Refrigeration and Air Conditioning Refrigeration and Air Conditioning
An official response to the European Commission’s F-Gas review has said that illegal trade will continue to undermine wider success of legislation without more harmonised penalties
Stricter enforcement of EU F-Gas regulations to tackle illegal trade should be prioritised in upcoming reforms of the legislation, according to the European FluoroCarbons Technical Committee (EFCTC).
A stronger, more consistent approach by all member states to tackle black market supply is among several recommendations set out in an official response from the committee to the European Commission’s review into the future of F-Gas.
The industry body said that it continued to support the overall structure and aims of the regulation but would welcome a more consistent approach to cracking down on black-market trade. Since 2015 the F-Gas regulation has been able to drive the European market towards adopting lower GWP products, while ensuring sufficient choice and flexibility in how this is done, the EFCTC claimed.
It added, “Data from the European Environment Agency has demonstrated that F-Gas emissions have been decreasing since 2014 and leading the European Commission to conclude that the F-Gas Regulation’s provisions are effective.”
“However, the impact of illegal trade quantities since 2018 on the magnitude of the emission reductions is uncertain. As the objective of the F-Gas Regulation is to reduce carbon emissions by two-thirds by 2030 - in terms of CO2 equivalent - compared to 2015 levels, improved enforcement at member state level is essential to achieving this objective.”
The EFCTC’s official response to F-Gas review has instead urged authorities to do more to curb the illegal trade of refrigerant alongside the existing commitments to curb greenhouse gas emissions.
It argued that authorities had struggled to handle an increase in illegal imports of HFCs in recent years due to an inconsistent response from EU member states.
This response has served to delay the introduction of more low-GWP solutions on the European market, according to the EFCTC.
The trade body accepted in its response to the review that progress had been made to try and tackle the illegal trade. However, the organisation has called on the European Commission to implement more harmonised and dissuasive penalties across the EU for illegal trade of refrigerant.
Another recommendation of the EFCTC is to try and improve monitoring of the regulation across the continent. This could be managed by requiring individual member states to evaluate logbooks from registered suppliers to get a clearer picture around leakage, recycling, recovery and reclamation rates when handling refrigerant.
In the longer-term, the organisation said that amendments beyond the existing phasedown schedule should be clearly aligned with the Montreal Protocol requirements as a means to ensure the competitiveness of EU-based companies.
The EFCTC stated, “Any new measures proposed during the review must take into account the investments that market operators have already made to meet the requirements under the current F-gas regime, which run until 2030.”
“Alterations to the current regime could potentially be both disruptive and costly, with little actual environmental benefit.”
The F-Gas regulation have failed by creating a quota system (their statement indicates that it was abused!!!) as some manufacturers of equipment and refrigerant have used it to promote flammable refrigerants on the deceptive claim that they are low GWP knowing very well that their proposal will be short lived and can cost lives. They also manipulated the quota by stopping to supply of legitimate equipment 5-6 years (R410A) before the F-Gas reduction in 2025?. This prompted the escalation of prices (from £15/kg to £85/kg) from refrigerant suppliers in Europe and especially in the UK which allowed the illegal import to escalate, as anybody can import (legally) if they have a quota be it less than the 100 ton+ and do horse trading?. The proposed revision is even worse (thank God UK is out) by forcing (proposed) importers from manufacturers who do not have manufacturing facilities in the EU. The best thing if EFCTC would want to protect the market and have fair international share is a) Demand that manufacturers to supply changeless equipment (especially the common, mass produced), this will allow the UK industry supply equipment that is 1st Energy efficient and secondly protect consumers lives and assets, b) EFCTC can help by insuring their members follow one common safe & energy efficient and sustained policy.. We all need to remember that the Grenfell disaster started by the misuse of refrigerants and management ignorance of basic facts like A1 class is non-flammable, A2L class is flammable and A3 class is highly flammable and explosive!. This basic categorisation of safety as set out in ISO817 and ASHRAE 34 is clearly communicated, clearly displaced and honestly (not pretend to be environmentally friendly) marketed. 72 lives and many more around the world is worth much more than corporate greed (Greenwashing) or incompetency that is current. Worth also to remember that F-Gas Certification have nothing to do with political EU F-Gas Regulations.Neil Afram F.Inst.R.