The European Partnership for Energy and the Environment (EPEE), representing the refrigeration, air-conditioning and heat pump manufacturing industry in Europe, requested an exemption for F-gases and fluoropolymers in its reply to the universal PFAS restriction proposal.
“We requested these time-unlimited derogations to avoid a significant loss of efficiency for key products in heating and cooling,” – said Russell Patten, Director General of EPEE. “Further restrictions on the use of F-gases and fluoropolymers would drastically slow the deployment of heat pumps, on which the EU depends to reach independence from Russian fossil fuels and to meet the climate target by 2030.”
EPEE stated in its reply [f-gas/fluoropolymers ] that a broad ranging PFAS ban would hinder the ongoing and future research and development of even safer and more energy-efficient devices. F-gas refrigerants are essential to the optimal performance of equipment and products that contribute to the decarbonisation of the energy system and buildings, and provide efficient heating and cooling solutions for domestic, industrial, commercial, and medicinal applications, as well as many others.
Currently there are no viable alternatives to fluoropolymers that could fulfil the same criteria with the same level of efficiency and safety. Fluoropolymers stand up to the unique and harsh operating conditions of RACHP equipment, and are used for their sealing capacity, resistance to pressure and temperature, persistence, electrical properties and low friction. Fluoropolymers offer the safest way to transport refrigerants and avoid leakages of toxic and flammable gases. A ban on their use would mean returning to less efficient, less safe, older alternatives, and would impact many European industries beyond the RACHP sector itself.
“RACHP products control the temperature and air quality of schools and hospitals, transport medicine and food, and keep people warm all through winter – and we deliver these services extremely efficiently and safely.”
Some F-gases degrade to trifluoroacetic acid (TFA), which is known to be a persistent substance according to the proposed PFAS restriction criteria. However, eminent scientific experts in the latest UNEP report found that the impact of TFA is limited and “currently judged not to pose a risk to human health or to the environment.”
EPEE also raised concerns about the risk of equipment obsolescence, as many types of RACHP equipment can be used from 12 to up to 30 years in certain applications. As such the restriction proposal could impact end-of-life practices, recycling and reclamation of gases, exports from Europe, maintenance and refilling of existing equipment.
