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Review of EU rules on fluorinated greenhouse gases

Climate action

Fluorinated greenhouse gases are being used in particular in refrigeration and air-conditioning. Emissions from such gases are resulting in climate change. In 2014 the EU made new strict rules that will reduce EU emissions significantly. However, in the light of the European Green Deal and Climate Law; recent international obligations under the Montreal Protocol; technical progress and lessons learned during the implementation, it is time to update the rules.

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Public consultation

ID: 12479

Lobbying Activity

100 responses

Consultation response

Climate Action Network Europe, 7 Sept 2020

With the EU climate neutrality target, the F-Gas Regulation requires revision to strengthen its contribution to the target and to improve the Regulation’s implementation. The Regulation is a landmark piece of EU climate legislation for transitioning away from fluorinated gases such as…

Consultation response

European Chemical Industry Council, 28 Jun 2022

EFCTC representing fluorocarbons manufacturers fully supports the objectives of the F-gas Regulation to encourage transition to lower GWP refrigerants. Our industry remains committed to do its part to comply with the already ambitious phasedown schedule for HFCs. This revision, in particular, the…

Chemical Industry Urges Maintaining Current F-Gas Phase-Down Schedule

European Chemical Industry Council, 7 Sept 2020

The industry requests maintaining the current market-based phase-down system while aligning only with the 2036 Montreal Protocol target. They want improved enforcement against illegal imports and removal of certain exemptions, but oppose accelerating the existing reduction schedule beyond what's already planned.
This would allow continued EU production and market access for their lower-GWP fluorinated products.
Climate goals lose faster greenhouse gas reductions achievable with more ambitious phase-down targets.

Consultation response

SMEunited aisbl, 4 Sept 2020

Already in 2017 it was obvious that the availability of crucial f-gases in the internal market would become limited. Prices were exploding, supply could not be guaranteed for many applications. Only between March and October 2017 prices in central Europe increased to ~750% for common cooling…

Consultation response

Eurelectric aisbl, 7 Sept 2020

Eurelectric welcomes the publication of the combined Evaluation Roadmap and Inception Impact Assessment on Fluorinated gases (F-gases). The European power sector supports the EU commitment to reduce the global greenhouse gas emissions towards the achievement of climate neutrality by 2050, as part…

Enel Group urges flexible F-gas rules for energy transition

ENEL SpA, 28 Jun 2022

Enel requests raising climate-impact limits for electrical equipment and guaranteeing spare parts for existing machinery. They also suggest slowing gas phase-outs to support the massive deployment of heat pumps.
Enel would lower compliance costs and avoid relying on a limited number of technology suppliers.
Environmental groups lose because the proposal allows gases with higher global warming potential.

EDF urges realistic F-gas timelines to ensure grid stability

ELECTRICITE DE FRANCE, 27 Jun 2022

EDF seeks to condition SF6 bans on the availability of multiple suppliers and equipment providers. They request exemptions for spare parts and non-standard applications to protect existing nuclear infrastructure. Finally, they warn against aggressive HFC phase-downs that could disrupt the heat pump market.
This would lower compliance costs and ensure the reliability of their long-term infrastructure.
Consumers and the building sector may suffer from heat pump shortages and higher costs.

Consultation response

ENEL SpA, 7 Sept 2020

Enel Group welcomes European Commission initiative for the review of Fluorinated Greenhouse Gases rules. Enel is strongly committed to the objectives of the Paris Agreement and the achievement of a 2050 zero-emission goal, alongside an ambitious science based certified reduction target by 2030.…

Siemens urges switch to F-gas-free solutions for power grids

Siemens AG, 29 Jun 2022

Siemens recommends a direct move to F-gas-free switchgear to ensure long-term regulatory compliance. They caution against replacing SF6 with hazardous chemicals like PFAS that could harm health. Any new alternatives should follow the same strict safety and reporting rules as current gases.
Stricter rules would boost Siemens' market share for their existing fluorinate-free product portfolio.
Manufacturers using PFAS-based alternatives could see their products restricted or subject to heavy oversight.

Consultation response

Siemens AG, 4 Sept 2020

Siemens AG likes to address 3 topics regarding aspects of SF6 management in its feedback to (EU) No 517/2014. For further details and annotations please refer to the attachment. A. Countries that adopted a self-commitment on SF6 emissions reduction, show significantly higher reductions from 2.G.1…

Consultation response

Wirtschaftskammer Österreich, 3 Sept 2020

Bereits 2017 wurde deutlich, dass die Verfügbarkeit der wichtigsten F-Gase auf dem Binnenmarkt begrenzt sein wird. Die Preise explodierten, die Versorgung konnte für viele Anwendungen nicht mehr gewährleistet werden. Nur zwischen März und Oktober 2017 stiegen die Preise für gängige Kältemittel in…

Schneider Electric urges stricter limits on potent greenhouse gases

Schneider Electric, 29 Jun 2022

Schneider Electric supports phasing out harmful gases in electrical equipment and lowering global warming limits for new gear. They also request stricter monitoring of alternative substances to prevent environmental damage.
The company's air-based products would gain a market advantage over competitors' fluorinated alternatives.
Competitors manufacturing fluorinated alternatives would face higher compliance costs and stricter market prohibitions.

Consultation response

Schneider Electric, 7 Sept 2020

See attached file.

MedTech Europe urges F-gas exemptions to protect patient care

MedTech Europe, 29 Jun 2022

Exempt medical devices and laboratory equipment from the new fluorinated gas regulations. The industry needs longer transition periods to redesign products safely.
This prevents costly product redesigns and protects the industry's global market share.
Patients and hospitals face potential treatment shortages and reduced diagnostic accuracy.

Bosch: Strict gas rules could stall heat pump rollout

Robert Bosch GmbH, 28 Jun 2022

Bosch requests targeted exemptions for larger units and a slower transition to natural refrigerants. They advocate maintaining current phase-down timelines to reflect market realities.
This avoids costly system redesigns and protects existing investments in current heat pump technologies.
Environmental groups lose because high-warming greenhouse gases would remain in circulation for longer.

GE warns low gas limits threaten green grid rollout

General Electric Company, 29 Jun 2022

GE requests raising the gas warming limit from 10 to 2000. They argue current proposals would ban their alternative and delay grid updates.
This change would prevent the disappearance of GE's market-ready green technology.
Grid operators face supply bottlenecks and higher prices for compliant electrical equipment.

German energy industry urges realistic deadlines for F-gas phase-out

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 28 Jun 2022

The association requests extending deadlines for banning climate-harming gases in electrical switchgear. They emphasize that repair, maintenance, and expansion of existing plants must remain permitted throughout their service life. Additionally, delivery bottlenecks and limited space for new equipment should justify continued use of traditional gases.
This would avoid the economic disadvantage of replacing entire switchgear units due to minor component failures.
Environmental objectives suffer as the postponement delays the intended reduction of potent greenhouse gas emissions.

VDMA Demands Precise Definitions for Industrial Refrigeration Equipment

Verband Deutscher Maschinen- und Anlagenbau e.V., 22 Jun 2022

VDMA requests a clear definition of self-contained equipment to ensure correct product categorization. They also seek guidance on leak check requirements for complex refrigerant blends.
Clearer definitions would prevent immediate regulatory shifts and provide legal certainty for manufacturers.

Deutsche Umwelthilfe urges complete phase-out of fluorinated greenhouse gases

Deutsche Umwelthilfe e.V., 29 Jun 2022

The organization calls for a complete phase-out of all fluorinated gases to prevent the accumulation of persistent degradation products in ecosystems. They advocate for an accelerated phase-down based on maximum technical feasibility rather than proportionate costs. Additionally, they request bans on fluorinated gases in new equipment to promote sustainable, F-gas free alternatives.
They achieve their environmental goals by preventing long-term chemical contamination of soil and water.
Chemical manufacturers face strict bans on their next-generation substitutes and associated revenue losses.

E.ON Urges Delay to EU Greenhouse Gas Equipment Ban

E.ON SE, 29 Jun 2022

E.ON recommends extending all deadlines for bans and ensuring at least two manufacturers provide proven alternative solutions. They request exemptions for spare parts to avoid replacing entire substations instead of single components. Additionally, they suggest a higher global warming potential threshold to include promising alternative technologies.
This would reduce compliance costs and prevent the premature disposal of expensive power grid equipment.
Environmental groups lose as high-emission gases remain in the power grid for several additional years.

Siemens Energy backs EU phase-out of fluorinated greenhouse gases

Siemens Energy AG, 29 Jun 2022

The company supports a global warming potential limit below 10 for grid technology to foster innovation. They also propose extending strict containment measures to all fluorinated gases used in switchgear.
This regulation would convert their previous research investments into industrial growth and market leadership.
Non-European manufacturers holding exclusive patents for harmful gases would lose their strategic market control.

Consultation response

Siemens Energy AG, 7 Sept 2020

Siemens Energy welcomes the opportunity to give feedback on the review of the Fluorinated Greenhouse Gas Regulation (F-Gas Regulation, 517/2014) regarding the phase out of SF6 in high-voltage (HV) applications. Siemens Energy fully supports the European Union’s ambition to become the world’s first…

Consultation response

APPLiA (Home Appliance Europe), 28 Jun 2022

APPLiA, the EU trade Association representing manufacturers of home appliances, including, ventilating and air conditioning and heat pump equipment, would like to share with the European policy-makers its stance and views on the new proposal for a Regulation on F-Gases revising (EU) No 517/2014…

Consultation response

APPLiA (Home Appliance Europe), 7 Sept 2020

Please consider the attachment for APPLiA's feedback on the Inception Impact Assessment on F-Gases.

German grid operator EnBW urges delay in gas equipment phase-out

EnBW Energie Baden-Württemberg AG, 28 Jun 2022

EnBW requests a two-year extension for medium-voltage equipment transition periods. They propose that supply bottlenecks and delivery times serve as valid exceptions. They also demand continued access to spare parts for existing infrastructure maintenance.
This prevents expensive project delays caused by equipment shortages or technical redesigns.
Climate advocates lose as delayed phase-outs permit the continued use of warming gases.

AstraZeneca warns against rapid F-gas cuts for medical inhalers

AstraZeneca PLC, 29 Jun 2022

AstraZeneca requests maintaining current medical gas quotas until 2030 to protect patient safety. They also seek efficient regulatory pathways for approving new climate-friendly inhaler propellants.
A delayed phase-down prevents supply disruptions and provides time for necessary clinical trials.
Respiratory patients risk losing access to effective treatments, potentially leading to poor health.

AstraZeneca urges maintaining medical exemption for F-gas regulation

AstraZeneca PLC, 7 Sept 2020

AstraZeneca requests maintaining the medical exemption until at least 2030 for product development. They want doctors to retain freedom to choose the best devices for patient needs. Strict safety requirements prevent the company from meeting a more ambitious development timeline.
This would provide the company time to complete regulatory approval for new inhaler devices.

ENTSO-E urges flexible gas limits for electricity grids

European Network of Transmission System Operators for Electricity, 29 Jun 2022

ENTSO-E requests maintaining higher warming potential limits for alternative gases to ensure technology availability. They also advocate for exemptions to allow repairs and expansions of existing equipment using older gases.
This would prevent infrastructure project delays and avoid costs from prematurely replacing power grid assets.
Climate goals may be undermined by permitting gases with higher atmospheric warming potential.

Consultation response

European Network of Transmission System Operators for Electricity, 7 Sept 2020

ENTSO-E supports the EU to reduce the global greenhouse gas emissions towards climate neutrality in 2050 and is willing to commit further efforts to reduce SF6 emissions. SF6 is currently widely used in TSO high voltage (HV) applications such as gas-insulated lines and substations. TSOs, together…

ECOS urges EU to accelerate phase-out of climate-damaging F-gases

Environmental Coalition on Standards, 27 Jun 2022

The organization urges accelerating the HFC phase-down according to the maximum technical feasibility. They suggest a blanket ban on all new HFC-based equipment by 2030.
Mandating natural refrigerants would help the organization fulfill its mission of establishing robust environmental standards.
Incumbent chemical companies would lose significant windfall profits from the current HFC quota system.

Consultation response

Environmental Coalition on Standards, 7 Sept 2020

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation for transitioning away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). As an environmental civil society organisation, ECOS strongly welcomes the initiative of the European…

GSK urges F-gas phase-down safeguards to protect medicine supply

GSK, 29 Jun 2022

GSK requests that the EU ringfence F-gas quotas for medical use and monitor transition progress to ensure patient access. They also advocate for accelerated regulatory pathways for new, lower-emission inhaler propellants.
This would protect GSK's competitive edge as a major European inhaler manufacturer.
Patients with respiratory conditions could lose access to life-saving rescue inhalers.

Naturgy urges delay for SF6 equipment phase-out until 2030

NATURGY ENERGY GROUP, 21 Jun 2022

Naturgy proposes postponing mandatory replacement of existing facilities until 2030. They argue that current green alternatives lack the standardization needed for reliable grid operation.
This delay would help the company avoid equipment costs currently triple the conventional price.
Environmental interests lose as potent greenhouse gas emissions continue for another decade.

Honeywell urges technological neutrality in revised EU F-gas rules

Honeywell Europe NV, 29 Jun 2022

Honeywell requests more flexibility in the phase-down timeline and a wider choice of refrigerants. They argue for protecting existing installations from being prematurely taken out of service.
This approach protects Honeywell’s investments in diverse low-global warming potential technologies.
Consumers and businesses risk high costs from replacing functioning heating and cooling systems.

European heat pump industry warns F-gas rules threaten climate targets

European Heat Pump Association, 29 Jun 2022

The organization requests maintaining the current phase-down schedule until 2034 and removing new product bans. They argue that switching entirely to natural refrigerants within five years is technically unrealistic for the industry.
The association would avoid high immediate costs and maintain their current refrigerant supply chains.
Environmental groups lose out as potent greenhouse gases stay in the market much longer.

Consultation response

European Heat Pump Association, 7 Sept 2020

FULL CONTRIBUTION IN DOCUMENT ATTACHED 1) The multiple benefits of heat pumps are based on the refrigerant cycle which needs refrigerants to function. Key component of heat pump technology, refrigerants are required to fully exploit the heat pumps’ potential in decarbonising heating and cooling –…

Wiener Stadtwerke warns against rapid SF6 switchgear phase-out

WIENER STADTWERKE GmbH, 29 Jun 2022

The group requests a two-year extension for banning SF6 switchgear to ensure grid stability. They also advocate for continued spare part availability and higher warming potential limits.
This would protect the utility from high replacement costs and potential service interruptions.
Environmental goals are undermined by allowing the continued use of high-emission gases.

WACKER CHEMIE supports F-gas rules with technical exemptions

WACKER CHEMIE AG, 19 Apr 2022

WACKER supports the proposal's balance between higher ambition and justified exemptions. They want to maintain exemptions for refrigeration systems where no alternatives exist.
This allows WACKER to avoid extreme costs for converting their specialized refrigeration systems.
Other sectors may face stricter quotas to compensate for these specific industrial exemptions.

Consultation response

WACKER CHEMIE AG, 31 Jul 2020

WACKER is the world market leader and the only European manufacturer of high-purity polysilicon – the basic material for photovoltaic cells and semiconductor chips – and thereby holds a strategic position in the industrial value chains for enabling the green energy and digital transition in Europe.…

Boehringer Ingelheim urges F-gas phase-down delay for medicines

Boehringer Ingelheim, 29 Jun 2022

BI calls to maintain the reference value for medical F-gases and postpone the phase-down until 2030. They warn that current timelines are unrealistic for the necessary clinical testing of alternatives.
This delay would protect its domestic manufacturing operations and ensure continued global market supply.
Environmental groups and climate targets lose as high-GWP gases persist in the atmosphere.

ZVEI urges clear transition rules for phasing out SF6 switchgear

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 28 Jun 2022

The association calls for clear transition periods and a standardized lifecycle carbon footprint assessment. They request defining 'placing on the market' by contract delivery date to avoid project delays. The industry also seeks to continue exporting systems with SF6 components to non-EU markets.
These changes would provide manufacturers with investment security and protect their international competitiveness.
European system integrators would suffer if prohibited from exporting equipment to global markets.

Environmental Investigation Agency Urges Rapid EU Phase-Out of F-Gases

Environmental Investigation Agency, 27 Jun 2022

The EU should adjust the phase-down according to the maximum technical feasibility. They recommend a blanket ban on all new HFC-based equipment by 2030. They also suggest strengthening measures to prevent illegal trade and removing licensing requirement exemptions.
Phasing out these gases eliminates toxic chemical substitutes that threaten human health and nature.
Stricter enforcement would strip illegal HFC traders of their economic benefits and market access.

Consultation response

Environmental Investigation Agency, 7 Sept 2020

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation aimed at reducing fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). In the years since its adoption, however, it has become clear that it requires significant improvements to…

Chemours urges slower F-gas phase-down to protect heat pump goals

The Chemours Company, 29 Jun 2022

Chemours requests a slower HFC phase-down to protect the deployment of energy-efficient heat pumps. They also advocate for delaying quota fees and raising leak check thresholds for low-impact gases.
This would preserve market demand for Chemours' specialized low-impact chemical refrigerants and reduce costs.
Small businesses risk being excluded from the market by high investment costs for alternatives.

ABB backs SF6 phase-out but seeks clearer market rules

ABB Ltd, 29 Jun 2022

ABB supports phasing out SF6 gas but seeks better definitions for contract delivery dates. They also request specific warming thresholds for high-voltage switchgear to ensure product variety.
This would protect existing contracts and boost demand for ABB's green switchgear technology.
Competitors lacking low-warming gas alternatives could face significant market exclusion risks.

Consultation response

ABB Ltd, 7 Sept 2020

ABB feedback on the review of EU rules on the F-Gas regulation EU 517/2014 addressing SF6 in gas-insulated switchgear – ABB welcomes the opportunity to provide its input to the update of the F-Gas regulation EU 517/2014 regarding SF6 in gas-insulated switchgear. – We look back on intensive…

Confartigianato Imprese Urges Mandatory Tracking for Pre-filled Gas Equipment

Confartigianato Imprese, 7 Sept 2020

The organization recommends excluding combustible gases for safety and mandating traceability for pre-filled equipment. They want manufacturers and importers to be responsible for entering data into electronic registers.
Mandatory tracking by producers would lower costs and administrative workloads for small installation companies.
Equipment manufacturers and importers would face new requirements to track units and enter data.

3M warns F-gas limits could delay climate-friendly switchgear

3M, 28 Jun 2022

3M wants the emission limit for high-voltage equipment adjusted to include its gas-based alternatives. It also suggests using standard industrial names and clarifying regulatory definitions.
This would enable 3M to market its low-emission gas mixtures without facing restrictive barriers.
The single supplier of vacuum-based systems would lose its exclusive position in the market.

3M urges EU to phase out potent SF6 greenhouse gas

3M, 7 Sept 2020

The company requests a legislative phase-out of SF6 in electrical equipment when viable alternatives are available. They also propose a controlled phase-out for HFCs in existing fire suppression systems to prevent atmospheric venting.
Mandatory phase-outs would increase demand for 3M’s proprietary and sustainable alternative technologies.
Owners of legacy fire systems would incur new costs for controlled disposal.

French electricity industry urges flexibility in F-gas phase-out

UNION FRANCAISE DE L'ELECTRICITE - UFE, 29 Jun 2022

UFE requests extending the transition period to 2028 for certain voltage levels. Bans should only apply to new installations to ensure existing equipment can be repaired. They suggest conditioning bans on the existence of multiple equipment manufacturers.
This approach would protect energy infrastructure safety and avoid supplier monopolies.
Domestic consumers may face higher heating bills due to increased equipment costs.

Hitachi Energy urges higher GWP threshold for high-voltage switchgear

Hitachi Energy, 24 Jun 2022

Hitachi requests replacing the proposed GWP thresholds with a single limit of 1000. This would ensure grid reliability and support a faster phase-out of harmful SF6 gases.
Hitachi would continue selling its existing scalable and practical SF6 replacement solutions.
Consumers face higher energy bills and the climate suffers from delayed SF6 phase-outs.

Solvay urges focus on recycling over SF6 bans and quotas

Solvay SA, 29 Jun 2022

Solvay recommends focusing on gas containment and mandatory recycling instead of reducing production quotas. They also request a longer transition period for phase-outs, as alternative technologies are not yet industrially available.
This allows Solvay to maintain its manufacturing operations and avoid disadvantages against non-EU importers.
Environmental groups lose as potent greenhouse gases remain in industrial use for longer periods.

Agoria warns EU fluorinated gas rules will stall heat pumps

AGORIA, 29 Jun 2022

Agoria requests keeping the current 2030 timeline for phasing out gases. They also propose removing product bans for heat pumps.
This would allow their members to avoid the high costs of rapid product redesigns.
Environmental targets suffer if equipment bans limit options for homeowners to switch to heat pumps.

Consultation response

AGORIA, 7 Sept 2020

Agoria, the Belgian federation for the technology industry, supports the objectives of the European Green Deal in which technological innovations will have an important role to play to make the EU the world's first climate neutral continent by 2050. We are grateful to assist the Commission during…

Consultation response

Association of the European Heating Industry, 2 Sept 2020

Please find our comments attached. About the European Heating Industry The European heating industry brings together companies that are leaders in the production of efficient heating systems. Our members produce advanced technologies for heating in buildings, including: heating systems, boilers,…

Japanese business council warns F-gas phase-down threatens heat pumps

Japan Business Council in Europe, 29 Jun 2022

JBCE proposes maintaining the current phase-down until 2030 to protect the heating transition. They suggest avoiding new bans on equipment to allow manufacturers flexibility in adopting safer alternatives.
Delaying the phase-down prevents expensive, rapid equipment redesigns and mandatory retesting requirements.
Consumers in older buildings lose because safety standards restrict installing flammable alternative heat pumps.

Austrian power sector urges delays in SF6 gas phase-out

Österreichs E-Wirtschaft, 27 Jun 2022

The industry requests permission to maintain existing SF6 equipment until its end of life. They propose delaying phase-out deadlines for switchgear to ensure grid stability and competition.
This delay protects long-term supply contracts and reduces grid operational risks.
Environmental interests suffer as powerful greenhouse gases remain in use for longer.

Consultation response

Eaton Corporation, 21 Jun 2022

Kindly see the attached file.

CEDEC Demands Longer Transition for High-Voltage Switchgear Ban

European Federation of Local and Regional Energy Companies, 29 Jun 2022

The federation requests a two-year extension for phasing out SF6 gas in electrical equipment. They also demand exemptions for maintenance parts and clearer definitions for climate impact limits.
Longer deadlines prevent market disruption and ensure local energy companies maintain supply.
Pioneering manufacturers lose their potential monopoly status if multiple technical solutions are required.

Consultation response

European Federation of Local and Regional Energy Companies, 7 Sept 2020

CEDEC, the European Federation of Local Energy Companies, represents the interests of more than 1500 local and regional energy companies, active in every part of the electricity and gas value chain. CEDEC fully supports the Green Deal objectives the European Commission intends to achieve.…

Consultation response

Chiesi Farmaceutici SpA, 29 Jun 2022

Please find attached Chiesi's comments.

EPEE warns F-gas rules may jeopardize European heat pump rollout

European Partnership for Energy and the Environment, 22 Jun 2022

EPEE calls for maintaining current phase-down levels until 2030 to ensure enough refrigerants for heat pumps. They request removing specific bans on heat pump technology to avoid jeopardizing EU energy goals. Additionally, training requirements should cover all refrigerants to improve safety.
A slower phase-down protects manufacturers from unachievable redesign timelines and potential product shortages.
Consumers face higher costs and safety risks from a rushed transition to flammable refrigerants.

Consultation response

European Partnership for Energy and the Environment, 4 Sept 2020

Executive Summary As a supporter of the F-Gas Regulation and the European Green Deal, EPEE, representing the refrigeration, air-conditioning and heat pump industry, emphasizes that the heating and cooling sector can make an important contribution to achieving climate neutrality in Europe by 2050.…

Czech Chamber warns F-gas rules threaten heat pump rollout

Hospodářská komora České republiky, 29 Jun 2022

The organization calls for higher quotas for heat pump manufacturers and a delay in equipment bans. They suggest raising warming potential limits from 150 to 750 and postponing prohibitions by five years.
This prevents immediate redesign costs and allows time for technical development and training.
The EU's climate goals suffer as heat pump rollouts stall, prolonging fossil fuel dependency.

Consultation response

Amprion GmbH, 29 Jun 2022

The aim of limiting the global temperature rise is at the heart of climate change mitigation and can only be achieved by reducing greenhouse gas emissions and ultimately becoming carbon neutral. This requires a fundamental transformation of our energy system. The key to a reliable, affordable and…

T&D Europe seeks flexible F-gas rules for electrical switchgear

European Association of the Electricity Transmission and Distribution Equipment and Services Industry, 29 Jun 2022

T&D Europe calls for excluding spare parts and defective equipment from prohibitions to maintain existing grids. They also suggest removing 'open' tender requirements because switchgear markets rely on long pre-qualification processes.
Manufacturers avoid high costs from changing technologies during ongoing infrastructure delivery contracts.
Climate goals may suffer if exemptions allow the continued use of potent greenhouse gases.

Consultation response

European Association of the Electricity Transmission and Distribution Equipment and Services Industry, 3 Sept 2020

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry welcomes the opportunity to present its feedback experiences from the current 517/2014 “F-Gas regulation”, specifically regarding aspects of SF6 management. Please see the attachment

Consultation response

Bureau Brussels Consulting, 7 Sept 2020

The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the review of rules on flourinated greenhouse gases consultation and wants to draw attention to the following key points: • We must ensure via study that…

Spectaris seeks longer F-gas transition for medical equipment

SPECTARIS Deutscher Industrieverband für Optik, Photonik, Analysen- und Medizintechnik e.V., 29 Jun 2022

Spectaris requests a transition period until 2030 for medical and laboratory devices. They seek clearer definitions of refrigeration equipment to ensure legal certainty for manufacturers.
A longer timeline helps manufacturers manage the severe lack of certification experts.
Delayed phase-outs mean these greenhouse gas emissions will continue causing climate change.

EdEn warns F-gas rules could stall European heat pump deployment

Equilibre des Energies, 29 Jun 2022

EdEn recommends exempting heat pumps from the quota system to support decarbonization. They claim switching to propane refrigerants requires a fifteen-year transition period for safety.
This allows manufacturers to avoid immediate compliance costs and maintain current production.
Environmental groups lose as high-warming chemicals remain in circulation for longer periods.

Consultation response

Daikin Chemical Europe GmbH, 28 Jun 2022

This is a statement by Daikin Chemical Europe GmbH and focuses on the topic of MDIs only. Daikin Chemical Europe GmbH (Dusseldorf, Germany) belongs to the Daikin Group together with Daikin Europe N.V.. While Daikin Europe N.V. produces equipment such as air-conditioning, heat pumps and…

Consultation response

Associazione delle Imprese del farmaco, 29 Jun 2022

The Italian Association of Pharmaceutical Industry (Farmindustria) supports the EU’s goal of net carbon neutrality. We would call on EU legislators to devise the phase-down of medical F-gases in the EU in a way that maintains access to critical medicines for patients, allows for adequate time for a…

Consultation response

Baxter Healthcare SA, 28 Jun 2022

Baxter is a leading global pharmaceutical & medical device company committed to delivering life-saving and sustaining products. We have been working with clinicians and hospitals across Europe for years to provide anaesthetic agents (inhaled & intravenous) that allow clinical treatment to be…

Eurovent warns steep HFC phase down threatens heat pump roll out

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 28 Jun 2022

Eurovent requests maintaining current HFC phase down steps until 2030 and calls for the removal of additional product bans for heat pumps. They also seek exemptions for fixed double duct air conditioners and better definitions for technical terms.
This would give manufacturers more time for research and development while protecting the affordability of their products.
The environment loses as fossil fuel appliances may remain in the market longer due to slower heat pump adoption.

Eurovent Urges Improved F-Gas Enforcement and Technological Neutrality

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 4 Sept 2020

The review should focus on avoiding circumvention of quotas and removing barriers to flammable or reclaimed refrigerants. It must maintain energy efficiency and provide a predictable schedule so industry can adapt.
Better enforcement and predictable price levels would protect compliant manufacturers from unfair competition.
Illegal gas importers and uncertified equipment installers would face more effective market surveillance.

Consultation response

European Federation of Allergy and Airways Diseases Patients' Associations, 29 Jun 2022

EFA welcomes the determination of the European Commission to reduce greenhouse emissions generated in the European Union. Climate change negatively affects human health, and more especially the health of vulnerable people such as allergy, asthma and COPD patients. Asthma affects 30 million…

Consultation response

European Federation of Allergy and Airways Diseases Patients' Associations, 7 Sept 2020

The European Federation of Allergy and Airways Diseases Patients’ Associations (EFA) is the voice of over 200 million people living with allergy, asthma, and chronic obstructive pulmonary disease (COPD) in Europe. We bring together 39 national associations from 24 countries and channel their…

Consultation response

Polystyrene Loop Coöperatief U.A., 21 Aug 2020

Please find attached the feedback from PolyStyreneLoop

Consultation response

shecco, 29 Jun 2022

Dear Policy Officer at the European Commission, dear stakeholders, Please find herewith attached the feedback from the Clean Cooling Coalition on the proposed amendments to the EU F-Gas Regulation. The Clean Cooling Coalition (CCC) is coalition of progressive European companies from the heating,…

Consultation response

shecco, 4 Sept 2020

shecco, together with the Clean Cooling Coalition, welcomes the opportunity to present feedback on the "Fluorinated Greenhouse Gases - review of EU Rules (2015-20)" roadmap. Please refer to the attachment for our detailed submission.

Consultation response

Krajowe Forum Chłodnictwa - Związek Pracodawców, 28 Jun 2022

Przedstawiona propozycja redukcji stosowania fluorowanych gazów (HFC/HFO) jest ogromnym wyzwaniem dla naszej branży i ma wpływ na producentów, instalatorów, serwis i służby utrzymania ruchu dla urządzeń chłodniczych. Zaproponowane dalsze redukcje kontyngentów i objęcie kwotami inhalatorów,…

Consultation response

VDE Verband der Elektrotechnik Elektronik Informationstechnik, 28 Jun 2022

In April 2022, the EU Commission presented a draft for the new version of the F-Gas Regulation (EU Regulation 517/2014). VDE FNN, as a national rule maker and recognized platform for grid technology and grid operation, supports the Commission's climate protection goals especially with regard to a…

Consultation response

International Pharmaceutical Aerosol Consortium, 24 Jun 2022

The International Pharmaceutical Aerosol Consortium (IPAC) and its members support the EU’s goal of net carbon neutrality. As detailed in the attached Position Paper, we call on EU legislators to devise the phase-down of medical F-gases in the EU in a way that maintains access to critical medicines…

Consultation response

Eviny AS, 7 Jun 2022

Eviny AS welcomes the proposal to prohibit installation and replacement of electrical switchgear containing SF6 within the timeframe suggested in the proposal. In our opinion the suggestion will expand the market for climate friendly alternatives, speed up the technological development among…

Consultation response

FUNDACIÓN ECOLOGÍA Y DESARROLLO, 7 Sept 2020

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation for transitioning away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). However, from ECODES, we consider that in the years since its adoption, it has become clear it requires…

Consultation response

International Pharmaceutical Aerosol Consortium, 5 Sept 2020

The International Pharmaceutical Aerosol Consortium (IPAC) represents major pharmaceutical companies – AstraZeneca, Boehringer Ingelheim, Chiesi Farmaceutici, GlaxoSmithKline, and Kindeva – which research, develop, and manufacture products for the treatment of respiratory illnesses such as asthma…

Consultation response

Federation of European Rigid Polyurethane Foam Associations, 29 Jun 2022

PU Europe is the European Federation of manufacturers of thermal insulation products, from construction products manufactured in factories to in-situ formed PU foam, based in the European Union and the UK. Our members provide long lasting products and solutions (over 50 years for most of them) that…

Consultation response

Air Conditioning and Refrigeration European Association, 29 Jun 2022

AREA represents the European refrigeration, air conditioning and heat pump (RACHP) contractors. RACHP contractors are the essential link between end users and manufacturers. They design, install and maintain RACHP equipment using every available solution with complete neutrality towards equipment…

Consultation response

Mexichem UK Limited, 29 Jun 2022

Koura is a global producer and supplier of F-gases including having a significant presence in the global supply of F-gases for use in MDIs. Koura supports the purpose of the F-gas Regulation to transition to lower GWP solutions. Koura supports the strengthening of measures to tackle the threat of…

Consultation response

The Japan Refrigeration and Air Conditioning Industry Association, 29 Jun 2022

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration, air conditioning and heat pump (RACHP) equipment in Japan would like to thank the Commission for the effort for revision of the EU F-Gas Regulation and the opportunity to provide…

Consultation response

European Cold Storage and Logistics Association, 29 Jun 2022

Dear all, please see attached the feedback from the European Cold Storage and Logistics Association - ECSLA. Best regards, ECSLA

Consultation response

Westfalen AG, 28 Jun 2022

Anbei finden Sie die Stellungnahme des Coolektiv zum vorliegenden Vorschlag zur Revision der F-Gas Verordnung.

Consultation response

European Federation of Catering Equipment Manufacturers, 28 Jun 2022

EFCEM (European Federation of Catering Equipment Manufacturers) supports the alignment of the F-gas Regulation with the European Green Deal, European Climate Law, obligations on HFCs under the Montreal Protocol, progress and lessons learned. Professional products represented by EFCEM have a small…

Consultation response

, 27 Jun 2022

La révision du règlement F-Gas 517/2014/UE doit trouver un équilibre et une cohérence avec les différents objectifs environnementaux de l’Union Européenne pour lutter contre le changement climatique. Synthèse de notre analyse et position : La révision de la réglementation F-Gas 517/2014/UE…

Consultation response

, 21 Jun 2022

Siehe angehängte Datei

Consultation response

Deutscher Kaelte- und Klimatechnischer Verein e.V., 20 Jun 2022

Stellungnahme siehe Anlage

Consultation response

Bundesverband Wärmepumpe (BWP) e.V., 20 Jun 2022

Die Wärmepumpen-Branche steht vor einem massiven und großflächigen Markthochlauf. Aus Gründen der Energiesicherheit und des Klimaschutzes werden politische Rahmenbedingungen derzeit so gestellt, dass Wärmepumpen innerhalb weniger Jahre zur neuen Standardheizung werden und potenziell die gesamte…

Consultation response

Air Conditioning and Refrigeration European Association, 7 Sept 2020

AREA, the European association of refrigeration, air conditioning and heat pump (RACHP) contractors, welcomes the timely publication of the combined roadmap / impact assessment. An evaluation of the performance of the existing Regulation is necessary to identify opportunities for clarifying and…

Consultation response

The Japan Refrigeration and Air Conditioning Industry Association, 7 Sept 2020

Please find JRAIA's response to F-gas Regulation Roadmap / Inception Impact Assessment as per attached here.

Consultation response

Bundesindustrieverband Technische Gebäudeausrüstung e.V., 7 Sept 2020

Please find attached the BTGA and FGK joint position paper on the review of this directive.