A number of German organisations whose industry is active in the entire cold chain in Germany – BIV, BTGA, Bundesfachschule, FGK, RLT-Herstellerverband, VDKF and ZVKKW – have drafted a joint statement on the planned ban of the group of chemicals known as PFAS under the European REACH regulation. The statement was sent to the political decision-makers of the European institutions, Council, Parliament and Commission, to the Bundestag, to the relevant federal ministries and to the associations of operators affected by the PFAS ban.
The statement points out that the refrigeration, air conditioning and heat pump industry uses PFAS chemicals in many forms and applications, including seals, construction and coating materials, electrical and electronic components, and also as fluorinated refrigerants. However, in many cases, suitable alternatives with the same mandatory material properties of resistance and durability are currently neither available nor can be developed as market-ready products within the timeframe of the ban. The organisations are therefore against a blanket ban on all PFAS chemicals, which is currently under consideration by the European Chemicals Agency (ECHA), and demand that the availability of suitable substitutes also be considered. Otherwise, the safe operation of refrigeration, air conditioning and heat pump systems would be seriously jeopardised.
The main demands in the declaration are:
- Full exemption for fluorinated refrigerants
- Temporary and unlimited exemption for PFAS-containing refrigerants for existing systems.
- Indefinite exemption for PFAS-containing spare parts for existing systems.
In their statement, the organisations also question the legal conformity of the proposed PFAS ban with EU law, which is to be implemented exclusively by the European Commission without the involvement of the EU Parliament and Council. This procedure makes sense for insignificant amendments to an existing regulation, but not for the planned ban of around 10,000 PFAS chemicals.