The Japan Refrigeration and Air Conditioning Industry Association
JRAIA
The Japan Refrigeration and Air conditioning Industry Association (JRAIA) and its member companies represent the interests of producers and developers of refrigeration, air conditioning and heat pump equipment.
ID: 857375848714-69
Lobbying Activity
22 Jan 2025
The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration and air conditioning equipment in Japan is continuously pursuing and supporting the development of environmentally friendly technologies to contribute to the conservation of the global environment. JRAIA supports the two main amendments that were presented by DG ENER on 18 December 2024. The proposed amendments give better clarity to Regulation 2024/1834. First, Article 9(1) is clearer thanks to the editorial amendment given in Article 1(2) of the proposed amending Regulation. There were concerns over the transitional periods of both fans integrated into other products and spare part fans, and, as such, the new wording explicitly states that integrated fans have a 3-year transitional period and spare part fans a 13-year one. Second, the substantial amendment regarding the verification tolerance value of the fan speed in Table 3 of Annex IV sets it now at 5%, while it was previously set at 2% (Annex(4)) of the proposed amending Regulation). 5% is welcomed by JRAIA as it fits better the current market and is in line with similar technical requirements of tolerance found in ecodesign requirements for professional refrigeration (ENTR Lot 1) and ecodesign requirements for air-to-air heat pumps and air-conditioners (ENER Lot 10). However, changes in certain definitions are unprecise and lead to confusion. The substantial amendment leads to a rework on the definitions. DG ENER proposed a new definition of BEP, best efficiency point and a new definition of inherent speed as well. These proposed definitions in the amending Regulation (Article 1(1)) are confusing. The Inherent speed definition reads: (32) inherent speed means the rotation speed of the fan impeller, when the fan is operated at its nominal voltage and frequency (50 Hz, or 60 Hz in case of motors rated at 60 Hz only), applying the out-of-the-box default settings in case of VSD- driven fan. Yet, it is not precise which default settings should apply in the case of a fan integrated into another product; while JRAIA understands this is relevant for standalone fans, it is not appropriate not fans integrated into products. The inherent speed can be different for the same fan in different products. As such, we would suggest a change to the new definition of BEP, best efficiency point as follows, to ensure that also fans integrated into products are considered: (3) best efficiency point (BEP) means the best energy efficiency point for fan operation, determined at inherent speed; or as declared by the manufacturer for fans integrated into products; JRAIA believes this will avoid confusion among manufacturers, importers of equipment, and authorised representatives. We would be very happy if you consider our comments.
Read full response15 Oct 2024
The Japan Refrigeration and Air Conditioning Industry Association (JRAIA), representing manufacturers of refrigeration and air conditioning equipment in Japan, appreciate the opportunity provided by the European Commissions to express industrys comments regarding Draft Implementing Regulation Ares(2024)6576996 and its Annex on new minimum certification requirements for air-conditioning systems in mobile equipment proposed pursuant to Regulation (EU)2024/573. JRAIA supports the proposed implementing regulation Ares(2024)6576996 and its Annex, and considers reasonable as minimum certification requirements for air-conditioning systems in mobile equipment. However, to ensure the actual implementation of the regulation will require the accreditation of certification bodies that are capable of developing training manuals on the operations for the various types of vehicles and refrigerants covered. According to Article 4 of the proposed regulation, the accreditation of certification bodies is left to Member States, but those certification bodies should be notified by Member States to the European Commission in accordance with Article 4 (2) of current regulation (EC) No. 307/2008. Handling of flammable refrigerants, including R-1234yf which is becoming popular as the refrigerant for mobile air conditioning systems, requires higher level of safety consideration compared to conventional training contents for non-flammable ones. Therefore, training manuals should include handling procedures that take into account the configuration of the air conditioning equipment installed in various types of vehicles and the installation conditions, and also that take into account high level of safety considerations. In addition, JRAIA hopes that the Commission will take responsibility on the appropriate certification by competent bodies. We, JRAIA, would like to make further contributions, whenever useful and needed, and share the knowledge and experience of our members. We remain at your disposal and look forward to working with you throughout this review process.
Read full responseResponse to Persistent organic pollutants - UV-328
27 Aug 2024
The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration and air conditioning equipment in Japan is continuously pursuing and supporting the development of environmentally friendly technologies to contribute to the conservation of the global environment. UV-328 is to be regulated not only as a chemical substance but also as a content in an article under the POPs regulation. Therefore, we are promoting the substitution of UV-328 used in Refrigeration, Air Conditioning and Heat Pump (RACHP) equipment. On the other hand, the Ecodesign for Sustainable Products Regulation (ESPR) promulgated in 2024 provides the prohibition of disposal of products and the requirements for long term use of products like reusability and repairability. In order to meet both these new requirements and the POPs regulation promulgated in 2019, certain exemptions for RACHP equipment are indispensable. Specifically, the placing on the market of UV-328 present in articles and the use of such articles should be allowed as follows: 1) Spare parts for RACHP equipment that has already placed on the market in the Union before or on the date of the regulation where UV-328 was initially used in their production. 2) RACHP equipment and its spare parts containing UV-328 that has already placed on the market in the Union before or on the date of the regulation. Otherwise, this will result in the following and would make it impossible to achieve the product sustainability that ESPR aims for. 1) Since placing on the market of the spare parts will be prohibited after the start date of the regulation, it is impossible to repair a RACHP equipment that has already been placed on the market before the start date of the regulation. Therefore, the products must be discarded in case the products break down. 2) A RACHP equipment or its spare parts cannot be used after the start date of the regulation, if they have been placed on the market, for example import in the EU market, but use of them has not started, for example sold to end user, by the start date of the regulation. Therefore, the RACHP equipment or its spare parts must be discarded. We would be very happy if you consider our comments.
Read full responseResponse to Minimum requirements for certification programmes and training attestations for RACHP equipment
10 Jun 2024
JRAIA(The Japan Refrigeration and Air Conditioning Industry Association) would like to submit following comments. 1) General Comment The Article 1 of the F-Gas regulation mentions laying down rules on related ancillary measures, such as certification and training, which includes the safe handling of fluorinated greenhouse gases and of alternative substances that are not fluorinated. On the other hand, the scope of the F-Gas regulation is limited to only F-gases according to the Article 2 of the F-Gas regulation. JRAIA has some concerns that those who will only work with natural refrigerants may not get the certification & training due to the unclear scope. JRAIA expects that the safety of natural persons who especially perform activities entailing opening into the refrigeration circuit containing natural refrigerants in any stage of the product lifecycle, should also be covered depending on the products category, by certification programs fully aligned with applicable harmonized European standards. 2) Article 3.2 Heat pumps can reduce the greenhouse gas emissions from heating and hot water supply compared to fossil fuel boilers, and are considered as a key technology for achieving EUs climate neutrality. In order to accelerate the deployment of heat pumps for each household, it is crucial to expand the number of installers who can install and maintain heat pumps. Establishment of certification category applicable only to residential applications, similar to category II of the current implementing act, can narrow down the necessary skills and knowledge, and make it easier for more people to get the certification and training. Since this will consequently contribute to speeding up the deployment of heat pumps and decarbonization, new category for residential application should be established.
Read full responseResponse to Update of format of F-gas labels
4 Jun 2024
JRAIA (The Japan Refrigeration and Air conditioning Industry Association) would like to submit following comments. 1) Article 1.11 In the Article 1.11, metered dose inhalers (MDI) allow to be complemented by the statement with reduced impact on the climate. However, JRAIA understands this statement can also be applied to any other products that contain lower GWP refrigerant We recommend the commission to apply this statement for other products to ensure the end-users understanding. 2) Article 3 JRAIA is concerned about the limited implementation time of the new labelling requirements. The requirements are newly applicable to products and equipment containing or relying on HFOs, and existing labels for HFC blends (with HFO / non-fluorinated gases) require changes due to new GWP values. In general, new labels following requirements are prepared by the manufacturers several months before the products enter into EU market. Especially if shipped from outside of Europe, more time is required for manufacturers. For this reason, JRAIA calls for a grace period of twelve month from 1 January 2025, the date of entry into force.
Read full responseResponse to Regulatory measure on the review of ecodesign requirements for industrial fans
3 Nov 2023
The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration and air conditioning equipment in Japan would like to comment on a draft act of Ecodesign requirements for fans driven by motors with an electric input power between 125 W and 500 kW (ENER Lot 11) and repealing Regulation (EU) No 327/2011. JRAIA welcomes the Commission for incorporating some of the proposals in JBCE and JRAIAs joint position paper for the Consultation Forum on 9th June 2023 into the draft act. However, we deeply appreciate it if you could take our comments below into consideration before adoption by the Commission. 1. Remove any risk of double regulation 2. Spare Parts Requirement for Integrated Fans 3. Consideration of PFAS restriction proposal For details, please find a document attached here.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) supports the Commission's proposal to repeal the existing EU Packaging Waste Directive and to renew the regulation on packaging and packaging waste as a legislative act. We believe that this revision will explicitly limit Member State-specific requirements under Article 4 to achieve more exclusive harmonization at EU level, and will prevent unharmonized legislation among Member States. JRAIA strongly recommends that the Commission will take economically viable scheme in line with the policy objectives of the European Green Deal and the new Circular Economy Action Plan. We deeply appreciate the Commission to take our comments attached here for further consideration.
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