Industrial groups denounce a study on F gases


BELGIUM: Leading associations across Europe, the UK and Japan have expressed “serious concerns” over the content of the recent European Commission study on F-gases.

The study presented at DG Clima’s stakeholder workshop on May 6 has already been criticized for its claims about the extent to which “natural” refrigerants could replace HFCs in RACHP equipment.

The 15 associations, which include the Japan Refrigeration and Air Conditioning Industry Association and the Japan Business Council in Europe, oppose the modeling approach taken by the consultants, Öko-Research, and believe that it does not provide the technical justification to support the policy options proposal.

Manufacturers association Eurovent has already called the substitution scenarios unrealistic and expressed skepticism about the modeling assumptions used. In particular, Eurovent takes issue with a study scenario that suggests hydrocarbon refrigerants could be used in up to 90% of small heat pumps from 2025, and in all large split and VRF air conditioners by 2030.

the Cooling station, although not invited to participate in the workshop, previously reported that the study included proposals to ban the use of R410A in new stationary air conditioners and heat pumps. Now the industrial groups have reacted.

In a scathing statement signed by associations, including EPEE, AREA, EHPA, ASERCOM and the British manufacturer group FETA, accuses the study of lacking in detail in the modeling, of having an unrealistic approach to certain refrigerants and technologies , lacking recognition of the significant reduction potential of heat pumps and a disregard for the competitiveness of European manufacturers.

Lack of definition

He criticizes the detail of the substitution scenarios presented in the study. As an example, it indicates that heat pumps and air conditioners are not clearly defined and that no specific reference to condensing units in commercial refrigeration is lacking despite their specification in eco-design legislation.

The groups argue that refrigerant choice, life assumptions and other factors vary widely across application segments and that insufficient segmentation leads to premature and potentially misleading and unfounded conclusions.

It also argues that all types of low GWP refrigerants are needed to facilitate decarbonization in all sectors and challenges the modeling assumptions.

The modeling of the study’s “substitution scenario” is particularly criticized

In particular, the study claims that 80% of centrifugal chillers could use “natural” refrigerants (CO2, hydrocarbons and ammonia) by 2025, 90% of small heat pumps using hydrocarbons by 2025, and all large 100% air conditioners and VRFs on hydrocarbons by 2030 are described as “unrealistic” – especially since these products are not yet available on the market.

Study compilers are also accused of ignoring crucial aspects of safety, energy efficiency, affordability, as well as existing safety standards and building codes that limit the use of flammable refrigerants. and toxic in all air conditioning and heat pump applications.

“Energy efficiency should never be compromised, as the bulk of emissions are related to energy use (indirect emissions) rather than refrigerants (direct emissions),” the statement said.

Ignored heat pumps

The group is also concerned that failure to take into account the contribution of heat pumps and air conditioners in terms of reducing energy-related CO2 emissions could jeopardize the benefits of heat pumps over the household. decarbonisation path with restrictive obligations related to refrigerants.

Without taking a breath, industrial groups criticize the study for being based on “very incomplete data” which does not take into account aspects such as reduction of leaks, recovery, recycling and recovery. It is also said to ignore important considerations regarding safety standards and / or EU directives / regulations – like the General Product Safety Directive, the Low Voltage Directive, the ATEX Workplace Directive. , the Machinery Directive, the Pressure Equipment Directive – and local and regional building codes or ecodesign measures. .

Disadvantaged manufacturers

It is feared that the adoption of such measures could harm the competitiveness of European manufacturers in foreign markets.

“For the EU, in order to be a technological leader at world level and to avoid a shift in production outside the EU, a level playing field and fair and equal treatment with manufacturers in outside the EU are a top priority, ”the statement said. “However, as long as the refrigerants exported in pre-charged equipment are not factored into the modeling and exempt from quota requirements in the EU, this cannot be the case.”

It also argues that the industry has developed new product platforms, based on the use of flammable refrigerants, and relies on the predictability of phasing out existing F-Gas.

“These efforts and the fact that these platforms will potentially not have time to mature in the market, have not been considered in terms of reduction costs, etc. It seems that the huge effort undertaken by the industry to provide compliant products was not taken into account at all, being considered “negligible”. “

The declaration is signed by ADC3R (the association of suppliers and recoverers of French refrigerants), AGORIA (formerly Fabrimetal, the Belgian association of metallurgical companies), AFCE (the French alliance for the cold climate, APPLIA (the European Association of Home Appliances), AREA (the European Association of Contractors), ASERCOM (Association of European Manufacturers of Refrigeration Components), EHI (representing the European heating industry), EHPA (European Association of Heat Pumps), EPEE (European Partnership for Energy and the Environment), Eurovent (Association for Climate (HVAC), Process Cooling, and Food Cold Chain Technologies), FETA (Federation of Environmental Trade Associations), FGK (the association representing German air conditioning and ventilation industry), JBCE (Japanese Business Council in Europe) and JRAIA (Japanese Association of the refrigeration and air conditioning industry).

Related stories:

Adoption of HC refrigerant in European air conditioners is “unrealistic”May 26, 2021
BELGIUM: European manufacturer group Eurovent has dismissed as “totally unrealistic” claims by the European Commission that hydrocarbon refrigerants could replace HFCs in air conditioning systems by 2030. Read more …

F-gas magazine plans to ban R410A
BELGIUM: A ban on the use of R410A in new stationary air conditioners and heat pumps is being considered as part of the revision of the European regulation on F gases (517/2014). Read more…


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