IIR (International Refrigeration Institute) responded to the consultation of the European Commission "Fluorinated greenhouse gases - Revision of EU standards (2015-20)" which aims to collect opinions and suggestions on the updating of the Regulation on fluorinated gases (EU) n. 517/2014.

The IIR believes that the F-Gas Regulation is a great success and that the quota reduction program and refrigerant bans as previously agreed should continue to apply until 2030. According to IIR, the proposed elimination and reduction pace is adequate and it shouldn't be speeded up or slowed down.

Energy efficiency of equipment and systems such as buildings or vehicles must also be given priority. According to IIR, a faster gradual reduction would certainly lead to less energy efficient solutions. In addition, clear and stable regulations are needed to build trust and enable smart investment planning. The refrigeration sector accounts for around 20% of global electricity consumption and this share is constantly increasing. Indirect CO2 emissions from electricity consumption are double the direct impact of refrigerants.

However, in any case, it is now necessary to decide on quotas for the period 2030-2036, as the European Union will have to comply with the Kigali amendment to the Montreal Protocol, whose goal is a gradual reduction of 85% of carbon emissions. CO2 eq in 2036 while the target for F-gases 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 affected by the F-Gas Regulation. The IIR is preparing an information note on refrigeration below -50 °C. It will explain how a gradual reduction in these sectors could possibly be implemented 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 energy actions, such as the Ecodesign Directive, is essential. Priority should be given to air conditioning and heat pumps, where the implementation of energy efficiency labeling should be pursued and the ban on inefficient equipment should be planned.

Other actions should be taken during the 2020-2030 period. The use of natural refrigerants should be encouraged and facilitated through the harmonization of national laws, including safety standards (e.g. ammonia) and through the harmonized implementation of new standards on hydrocarbons and other flammable low-GWP refrigerants and slightly flammable. A review of current and future regulations and their practical application in all EU member countries regarding flammable and toxic refrigerants must be carried out. Rapid implementation of new standards across Europe would help to gradually reduce existing HFCs.

Furthermore, training on low-GWP refrigerants should be better promoted or, better yet, become mandatory. The IIR participated in the EU-funded Real Alternatives for Life project: there are tools for such training. Research and development in all uses of refrigeration must continue more than ever to reduce the TEWI of an increasing number of applications. In parallel, the control and certification of plants should be strengthened to reduce losses.

More information here