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German industry presses for PFAS exemptions

GERMANY: Leading German HVACR associations have warned against a blanket PFAS ban and urged that the economic impacts of a ban be considered alongside the environmental ones.

In a letter to members of the Bundestag and relevant ministries, the associations explain the potential consequences of a blanket PFAS ban on the refrigeration, air conditioning, and heat pump technology sectors, key areas of energy supply, the economy, and the transition to sustainable heating.

This initiative is prompted by the ongoing PFAS restriction process led by the European Chemicals Agency. While the proposal currently under discussion envisages far-reaching restrictions on PFAS substances, a final decision has not yet been reached.

The associations insist that they explicitly support the goal of reducing harmful PFAS releases into the environment, but point out that fluorinated refrigerants are already strictly regulated under the EU F-gas regulation. They also believe that any future PFAS regulation should also include provisions for exemptions where no technically

suitable alternatives are available, where safety requirements preclude the use of alternative refrigerants, or where there is a risk of disproportionate economic consequences.

The signatories to the letter include the BTGA (Federal Industrial Association for Technical Building Services), the BVKMW (Federal Association of the Refrigerant Industry), the FGK (Trade Association for Building Climate Systems), the Manufacturers’ Association for Air Handling Units, the TGA Representative Office Berlin, the VDKF (Association of German Refrigeration and Air Conditioning Specialist Companies), and the VDMA General Air Technology Association.

Related stories:

EU study recommends excluding refrigerants from PFAS restrictions – 20 December 2025
EUROPE: The European parliament’s Policy Department for Transformation, Innovation and Health has recommended that F-gases should be excluded from future PFAS restrictions, and focus regulatory controls through the existing F-gas regulation. Read more…

Group calls for phase out of PFAS in HVACR – 26 February 2025
BELGIUM: A new group promoting the adoption of “natural” refrigerants has petitioned the European Chemicals Agency (ECHA) to restrict the use of PFAS within the European HVACR sector. Read more…

PFAS impact discussions March on – 18 February 2025
FINLAND: The dates and agendas for the evaluations of the impact of fluorinated gases under proposed new European PFAS restrictions have now been published by the European Chemicals Agency (ECHA). Read more…

ECHA to consider impact of PFAS ban on seals – 24 November 2024
EUROPE: The European Chemicals Agency (ECHA) is to consider the impact of PFAS bans on the use of fluoropolymers in the manufacture of vital RACHP components like seals and gaskets. Read more…

PFAS consultation receives over 5,600 comments – 26 September 2023
FINLAND: The European proposals to restrict the use of PFAS chemicals have received more than 5,600 comments from more than 4,400 organisations, companies and individuals. Read more…

EPEE seeks PFAS exemption for F-gases – 25 September 2023
BELGIUM: The European Partnership for Energy and the Environment (EPEE) has requested an exemption for F-gases and fluoropolymers in any forthcoming PFAS restrictions. Read more…

PFAS proposals are “disproportionate” – 2 September 2023
BELGIUM: An association representing 770,000 European technology companies has called the proposed “blanket restriction” of all PFAS, regardless of their toxicity and risk profile, disproportionate. Read more…

PFAS exemptions required for critical applications – 10 July 2023
GERMANY: A leading German research body has said that, without exemptions, any future PFAS regulation could jeopardise the safe and effective uninterrupted operation of refrigeration and heat pump systems. Read more…

PFAS ban would render systems unsafe – 25 May 2023
GERMANY: A leading European refrigeration research council claims that the safe, efficient and trouble-free operation of RACHP systems is not possible without the use of PFAS-containing materials. Read more…

PFAS ban affects most refrigerant blends – 12 February 2023
EUROPE: The banning of just five refrigerants under the new PFAS regulation proposals would lead to the banning of virtually all the current lower GWP HFC/HFO alternative refrigerant blends. Read more…

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