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German concern over ENVI F-gas report

GERMANY: Industry groups in Germany have warned that F-gas amendments proposed by the European parliament’s environment committee would jeopardise existing systems and put climate policy goals at risk.

A number of German refrigeration and air conditioning associations have written to the European parliament’s committee on environment, public health and food safety (ENVI) calling for the rejection of several of the amendments.

The groups –  contractors body VDKF, the federal guild BIV, refrigeration and air conditioning heat pumps association ZVKKW and the Bundesfachschule Kälte-Klima-Technik training organisation – say that while the EU Commission’s proposed amendment was viewed by many as a threat to the refrigeration and air conditioning industry, the ENVI committee “is once again tightening the thumbscrews” – especially as far as the bans are concerned. 

The ENVI proposal, published in October, provides for, among other things, a general ban on placing stationary refrigeration systems with F-gases on the market from 2025 onwards. It also seeks a general ban on the placing on the market of  single split air conditioners and heat pumps with F-gases from 2026, of split air-conditioners and split heat pumps with F-gases with a rated output of up to 12kW from 2027, as well as a ban on F-gases with a GWP >150 in these plants with a nominal output above 12kW up to 200kW from 2028. 

There are similarly rigid ENVI requirements for maintenance and service. From 2024, a ban on the use of F-gases with a GWP >150 for maintenance and service on stationary refrigeration systems (with the exception of chillers) is planned; in the case of air conditioning systems, heat pumps and chillers, this ban applies to F-gases with a GWP >2500. This would also apply to recycled refrigerants.

The organisations have said that they welcome the goals of the F-gas regulation and support the gradual reduction of fluorinated refrigerants and the priority use of natural refrigerants wherever it is technically possible and makes sense from an energy perspective. 

However, they confess to being “extremely concerned” about the wording of the ENVI proposals, which, they say, neither the operators of the millions of existing refrigeration and air conditioning systems nor the installers can implement.

Should the ENVI proposal be implemented as it stands, the groups claim that the operation of countless refrigeration, air conditioning and heat pump systems in systemically important sectors of the economy would be at risk and system operators saddled with an unplanned high investment in difficult economic times. 

From an environmental standpoint, the groups echo the concerns of other European industry bodies that the proposals would put climate policy goals at risk.

Germany, with its great many refrigeration, air conditioning and heat pump manufacturers, would be disproportionally affected.

The German organisations are therefore calling for the rejection of several ENVI amendments, specifically a further drastic reduction in quotas and bans on the use of F-gases for service and maintenance on refrigeration systems. 

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