The European Commission (EC) is facing mounting criticism from industry groups and NGOs for its recently proposed revisions to the EU F-gas Regulation – but for vastly different reasons.

Since the EU F-gas Regulation proposal was released on April 5, many NGOs have warned that it risks undermining Europe’s efforts to meet important climate goals due to the continued use of harmful HFCs, which currently account for 2.5% of Europe’s total greenhouse gas emissions. Meanwhile, HVAC&R trade associations have voiced concerns that the proposed changes are too restrictive and threaten the competitiveness of European manufacturers, as well as EU decarbonization targets and heat pump deployment.

The latest version of the EU F-gas Regulation, which will accelerate the HFC phase-down from 2024 onwards, aims to reduce HFC use by 97.6% by 2048, based on 2015 levels. Previous iterations of the regulation had an 80% reduction target over the same period. This revision will fully align the EU’s HFC phase-down with the Kigali Amendment to the Montreal Protocol. It will also open doors to further adoption of natural refrigerants such as CO2 (R744), ammonia/NH3 (R717) and hydrocarbons.

“For decades the European Union has had the world’s most ambitious policy on fluorinated gases and Ozone Depleting Substances,” said Frans Timmermans, the EC’s Executive Vice-President for the European Green Deal, in a statement. “While existing laws have been successful, science urges us to go further and faster now.”

A faster transition to natural refrigerants

Despite the commitment to a faster HFC phase down in the EU F-gas Regulation, NGOs have criticized the proposal for lagging behind market evolution. While the revision does abolish certain exemptions included in existing regulations, the ongoing permitted use of HFCs is said to “fall short.”

“We are surprised to see that climate-harmful refrigerants will still be allowed in heat pumps and refrigeration in this revision, especially considering how much the market has evolved towards natural refrigerants,” said Davide Sabbadin, Senior Policy Officer for Climate at the European Environmental Bureau (EEB). “Fluorinated gas should be the exception, not the rule,” he added.

According to a statement released by EEB last week, “more ambition is needed to keep the EU in the lead in this sector: the revision should have banned all [HFCs] for all applications, with the only exception of those sectors where natural refrigerants are not yet fully available.”

This sentiment has been echoed by Clare Perry, Climate Campaign Leader at the London-based Environmental Investigation Agency (EIA), who fears that the inclusion of HFCs in the revised EU F-gas Regulation “will result in yet another lost decade of climate change action at a time when the world can least afford it.”

However, for industry bodies such as APPLiA (Home Appliance Europe), there is a deep concern that the accelerated rate of the HFC phase down and new equipment bans will negatively impact the innovation and competitiveness of European manufacturers.

Heat pump dispute

Heat pumps, a replacement for fossil-fuel-based appliances, are at the center of much of the disagreement over the F-gas proposal. This is especially so in light of the EC’s plan (dubbed RePowerEU) to roll out 30 million heat pumps by 2030 to reduce reliance on Russian gas.

There is concern from NGOs that doing so without ensuring they operate on natural refrigerants will lock in polluting technologies for decades to come.

“It is critical that the revised [EU] F-Gas Regulation includes robust measures to ensure these heat pumps do not lock in the use of HFC refrigerants, effectively pitting one piece of climate legislation against another,” said the EIA’s Perry.

“Climate-friendly natural refrigerants can cover a significant proportion of the heat pump market, so a double climate win is possible – if the [European] Parliament and Council [of the EU] have the vision to make it happen,” Perry added.

“It is critical that the revised F-Gas Regulation includes robust measures to ensure these heat pumps do not lock in the use of HFC refrigerants, effectively pitting one piece of climate legislation against another.”

Clare Perry, EIA

In opposition, trade associations are concerned that the newly proposed EU F-gas Regulation will slow down Europe’s adoption of heat pump technologies, and therefore its transition towards a cleaner economy.

For example, the European Heat Pump Association (EHPA) stated that the lack of “sufficient” HFC alternatives and trained installers “will massively ‘decelerate’ the deployment of heat pumps and other heating and cooling solutions required to achieve EU’s 2030 climate and energy, as well as geopolitical goals.”

Meanwhile, the European FluoroCarbons Technical Committee (EFCTC), while applauding the proposal’s provisions to improve phase-down enforcement, has strongly reiterated concern that “the earlier and more severe proposed phase-down could undermine the goals of the RePowerEU Action Plan. The [proposed revisions] could potentially slow down the much-needed adoption of heat pumps in Europe as well as other energy efficient technologies.”

Folker Franz, Director General of the European Partnership for Energy and the Environment (EPEE), noted that the current EU F-gas Regulation quota cuts HFC use by 88% by 2030. “Our modelling shows that this will be just enough to install the needed 50 million new heat pumps by then,” he said. “The EU would harm its own cause by further cutting the quota.”

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