The IIR has responded to the European Commission consultation “Fluorinated greenhouse gases – review of EU rules (2015-20)” which aims to collect opinions and suggestions about the update of the F-gas Regulation (EU) No 517/2014.
The International Institute of Refrigeration (IIR) has consulted its Science and Technology Council and all its Commission members in the various IIR member countries who are experts in the fields of refrigerants, including their use in all applications: refrigeration and cold chain, air conditioning, heat pumps, cryogenics…
They all consider that the F-gas regulation is a major success and that we must continue to apply the quota reduction program and the refrigerants bans as previously decided, until 2030. This shouldn’t be done any slower, since it seems possible to continue the phase-down of HFCs as scheduled, nor faster since, in addition to illegal trade issues, priority must now be given to the energy efficiency of equipment and whole systems such as buildings or vehicles. Faster phase-down would certainly lead to less energy-efficient solutions. In addition, clear and stable regulations are necessary to give confidence and enable intelligent investment planning. The refrigeration sector accounts for about 20% of global electricity consumption and this share is steadily increasing (see IIR, IEA and UNEP publications). Indirect CO2 emissions due to electricity consumption are twice as high as the direct impact of refrigerants.
However, in any case, it is necessary to decide now on quotas for the period 2030-2036, since the European Union shall respect the Kigali amendment to the Montreal Protocol: the objective is a 85% phase-down on CO2 eq emissions in 2036 and the target for F-gas is only 79% in 2030. Such a reduction would not be a problem but the sooner it is decided, the better.
Some sectors are currently not concerned by the F-gas regulation. The IIR is preparing an Informatory Note on refrigeration below -50°C. It will explain how we could possibly implement a phase-down in these sectors and the IIR will keep the Commission informed.
Actions must be taken at European level on energy consumption, considering the Total Equivalent Warming Impact (TEWI). Coordination with EU actions on energy, such as the Ecodesign directive, is essential. Priority should be given to air conditioning and heat pumps, where the implementation of energy efficiency labelling should be pursued and a ban on inefficient equipment should be planned.
Other actions should be taken during the period 2020-2030. The use of natural refrigerants should be encouraged and facilitated through the harmonisation of national legislations, including safety rules (e.g. ammonia) and through harmonised implementation of the new standards on hydrocarbons and other low-GWP flammable and mildly flammable refrigerants. A review of the current and future regulations and their practical application in all EU member countries regarding flammable and toxic refrigerants should be carried out. A rapid implementation of new standards across Europe would help phasing-down current HFCs.
In addition, training on low-GWP refrigerants should be better promoted or, better still, become mandatory. The IIR has participated in the EU-funded project Real Alternatives for Life: tools for such training exist. Research and development in all refrigeration uses must continue more than ever in order to reduce the TEWI of a growing number of applications. In parallel, control and certification of installations should be reinforced to reduce leakage.
The IIR and its experts are at the disposal of the EU Commission, which is an official observer in our Organisation due to its intergovernmental status, to assist it in conducting the review and to participate in working groups on this issue if any.