvertently increase the energy consumption which is very unattractive from a climate perspective. No compressors for Direct Current (DC), which is used in the electrical system of SPV and mobile Devices, are available today for CO2. For these reasons, CO2 is not considered as an alternative, or only in very few devices designed for SPV. Industry experts estimate the time for the development to be 5-8 years assuming that the component availability continues to progress. The consultation indicated that most hermetically sealed products should be converted to flammable hydrocarbon refrigerants. The technical challenges are fewer and the availability of the components is good. However, the concerns on the safety aspects related to risks of igniting leaked refrigerants. Important considerations here are: 1. The products are often installed in rooms with limited volume, such as SPVs and boats, where even the leakage of a limited amount of refrigerant could pose a significant risk. There are many applications to consider, including misuse. 2. Portable products, like cooling boxes, are stored and used in habitation areas of SPV with very small volume. The free volume in the SPV is often too small to allow dilution of a leaked refrigerant charge, so a spark could ignite the refrigerant with serious consequences. This becomes a problem especially when there are open ignition sources such as the hotplate in the same room, which is typical for SPV. 3. Mobile devices are per definition subject to significantly more vibration than stationary refrigerators, freezers, air conditioners and other appliances due to intended use. Therefore, the risk of leakage is also higher for mobile products. Therefore, it must be excluded that leakages occurs. Time to re-design products and fully implement hydrocarbons vary significantly between product categories. The estimated time for the conversion is 3 to 6 years depending on complexity and the number of models that must be converted. European Caravan Federation Hamburger Allee 14 60486 Frankfurt GERMANY Phone: +49 -- 69 -- 70 40 39 0 E-mail: M@e-c-f.corn 3