Refrigerants, Naturally! urges the European Parliament and the Council to bolster the revised regulation during the trilogue negotiations. We endorse the Parliament's position to completely phase out hydrofluorocarbons (HFCs) well before 2050, aligning with the objective of achieving climate neutrality by 2050. Viable F-Gas-free alternatives to HFCs and hydrofluoroolefins (HFOs) already exist, and continued technological advancements will further enhance these alternatives.
Phasing out F-Gases in Refrigeration Systems
The adoption of natural refrigerants in refrigeration systems will mitigate environmental harm caused by F-gases, including HFCs and HFOs. Numerous manufacturers offer a wide range of commercial refrigeration systems utilizing natural refrigerants such as CO2 and hydrocarbons, demonstrating both their market viability and technical feasibility. By banning F-gases in refrigeration systems, the European market can strengthen its position, particularly benefiting medium-sized European manufacturers, as the global phase-down under the Kigali Agreement gains momentum. Refrigerants, Naturally! supports the Parliament's ambitious proposed bans on stationary refrigeration and urges a swift transition away from F-gases in new mobile systems, including transport refrigeration and mobile air-conditioning.
Removing unnecessary barriers for Natural Refrigerants in Heat Pumps:
Refrigerants, Naturally! proposes a revision in the draft proposal of the Parliament concerning safety standards. The current statement on safety standards presents a vague clause that can be exploited by dominant industry stakeholders to serve their commercial interests, without proper oversight by policymakers. Instead, Refrigerants, Naturally! suggests replacing the reference to safety standards with applicable European directives and regulations, which carry legally binding obligations. Furthermore, we advocate for the banning of F-gases in larger heat pumps, as these systems can operate safely using natural refrigerants with a global warming potential (GWP) below 1. Such a ban would support the leading market position of European manufacturers.
Plug-in and self-contained systems
Plug-in and self-contained systems equipped with natural refrigerants are readily available in the market, offering environmentally friendly cooling solutions for cold storage up to 50 kW. Larger systems can be operated safely in compliance with the requirements outlined in the EN378 standard. Consequently, there is no longer a need to continue using F-gases in these systems.
Single and multi-split systems
Refrigerants, Naturally! requests that new single-split systems containing F-gases with a rated capacity of up to and including 12 kW should not be permitted for placement in the market beyond January 1, 2027. The safe use of natural refrigerants with a GWP below 1, in accordance with the relevant product safety standard (IEC 60335-2-40), is both feasible and commercially viable, with available systems to support this transition. For split systems above 12 kW, the ban should extend to refrigerants with a GWP above 750 from January 2027, followed by a ban on systems using refrigerants with a GWP above 150 from January 2029. From January 2030, all F-gas-containing split systems should be prohibited. Such a ban would encourage the safe use of indirect or hybrid systems employing natural refrigerants and would benefit European industries, particularly small and medium-sized enterprises involved in fan-coil and monobloc design and manufacturing. These market segments are already experiencing high growth rates and attracting investments. Multi-split systems utilizing HFCs, especially those designed with variable refrigerant flow (VRF), are prone to higher leakage rates and should be phased out of the market.
Updated Restrictions on F-Gases
Refrigerants, Naturally! welcomes the Parliaments’ suggested amendment to monitor technological and market developments in the sector and if needed amend the F-Gas regulation to strengthen prohibitions on the placing of products on the market .
Integration of the Green Deal Zero Pollution Target
The European Union, through initiatives such as the Green Deal, has committed to international leadership in achieving climate neutrality and zero pollution. F-gases and their by-products contribute to the increase of per- and polyfluoroalkyl substances (PFAS), including trifluoroacetic acid (TFA), in the environment. PFAS pose long-lasting risks to ecosystems and human health. Refrigerants, Naturally! calls upon the EU Parliament and the Council to ban all fluorinated gases, including HFOs, where alternatives are available. Natural refrigerants provide environmentally friendly alternatives to F-gases. The current proposals, which may lead to increased use of low GWP F-gases, contradict the principles and objectives of the EU's Zero Pollution Action Plan. Delegating control of detrimental environmental effects to the REACH regulation is an ineffective strategy. The restriction of PFAS, including F-gases, would require significant time and may not fully address the issue. The European Parliament's intention to collaborate with the industry to direct investments into alternatives, while well-intended, falls short of achieving the desired outcomes. Cooling and heating technologies already present in the market offer strict GWP limits and discourage the use of F-gases, as natural refrigerants can be safely utilized in nearly all applications.
By addressing these recommendations, the European Union can reinforce its commitment to climate protection, promote sustainable practices, and pave the way for a future driven by natural refrigerants.
Phase out HFCs well before 2050
Prior to 2050
Ban F-gases in refrigeration systems
· Stationary refrigeration: January 2027
· Transport refrigeration (vans, ships): January 2027
· Transport refrigeration (trucks, trailers, reefer containers): January 2029
· Mobile air-conditioning (passenger and cargo ships, buses, trams, trains): January 2029
Ban F-gases in Heat pumps
· After January 2027
Ban F-gases in new single-split systems
· Rated capacity up to and including 12 kW: January 2027
· Rated capacity above 12 kW: January 2027 (GWP above 750) and January 2029 (GWP above 150)
Ban F-gas-containing split systems
Strengthen prohibitions on placing F-gas-containing products on the market
Continuous monitoring and potential amendments to the F-Gas regulation
Ban fluorinated gases that can degrade into PFAS and potent climate-changing by-products
Where alternatives exist, align with the Zero Pollution target of the European Green Deal
 https://www.europarl.europa.eu/RegData/seance_pleniere/textes_adoptes/definitif/2023/03-30/0092/P9_TA(2023)0092_EN.pdf Amendmends 18b) and 18c): “…..except when required to meet safety standards”,