Further to the F-gas stakeholder workshop that took place early May, AREA has submitted comments both individually and as part of a large industry coalition.
AREA joined 14 other European and national trade associations representing a large spectrum of the refrigeration, air conditioning and heat pump industry. Together, the industries flagged insufficient technical justifications in support of the policy options currently evaluated as part of the impact assessment in preparation for the upcoming revision of the F-gas Regulation.
In a joint statement, the co-signatories noted in particular:
- A significant lack of granularity for the subsectors (notably heat pumps) in the modelling
- A nonrealistic approach/assumptions to certain refrigerants and technologies, that could notably prejudice energy efficiency
- A lack of recognition of the significant abatement potential of heat pumps
- A general lack of data
- A disregard to competitiveness of the European industry
In an individual submission, AREA provided further explanations and justifications on the costs of extending the F-gas certification scheme to alternative refrigerants and stressed the importance of maintaining refrigerant's choice in support of energy efficiency.
Both sets of comments can be downloaded below.
AREA comments Fgas review 210524 FINAL.pdf
Joint-F-Gas Industry Comments on the Review of the F-Gas Reg. - 25 May 2021 - Final.pdf