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F-gas consultation echoes illegal import concerns

BELGIUM: Illegal imports, ineffective policing and penalties have been identified as the most serious challenge to implementation of the European F-gas regulation.

These were the views of respondents to the European Commission’s open public consultation on the F-gas regulation, part of its assessment of policy options for the regulation’s review. A recast of the regulation is likely by the end of this year.

The concerns about illegal imports and enforcement highlighted in the open public consultation largely reflect those of industry stakeholders in their feedback to the Commission last year. 

After illegal imports, respondents to the latest consultation identified “unjustified” barriers in safety standards and codes and the misuse of the quota system as serious concerns. And, while respondents had mixed opinions on the effectiveness of different measures in preventing illegal activities, a majority tended to think measures taken to date had not been effective enough and penalties by European member states were seen as the least effective.

Respondents were split on the effectiveness of customs controls and market surveillance. Reporting and verification was seen as more effective than the other relevant measures.

Overall, however, the Commission noted that there was an “overwhelming response” that the F-gas regulation had had a positive or very positive impact on its objectives. In particular, the responses noted its contribution to meeting the EU’s climate targets and contribution to the Kigali Amendment.

The regulation was also seen to have had a positive impact on stimulating innovation and reducing the use of high GWP F-gases. 


The Commission received a total of 241 responses to the open public consultation, which closed in December. It noted that respondents were, overall, very well informed about F-gases and relevant legislation. 

Over 50% of respondents were individual company/business organisations, while 44 were business associations (18.3%). Other responses were received from EU citizens (11.6%), NGOs (5.8%), public authorities (3.3%), academic/research institutions (2.5%), consumer organisations (1.2%), trade union (0.4%) and several who identified as “other” (5.4%). 

The majority of respondents were concentrated in north-west Europe, with the highest number, 54, from Belgium, followed by Germany (32) and France (31).

A large number of responses also concerned the use of SF6, a high GWP gas used in electrical switchgear equipment, but respondents were most commonly involved in stationary refrigeration/air conditioning (114, 27.0%).

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