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Air Conditioning and Refrigeration European Association

AREA

AREA is the European federation whose members are the national federations representing refrigeration, air conditioning and heat pump contractors.

Lobbying Activity

Response to Minimum requirements for certification programmes and training attestations of air-co systems in certain vehicles

15 Oct 2024

AREA, the European association of refrigeration, air conditioning and heat pump (RACHP) contractors, fully supports an ambitious transition to alternatives to f-gases. To avoid accidents, injuries and fatalities involving systems with alternative greenhouse gas refrigerant which all present safety issues, and many of which are flammable, training and certification are essential. Thus, AREA welcomes the draft Implementing Act on new minimum training attestations requirements for air-conditioning systems in mobile equipment. Whereas the sufficient competence of the technicians is an indispensable risk-mitigating factor, and therefore a precondition for a successful transition from F-gases to alternative low GWP refrigerants, the Regulation should not lead to an overtraining of the contractors. For example, the competencies required to work on light duty vehicles should not be the same as those needed for trains systems. In addition, the Regulation should not create bridges between sectors, and particularly between car mechanics and the refrigeration fields. Competencies are very specific to each sector, and allowing attestations from one to apply to the other could have very harmful consequences. With this in mind, AREA would like to make the following suggestions for changes: Duration and refreshing training: A refreshment training every 7 years (similar to the F-gas certification) is essential due to rapid technological advancements. For instance, R290 (Propane) is expected to become common in cars within the next decade. Separate attestations: Attestations should be divided into 3 categories: - M1 for fluorinated gases and hydrocarbons- all vehicles, - M2 for fluorinated gases and hydrocarbons- only light duty vehicles and - N for CO2 (Currently, 700,000 electric vehicles in Europe already use CO2) Categories M requirements: Categories M1 and M2 should include more stringent safety and flammability requirements (similar to the F-gas certification) given the similarities between Implementing Act 2024/2215 and this Act.
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Response to Minimum requirements for certification programmes and training attestations for RACHP equipment

10 Jun 2024

AREA, the European association of refrigeration, air conditioning and heat pump (RACHP) contractors, fully supports an ambitious transition to alternatives to f-gases. However, AREA members have been voicing concerns regarding the very low level of training on alternative refrigerants among F-gas trained personnel and on the risk of a shortage of contractors trained in the use of low GWP refrigerants for years. Training and certification are required to avoid accidents, injuries and fatalities involving systems with alternative refrigerants which all present safety issues, and many of which are flammable. Therefore, AREA welcomes the extension of the F-gas certification scheme to alternative refrigerants in the new F-gas Regulation as a necessary complementary addition to the existing F-gas provisions in order to ensure safe, efficient and reliable handling of these refrigerants. Our position on the Implementing Act on training and certification is available in the attached document.
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Response to Review of EU rules on fluorinated greenhouse gases

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 and refrigerants, in the sole aim of ensuring the highest level of reliability, energy efficiency and cost-effectiveness. The European RACHP contracting industry fully subscribes to the EU’s decarbonisation and climate neutrality aspirations set out in the European Green Deal and, more recently, in the Fit-for-55 package. In this spirit, AREA also stands by the F-Gas Regulation’s objectives of reducing emissions of fluorinated greenhouse gases, and in particular those with high global warming potential (GWP). In this respect, our members play an important role in the transition to climate-friendly RACHP solutions, bearing in mind that the overall environmental impact of RACHP systems needs to be considered beyond refrigerants’ GWP, with a particular focus on energy efficiency and circularity of applied materials. The F-gas Regulation is arguably the most important and impactful piece of EU legislation for our sector. Its provisions dictate the conditions under which our contractors - the immense majority of whom are very small companies with a local market – carry out most of their operations. As concluded by the European Commission’s review, the current F-Gas Regulation has successfully achieved its objectives, setting a gold standard for the rest of the world. The Regulation has also had a tremendous impact on our industry, bringing opportunities but also unprecedented challenges that put many of our companies - in particular the smallest ones - to a tough test as regards refrigerants prices, available technical alternatives, and of course competence and skills. Despite the Regulation’s proven success, the proposal for a revision substantially toughens two of its core provisions - the phase-down scheme and the placing on the market prohibitions – with the stated goal of further accelerating the market penetration of alternatives, and in particular natural refrigerants. Yet, the proposal ignores the actual ability of the RACHP contracting sector to cope with such a surge. More worryingly, it fails to ensure that equipment working with alternative refrigerants can only be handled by competent contractors, thereby leaving the door wide open to widespread safety hazards and energy inefficient equipment. European RACHP contractors represented by AREA remain fully committed to the transition to climate-friendly alternatives to f-gases. For such a transition to be a success, several conditions ought to be met: the timing needs to be aligned with market and technological realities, equipment obsolescence should not be unduly forced, and alternative refrigerants – most of which are also greenhouse gases – should be properly regulated. It is also necessary that national authorities are ready. Indeed, they are in charge of setting and implementing some of the administrative framework surrounding many of the legal provisions, as well as enforcing those. Their readiness is a prerequisite so that market operators can fulfill their own respective requirements. With this in mind, AREA would like to give its opinion on the proposal for a revision in the attached document.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

AREA members, as the architects of RACHP systems, responsible for their design, installation, maintenance and repair, welcome the revision of the Energy Performance of Buildings Directive. With cooling needs expected to increase in the years to come, the refrigeration, air conditioning and heat pump (RACHP) sector has an important role to play in delivering on the energy efficiency and decarbonisation targets for 2030. Without proper design of the cooling system, energy savings of efficient equipment can be totally negated. Indeed, proper system design, effective installation, as well as regular maintenance and servicing are of the utmost importance to ensure that expected energy savings become a reality. Periodic inspections of heating and cooling systems are necessary to ensure the efficient functioning of the system, even in the presence of automated monitoring systems. RACHP contractors have in-depth knowledge on the design of systems, proper maintenance and operation and can provide tailor-made solutions to consumers based on users’ specific needs. They use every available solution with complete technology neutrality and with the sole aim of ensuring the highest level of reliability, energy efficiency and cost-effectiveness. We would like to take this opportunity to bring attention to some key aspects of the proposed revision in the attached document.
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Response to Ecodesign requirements for water pumps (review)

9 Feb 2022

Europump, the European Association of Pump Manufacturer Associations, welcomes the Commission's call for evidence for the initiative to revise the water pumps regulation EU 547/2012. Since the last Decade Europump supports initiatives and actions from the EU-Commission for energy savings in general and especially the regulations under the Ecodesign Framework-Directive for Water Pumps and for Circulators. When finalizing the existing regulation in 2011/12, Europump had to accept supporting the legislative approach on pumps alone (motor legislated in a separate piece of legislation, without VSD), knowing that this will bring little savings compared to a broader view on pump-units and their operation to be regulated. This approach is mentioned in “Article 7 – Revision” of the regulation EU 547/2012 itself, the so-called Extended Product Approach. The motor regulation EC 640/2009 which was developed under the same LOT of energy using products in parallel, considered frequency converters to be attached to the motor and allowing a lower IE-Class (IE2) than requested for stand-alone motors (IE3). Compared to the “business as usual” scenario this measure accounted for about 90-110 out of the 135 TWh p.a. by 2020 on energy savings alone depending on the different EU sources available (see attched file for details). In the revision study EU-Com itself proved this part of the regulation not to happen and therefore decided to delete the option from the regulation in its revised regulatory text published under EU 2019/1781. Consequently, the majority of the projected savings will not take place if not caught by other legislative means. For the pump side the Extended Product Approach is the answer to make these kind of savings happen (~ a third of it – 30TWh). Since several years now, throughout the revision process of the water pump regulation, Europump organized, supported and published independent studies by universities and contributed with needed information to the consultants who carry out the revision-study and impact assessment reports. All this culminated in the Consultation Forum in October 2019 where Europump supported the general way forward of the Commission, showed ways out of obstacles market surveillance authorities may have seen and suggested to have an EEI-legislation and requirements on a limited scope where it can be proofed that the expected energy savings will be obtained. Europump also promised to put effort in broadening the scope for following revisions in case a first step towards the Extended Product Approach with the regulation discussed would have been taken. Since then, very little progress on the legislative side was made in Europe. The consultants worked on an impact assessment report. A new draft text has not been made available. Therefore, Europump contributes to this “Call of Evidence” mainly with information already given inside the Consultation Forum in 2019 and an overview of the milestones achieved in the meantime. Taiwan has put a pump regulation in place which came into force beginning of 2022 and has its basis on the proposed methodology from Europump, the CEN Standards available and the draft legal text by EU-Com from 2019. According to our contacts in the UK, Great Britain through BEIS are looking to introduce the EPA earlier than the EU. Europump takes the opportunity to underline again its willingness to support the Extended Product Approach and would like to motivate all involved parties to overcome obstacles with constructive proposals and make the energy savings happen. Yours sincerely Frank Ennenbach, EUROPUMP Standards Commission Chairman Markus Teepe, EUROPUMP Ecodesign Working Group Chairman Attached file contains a compilation of 1) this text 2) Slide Deck from Consulation Forum Water Pumps 2019 3) Annex 13 to study of VHK water pump report 2019 for more details
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

Cooling is present in many aspects of our lives, playing an essential part in support of a variety of societal needs, ranging from food conservation and healthcare to residential and office comfort, and data center operations. In this context, it is no wonder that refrigeration and air conditioning applications have a significant share of the global energy consumption. With cooling needs expected to increase in the years to come, the refrigeration, air conditioning and heat pump (RACHP) sector has an important role to play in achieving the EU renewable energy targets and the overall European goal of climate-neutrality by 2050. In this context, AREA members, as the architects of RACHP systems, responsible for their design, installation, maintenance and repair, welcome the Fit for 55 Package, and more specifically, the revision of the Renewable Energy Directive. We would like to take this opportunity to set out what we believe are key conditions for our sector to contribute to the achievement of this ambitious objective. In particular, we would like to comment on article 18(3) and Annex IV of the draft Directive in the attached position paper.
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Response to Ecodesign and energy labelling working plan 2020-2024

6 May 2021

Dear Ladies and Gentlemen, Europump, the European Association of Pump Manufacturers, has some comments to the preparatory study done by Viegand Maagøe (see attched Excel sheet). Our main concern are the potential energy savings of the smart sensors. These savings are already included in the Extended Product Approach of our pumps. There is a high risk that these savings are counted multiple times. Vibration sensors as described in your report will be not help to run the pump at its optimal duty point required by the system. Pumps only vibrate if something goes wrong in the application or if the wrong pump was selected. The Extended Product Approach is based on the fact that the pump delivers the head and flow as required by the application by varying the rotational speed of the pump. Today this is done by a VFD. To establish and control the requirements of the application (pumping system) various types of sensors are needed (e.g. flow and pressure sensors). If the pump runs close the best efficiency point, there will be no vibration. Running the pump optimized for the system at any given point in time will ensure a minimum energy consumption. Dipl.-Ing. Frank Ennenbach Chairman of Europump Standards Commission
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

With cooling needs expected to increase in the years to come, the refrigeration, air conditioning and heat pump (RACHP) sector has an important role to play in delivering on the Renovation Wave targets for 2030. In this context, AREA members, as the architects of RACHP systems, responsible for their design, installation, maintenance and repair, welcome the revision of the Energy Performance of Buildings Directive. We would like to take this opportunity to set out what we believe are key elements to be considered when revising this legislation. The crucial role of RACHP contractors RACHP contractors have in-depth knowledge on the design of systems, proper maintenance and operation and can provide tailor-made solutions to consumers based on users’ specific needs. They use every available solution with complete technology neutrality and with the sole aim of ensuring the highest level of reliability, energy efficiency and cost-effectiveness. Without proper design of the cooling system, energy savings of efficient equipment can be totally negated. Indeed, proper system design, effective installation, as well as regular maintenance and servicing are of the utmost importance to ensure that expected energy savings turn into reality. Heating and cooling systems cannot be properly operated without constant monitoring, maintenance and improvements where needed. In fact, proper and regular maintenance carried out by competent people are an important factor to achieve energy savings and reduce operating costs. It is also the occasion to provide advice on further energy savings. Periodic inspections of heating and cooling systems are indeed necessary to ensure the efficient functioning of the system, and this even in the presence of automated monitoring systems. Contractors’ skills and knowledge To create new jobs and to address existing shortages of qualified staff, investments in skills will be needed. Delivering the necessary deep renovations will depend on the knowledge and expertise of building professionals. The services of our industries are vital for achieving the objectives of the Energy Performance of Buildings Directive. However, our sectors face challenges in attracting and retaining talent in the industry. In addition, refrigeration and air conditioning is a very innovative and constantly evolving industry. The high level of technicality of RACHP systems makes it necessary to have a corresponding level of competence from installers. Therefore, maintaining contractors’ skills and knowledge is of utmost necessity to ensure the deployment of decarbonised and energy efficient technologies. We are fully supportive of harmonised initiatives fulfilling this objective, as long as they are coordinated. Growing demand for cooling Whereas focus is traditionally put on heating, the growing demand for cooling in summertime for both residential and non-residential buildings should be taken into consideration when revising the EPBD. Indeed, the increasing need for cooling that is witnessed already now, is predicted to continue going forward. This is particularly visible in modern buildings that are better insulated and usually have more equipment generating heat (like computers and servers). In this context, contractors have an important role to play in achieving the EU energy efficiency targets. Improving indoor environmental quality (IEQ) Renovation can also improve comfort and sanitary conditions, making buildings healthier and improving wellbeing. In addition to improving the energy efficiency of buildings, the Energy Performance of Buildings Directive should also aim at delivering improvements in indoor environmental quality (IEQ). This can be achieved by setting harmonised mandatory minimum requirements for IEQ and for accelerating the replacement of old systems.
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Response to Review of EU rules on fluorinated greenhouse gases

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 simplifying the rules and strengthening their enforcement. It will also give the possibility to update the rules, notably in light of technical progress made and lessons learned during the implementation.  Training/certification/competence As part of the objective “Improve implementation and enforcement”, the option for technicians also to be trained on the use of alternative refrigerants is mentioned. We would like to point out that training is a tool but not an end in itself. What matters is competence, which must be evidenced. This is the correct approach of the current F-Gas Regulation, which provides for mandatory certification. We strongly believe that this approach must be followed for the same considerations on alternative refrigerants. Focussing on mandatory training would result in unnecessary obligations for those installers that are sufficiently knowledgeable, thereby creating a disproportionate cost for those very small enterprises.  Implementation and enforcement of the Regulation As mentioned in the roadmap, one of the main challenges to be tackled is linked to the implementation and enforcement of the Regulation. Indeed, insufficient enforcement of the f-gas regulation has led to illegal imports of refrigerants that are artificially weakening the effect of the phase-down and creating unfair competition on an already tense market. Stronger control of illegal imports is urgently needed. For a matter of clarity, article 11.5 needs to be refined, particularly regarding online sales of air conditioning units for private homes to ensure a proper enforcement of the RegulationFinally, as the use of alternative refrigerants increases, the question arises whether it is justified that those alternatives – most of which have safety issues - escape any legal scrutiny. For instance, it should be ensured that HC split systems, the sales of which rise as a result of the Fgas Regulation, are placed on the market, sold and installed in a safe manner by professional installers. The assessment of the Fgas Regulation should offer an opportunity to look into this, whether by enlarging the scope of the Regulation to include alternatives, a stand-alone legislation.  Orientation towards a stronger phase-down of the F-gas use AREA remains supportive of the Regulation’s objective to substantially reduce emissions of fluorinated greenhouse gases. This evaluation should focus on how the phase-down is fulfilling this purpose. However, in addition to the aspects mentioned in the roadmap, this evaluation should also take into consideration the following elements:  Economic and social costs to taxpayers and consumers, who will finally pay all the costs caused by changes to F-gas regulation.  Lifetime of the refrigeration and heat pump systems: 20 years lifetime is very usual for these systems which should not be dismantled before the end of their lifetime if the system is leak-free and energy efficient.  TEWI: An evaluation of the phase-down provides an opportunity to broaden view than just the GWP levels and look at the overall energy efficiency and life cycle costs of the equipment, including the total equivalent warming impact of the project/installation (TEWI). This would enable a more accurate apprehension of the real impact on CO2 emissions  Maritime sector: Emissions at sea are of a tremendous size compared to those at land. Saving 1 kilo on land makes no sense if ships shed 100 kilos. We appreciate the international dimension of this issue but strongly believe that its sheer size, as well as the existence of well-known alternatives (CO2, ammonia), justify it to be included in the evaluation.
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