the f-gas regulation the producers’ views on implementation

The F-gas Regulation The Producers’ views on

Implementation

Nick CampbellChairman, EFCTC

9 October 2006

Overview

• Consistency• Transparency• Reporting • Recycling• Labelling• Review

Topics to be covered:

In more detail

• Consistency• Transparency• Reporting • Recycling• Labelling• Review

Consistency

• Implementation in EU should be consistent across MS and with ODS regulation

• Proper enforcement mechanisms are required

• Harmonisation of licensing system

In more detail

• Consistency

• Transparency• Reporting • Recycling• Labelling• Review

Transparency

• Involvement of stakeholders when deciding on implementation measures

At national levelAt EU level

In more detail

• Consistency• Transparency

• Reporting • Recycling• Labelling• Review

Reporting

• Need clarification on who needs to report

• In many cases the final use cannot be determined (eg MAC or stationary)

• In many cases reclamation/destruction is performed by non producers

Reporting cannot provide accurate data on uses or emissions

In more detail

• Consistency• Transparency• Reporting

• Recycling• Labelling• Review

Recycling

– Definition of waste is a key issue– F-gases transferred between license

operators/producers and importers should be exempted– Used refrigerants to be purified and reused (Recycled

or Reclaimed) should qualify as products– Only contaminated refrigerants for Destruction should

be declared as waste – Highly bureaucratic and costly procedures for cross

border transfers (between EU Member States) are a major hurdle for efficient reclamation and environmentally optimized destruction

In more detail

• Consistency• Transparency• Reporting • Recycling

• Labelling• Review

Labelling

ADR sets out legal labelling requirements for containers– Proper shipping name, UN number– In addition ASHRAE designation (accepted

industry nomenclature)– EU Risk & Supply phrases for supply are not

required for bulk transport containers

• MSDS– Appropriate place to provide F-Gas

Regulatory and GWP information

In more detail

• Consistency• Transparency• Reporting • Recycling• Labelling

• Review

Review– Complex issue due to number of refrigerants on the

market (F-gases and alternatives) as well as numerous very different applications and operating conditions

– to compare equivalent systems including energy efficiency, safety, technological as well as economic aspects

– to use life cycle approach according to available standards in order to properly include energy related emissions

Focus on total system performance instead of GWP value

Thanks for listening!