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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 air conditioning, refrigeration equipment, and heat pumps.

Lobbying Activity

Response to Energy labelling requirements for local space heaters (review)

15 Aug 2022

JRAIA supports the Commission's position on the energy label which should allow different types of technologies (products) to be evaluated fairly. We will state this in our joint position paper with JBCE to the consultation forum held on 24 June 2022 concerning the merged labelling regulations for room heaters, room air conditioners and comfort fans.
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Response to Review of EU rules on fluorinated greenhouse gases

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 our comments. In this paper, we would like to comment on the proposed revision of the Regulation. RACHP business sectors have contributed to maintaining/improving human life, through comfort air-conditioning, industrial air conditioning (necessary for many manufacturing processes, Data centers, etc.). RACHP products and in particular Heat Pumps are indispensable to sustainability. The review of the EU F-Gas Regulation is a focus of attention for the global RACHP industry facing very significant challenges. JRAIA is of the opinion that this revision is the most consequential because the F-Gas Regulation is one of the pillars for the achievement of carbon neutrality. All of the policies in place in the current F-Gas Regulation from 2014 can already be considered to be successful and have already led to very substantial decreases in GHG emissions. However, a close look at the Commission proposal makes us think that the proposal really may stall the growth of the RACHP industry. This would have negative impacts on accelerating electrification of heating through Heat Pumps, and moving away from boilers that run on fossil fuels. The F-Gas proposal in essence undermines and goes against the REPowerEU plan, both the initial version of March and the final Plan of May 2022. Not only do we feel strong apprehensions about many elements of the F-Gas proposal, but there are quite a few inexplicable points which we believe need to be adapted, altered or at the very least clarified. Attached are JRAIA’s comments on the Proposed Revision. We would deeply appreciate it if our comments below could be taken into consideration.
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Response to Ozone layer protection – revision of EU rules

23 Jun 2022

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration and air conditioning equipment in Japan would like to comment on the proposal for the European Parliament and of the Council on revision of ODS Regulation (EC) No 1005/2009. We would deeply appreciate it if our comments below could be taken into consideration. 1. Article 3 : Definitions There is a lack of definitions of “air conditioning” and “heat pump”. The definitions in Article 3 are proper and understandable. In particular, it stands to reason that equipment and products are clearly defined.in such a way as to include their parts, which implies that the” repair as produced principle” can be applied. There are, however, no definitions of the two terms associated with the concept that will take center stage. The difference in definitions between the proposed ODS Regulation and the F-gas Proposal would cause confusion. 2. ANNEXES I and II : Ozone depleting substances referred to in Article 2(1) GWP values are added in Annexes. The ODS Regulation does regulate ozone depleted potential, not global warming potential. The new substances have low GWPs. Therefore, their description for information purposes would be incongruous. Detailed comments are in the attached file.
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Response to Sustainable Products Initiative

22 Jun 2022

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) deeply appreciate European Commission’s effort taken for an Ecodesign for Sustainable Products Regulation (ESPR), and welcomes this opportunity to feedback regarding the proposal for the ESPR. Executive Summary 1. In the development of delegated legislation for ecodesign requirements, it is desirable to clarify and implement only the necessary items by carrying out a feasibility assessment well in advance, considering factors such as avoiding duplication, considering the balance between environmental impact reduction and implementation costs, the existence of internationally recognised assessment and test methods and relevant harmonised standards, and technical documentation in the conformity assessment. As the characteristics of products vary from one product category to another, delegated legislation should identify the necessary items after a full assessment of each product category has been carried out. JRAIA would like to see the introduction of clear and effective acts in these processes, with ample opportunity for consultation with stakeholders, including manufacturers. 2. Requirements should be assessed based on a product-by-product approach. This is needed to understand the relevant and feasible requirements for each product group. What makes sense for one product group, might not for another. For example, a reparability score can be relevant to specific consumer products, whereas it might not be for products that can only be repaired by certified professionals or products that have very long lifetimes. Horizontal regulations would not be based on a product-specific approach and potentially involve the risk that certain requirements are not fit for purpose towards specific product groups. A vertical approach is recommended in order to avoid this. 3. It is necessary to ensure that requirements are measurable and verifiable: material efficiency requirements such as reparability, durability or recycled content are difficult to quantify and might not be so easy for market surveillance authorities to verify. Recycled content in particular creates concerns as there is no way to distinguish virgin material with recycled material. Such aspects should be considered before introducing certain requirements. 4. In order to maintain harmonisation between the entire set of EU regulations and provide certainty, requirements already covered by existing EU law should in principle be considered for regulation under those regulations. Each chemical substances that are “substance of concern” should be regulated separately in individual regulations. (e.g. F-Gas Regulation, WEEE and RoHS Directive, REACH Regulation, Conflict Minerals Regulation, POPs Regulation, and the forthcoming Sustainable Corporate Governance). 5. Cascading (so-called “Double regulation”) should be avoided. Regulating components or parts that are embedded in products that are also regulated under the ESPR limits the flexibility of design for the final product manufacturer and does not necessarily lead in every case to higher savings in every case. Detailed comments on the draft ESPR are in the attached file.
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Response to Ecodesign requirements for water heaters and tanks (review)

28 Mar 2022

JRAIA's position on the review of ED/EL for ENER-Lot2 has not been changed since the consultation forum held on 27th and 28th September 2021. Please refer to the attached document.
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Response to Energy labelling requirements for space and combination heaters (review/rescaling)

28 Mar 2022

JRAIA's position on the review of ED/EL for ENER-Lot1 has not been changed since the consultation forum held on 27th and 28th September 2021. Please refer to the attached document.
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Response to Energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans [review]

17 Feb 2022

JRAIA's position on the review of ED/EL for ENER-Lot10 has not been changed since the consultation forum held on 6th July 2021. Please refer to the attached document.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

JRAIA believes that careful consideration is required to avoid unnecessary complication, double regulations by taking into account logistical efficiencies of the products.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

JRAIA acknowledges that changes to the REACH regulation will lead to increased costs for industry throughout the supply chains. Furthermore, EU policy options contribute to keeping climate and environmental impacts need to be considered energy efficiency in parallel which is currently proposed in the European Green Deal. JRAIA believes that careful consideration is required to avoid unnecessary complication, double regulations. An appropriate reclaim and recycle of the chemical substances in line with CEAP also needs to be considered.
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Response to Review of EU rules on fluorinated greenhouse gases

7 Sept 2020

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