April 1. 2023. 5:03

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What are the immediate trade-offs for Europe in the revision of its F-gases rulebook?

The current EU regulation on F-gases is widely regarded as the gold standard globally, where Europe has led the way on reducing and containing emissions of F-gases. The most important measure in the Regulation is the quota system for hydrofluorocarbons (HFCs), which allows a gradual reduction of the quantity of new hydrofluorocarbons available on the EU market. The cap will achieve a 79% cut in the supply of new HFCs by 2030 compared to 2015.

Lately, Europe’s priorities have shifted; securing energy supplies is as equally important as supporting a balanced approach to decarbonisation and emissions reduction. The F-gas Regulation must be reviewed within the new global context.

The European Commission’s proposal for the revision of the current F-gas Regulation sets a target of reducing the use of fluorinated gases by 98% by 2050, with a target reduction of 76% as early as 2027.

Producers and the entire value chain rely on F-gases for valuable and sometimes critical applications. The new proposal raises questions on how these new ambitious goals could be applied in the real world in terms of technology change.

Where are we now?

The proposal by the Commission is currently under discussion in the European Council and the European Parliament. On 1st March, the European Parliament’s Environment (ENVI) committee voted and adopted a number of radical amendments to the proposal. EFCTC and the other industry associations operating in this sector are very concerned about the environment, social, economic and political impacts.

Impacts on various industry sectors

In particular, amendments to Annex IV now covers all F-gases, including the low GWP F-gases, banning their use in a wide range of applications in the next 3-5 years. There would be consequences for the operation of refrigeration (mobile and stationary), air-conditioning (mobile and stationary), foam, and technical aerosols currently in use across the EU. These products are carefully chosen and valued by users as critical substances to help them transition from higher-GWP HFCs whilst maintaining energy efficiency and safety.

For example, there will be an impact on temperature-controlled transport in the cold chain used to chill fresh produce and food (at 0 to 4°C) and freeze food products (at -18°C). This is vital to food supply and enables the reduction of food waste. Here, F-gases are used as refrigerants in commercial fridges, freezers and refrigerated transportation.

A challenge to heat pump development and deployment – potentially damaging the drive towards decarbonisation

The REPower EU Action plan has targets to roll out 20 million heat pumps by 2026 and nearly 60 million heat pumps by 2030. This demonstrates the high growth necessary in the residential heat pump markets and commercial/industrial applications in almost all sectors where the capture of heat from the air, ground, water or waste sources presents a real opportunity to decarbonise through direct energy savings.

These targets could be jeopardised by the ENVI proposal to the European Parliament plenary.

In addition, lower-GWP HFCs and HFOs are needed to meet these goals because they can be used in all locations such as intensively built areas, while this is not possible for “natural”, but actually industrially manufactured, flammable alternatives. As UBA stated in the report published in August 2022: “The share of the natural refrigerant R290 (propane) is assumed to increase to up to 30 percent in 2030”.

Can the installation, maintenance and servicing sectors cope?

There is also great concern over a possible pan-European skills gap, in particular, the need for training of technicians across Europe required for the rollout of low GWP refrigerants. With new technologies come new needs. Support and time will be needed to upskill contractors and engineers to install non-fluorinated alternatives: “a lack of trained installers and high upfront cost may slow deployment in the EU” was noted in the report on the progress on competitiveness of clean energy technologies published by the Commission in November 2022.

While there are half a million certified technicians across Europe for these applications, a 2021 survey found that under 10% of certified personnel are trained on alternatives, indicating a clear shortage of contractors. Upskilling will be a significant investment, which takes time. This is a critical factor for SMEs, who constitute a large part of service companies. Increased certification standards for technicians are vitally important to safely handle alternatives such as CO2, ammonia or propane, given flammability and the renewal of servicing tools for alternatives needing to be fitted for new requirements.


At the current stage, the European Parliament Environment Committee amendment proposals have gone to extremes by banning many low GWP F-gas alternatives prior to 2030. Such suggestions will not help Europe in moving towards its decarbonisation goal nor help many of the industry sectors in planning their transition towards net-zero by 2050.

The phasedown of F-gases globally has been a powerful driver for the industry to innovate and kick-start the transition to lower GWP solutions. It also took major steps in improving the future enforcement of the Regulation, in particular through use of the Customs Single window as well as through promoting increased inspections of facilities by Member States and data collection, reporting and analysis. The new electronic system allows automatic checks of incoming shipments, the identity and registration status of shipping companies as well as their allocated quota. This will help minimising the import into the EU of illegal possibly unsafe F-gases.

While industry continues to develop, the EU must consider the immediate and direct impact that the proposed revision could have on multiple sectors which currently rely daily on F-gases.

Most recently, we have seen the over-anticipation of the transition to non-fluorinated alternatives where, primarily for safety reasons, non-fluorinated alternatives cannot be used.

A more holistic view of F-gases, including their role in vital applications and in decarbonising Europe through the expansive rollout of heat pumps and insulation of buildings, is needed to ensure a safe and timely transition.

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