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German groups warn of refrigeration “extinction”

GERMANY: Industry groups are pleading with their members and their customers to urgently draw the attention of politicians to the “major problems” posed by the F-gas revision and PFAS proposals.

A position statement/letter produced by four of the leading industry bodies claims that the current drafts of the amendment to the European F-gas regulation and the proposed PFAS restrictions threaten many refrigeration systems with extinction.

It warns members that the regulations, if passed, have the potential to limit the use of fluorinated refrigerants in refrigeration, air conditioning and heat pump systems, making them either unavailable or only available to a very limited extent, in both new and existing systems.

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 –  stress the urgency of action with the EU Parliament due to vote on the F-gas regulation at the end of this month.


To stress the possible effects, the German alliance provide a number of examples of the possible effects and consequences of the two regulations.

It cites the case of a German news broadcaster investing almost €1m this year in a new essential refrigeration system with F-gases for studio and server cooling. The installation corresponds to all currently valid ordinances and regulations and would normally have a lifespan of 15 to 20 years. However, the alliance points out that from 2024, there is no longer any guarantee that refrigerant can be refilled in the event of a refrigerant leak, which endangers continued operation. Up to and including 2029, service would still be permitted with reprocessed or recycled refrigerant but this is already in limited supply today and by 2024 it will be in short supply.

Other businesses are said to be facing the same problem: a manufacturer of veterinary products who installed six split air conditioners with 130kW output in 2022, a slaughterhouse with a refrigeration system installed in 2022 and a district hospital in Lower Saxony that installed two chillers last year to cool a new building with nine operating rooms.

It is claimed that a similar scenario applies to the tens of thousands of bakers, butchers and restaurateurs who require refrigeration systems. According to there alliance, most of these systems use F-gases and many of these still have a long service life. In the event of a loss of refrigerant, they could not be put back into operation. It claims that that in these cases CO2 systems are many times more expensive and are neither economical nor energy-efficient to operate.

Effects will also be felt across industries, including Germany’s important automotive industry, where refrigeration is required for environmental and climatic simulation systems. Due to the temperature ranges and the safety requirements, the alliance says the use of flammable refrigerants are not possible and CO2 is not suitable for temperatures below -50°C.

It adds that if no refrigerant was available for service purposes in the event of leaks, tens of thousands of air conditioning systems in hotels, medical practices, office buildings, old people’s homes, private apartments, etc would become inoperable.

A large new Hamburg hotel, awarded a prize for its energy efficiency in 2018, would be unable to replace its F-gas-based heating and cooling system. Its replacement with a “natural” refrigerant system is technically unfeasible and in the event of a refrigerant loss from the system, the hotel would have to cease operations if the refrigerant required for maintenance was no longer available.

The document can be found and downloaded here.

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