EPEE Position Paper to the EU F-gas Regulation Revision Proposal

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On 5 April 2022, the European Commission published its draft proposal for the revision of the EU F-Gas Regulation.

In this framework, EPEE has developed a position paper representing the view and the thoughts of the industry for this proposal. The main positions here under are fully developed in the published position paper.

The F-Gas Regulation revision must strike the balance between reducing F-gas emissions and achieving the EU’s climate and energy goals.

The proposed HFC phase-down is in reality an HFC phase-out by 2027 that would seriously jeopardize an accelerated and comprehensive heat pump roll out in the EU in the coming years.

The European Commission’s model makes a number of untransparent and unrealistic assumptions about the speed of the refrigerant transition.

The scope of the proposed bans would be incoherent with the proposed phase down and create uncertainty as well as enforcement challenges for market authorities. The specific bans pertaining to heat pumps would be detrimental to the REPowerEU objectives and should be removed.

The extension of provisions to effectively prevent emissions and support installers are welcome and should go further.

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