EC urged to reconsider pre-charge rules
15th July 2018
EUROPE: Leading European air conditioning and refrigeration groups are claiming that the current interpretation of the F-gas regulations is making European manufactured products uncompetitive.
In a letter to the European Commission the groups, which include AREA, ASERCOM and EPEE, have called for a “reconsideration” of the current interpretation of the pre-charged equipment provisions in the quota system.
“The current interpretation of certain export provisions in the EU F-gas Regulation (EU 517/2014) and its implementing regulation (EU 1191/2014) has a negative impact on the competitiveness of EU manufacturers and hampers the export of innovative technologies,” the groups say.
Currently, the refrigerant in pre-charged equipment manufactured in Europe for export outside Europe is still included in the quota system. The situation has been exacerbated by the current refrigerant price increases and supply restrictions, and puts European manufacturers at a competitive disadvantage in world markets.
The manufacturers maintain that, “legally”, pre-charged equipment should not be included in the quota system as it is now. They argue that as these appliances represent only 1% of the total available quota, properly applying the quota system to pre-charged equipment exports would not affect the phase down.
“From a competitiveness perspective, properly applying the quota system to “precharged” equipment exports helps to partly level the playing field between companies manufacturing inside and outside the EU,” the groups say. They also add that companies who manufacture in the EU must cope with the use of new refrigerants and components, while their competitors outside of the EU don’t have to.
The letter sent last week is signed by European home appliance manufacturers body APPLiA, refrigeration and air conditioning contractors representative AREA, component manufacturers group ASERCOM, the German heat pump association BWP, heating equipment body EHI, the European Heat Pump Association (EHPA), EPEE, EUROVENT, UK manufacturers group FETA, the German manufacturers body FGK and Poland’s National Refrigeration Forum KFCh.
While, at first welcomed by the industry groups, DG CLIMA’s establishment of the Customs Inward Processing (IPR) has also not solved the problem.
“Unfortunately, after closer examination it does not solve the problem as it can only be applied to less than half of all cases for different reasons,” the groups state in their joint letter. “Moreover, it turned out to be a very complex administrative procedure which is extremely difficult, if not impossible to handle for SMEs.
“For these reasons and given our strong commitment to making the HFC phase-down a success, both in Europe and beyond, we urge the European Commission to reconsider their interpretation of the export provision for ‘precharged’ equipment. The F-Gas Regulation clearly allows to do so, and there are straightforward and quick solutions. For example, the issue can be solved by adapting the HFC register. Only then would global competitiveness of Europe’s production be ensured.”
Earlier this year, the German air conditioning and refrigeration industry made representations to the German Environment Agency, maintaining that pre-charged equipment manufactured in Europe and exported out of the EU should have the refrigerant credited back to the allowable quota.
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F-gas threatens Euro manufacturers – 4 February 2018
GERMANY: The German air conditioning and refrigeration industry has warned that refrigerant shortages and high prices risk putting European equipment manufacturers at a severe disadvantage in global markets. Read more…
