EPEE speaks out on HFC bans

EUROPE: Air conditioning and refrigeration industry group EPEE has reiterated its
support for a cap and phase down of HFC refrigerants, while restating its
opposition to product usage bans and a proposal in the F-gas revision to bring
an end to pre-charged equipment.

Speaking at the Chillventa exhibition following the publication of EPEE’s latest
study by SKM Enviros, EPEE secretary Andrea Voight repeated the group’s
support for a phase-down but voiced its opposition to usage bans and an
initiative to end the sale of non-pre-charged equipment. The group reacted after
the contents of a leaked EC F-gas review proposal document were revealed by
ACR News last week.

EPEE argues that HFC bans will force the market to use refrigerants which may
not be the most energy efficient, safe and economic alternative for a given
application. The leaked document had proposed a stepped ban on HFCs with a
GWP of over 2,150 by 2017. Such a ban would affect the vast majority of
supermarket systems currently running on R404A – a refrigerant with a GWP of
3,780. One of the few alternatives would be a move to CO2 but while CO2
systems might be an energy efficient solution in northern European climates, it
is known to struggle in higher ambient conditions.

“CO2 is not the most energy efficient alternative in commercial refrigeration
applications in southern European climate zones,” says EPEE. “Bans could
therefore lead to an increase in total emissions as energy consumption
contributes more than 70% to total emissions.”

EPEE maintains that there is no perfect refrigerant and bans “would be
technology prescriptive and take away the choice,” it argues. It also says that
HFC bans will also hamper innovation in terms of potential future low GWP
blends and refrigerants.

While supporting a phase-down of HFCs, EPEE argues for a less severe phase
down than that suggested in the leaked document.

“We call for a realistic and achievable schedule which for example will allow the
growth of technologies such as heat pumps and still achieves the required
emission reductions,” said Andrea Voight.

Based on findings from SKM Enviros, EPEE supports an HFC consumption
reduction of 30% in 2020 and of 65% in 2030, including a re-assessment in

“The setting of the baseline for a phase-down is of course crucial as well,” says
EPEE. “It should be realistic and take into account the development of the
market over the past couple of years.”

The leaked document proposes a steeper phase down with a 79% reduction by

EPEE says that its proposal will reduce direct emissions from the air conditioning
and refrigeration sector by more than 70 million tons of CO2-equivalent in 2030
- well within EU targets.

The existing F-gas regulation has already started to pay off, it argues, with
expected emission savings of more than 40% in 2030

On pre-charged equipment, EPEE says that in order to make a phase-down work
and achieve the required emission reductions, it is key to take into account precharged

“If this is not ensured, loopholes may be created where manufacturers from
outside the EU could import pre-charged equipment without restriction. The way
forward to avoid such a situation could be a reporting and quota system where
such equipment is included. Banning pre-charging equipment altogether, on the
other hand would be a very risky solution for several reasons.”

EPEE maintains that such a ban is likely to increase emissions “as factory
charging is done in a very controlled environment which cannot be reproduced in
the field”.
It also says that a ban would be detrimental for the export business of EU based
factories versus non EU based manufacturers and it will create unforeseeable
situations where market surveillance is virtually impossible.