Carbon Market Watch

For fair and effective climate protection.

Joint Letter to the European Commission on the need to ban of HFCs in the Shipping Sector

05 Sep 2012

PDF (LETTER)PDF (Response)

The European Commission should put in place measures to cut maritime hydrofluorocarbon (HFC) emissions as part of its wider strategy to reduce greenhouse gases from shipping. This is the ask a coalition of environmental NGOs have put forward in a letter to the EU’s Directorate General on Climate and Energy. HFCs are among the most damaging climate-change forcers and efforts to curb their emissions in the maritime sector cannot be further delayed.


Mr Philip Owen,
Head of Unit, Transport and Ozone

5 September 2012

Delivered via email

Dear Mr Owen,

In considering additional measures to reduce hydrofluorocarbon (HFC) emissions as part of its review of Regulation (EC) No 842/2006 on Certain Fluorinated Greenhouse Gases, the European Commission should include measures that cover HFC emissions from the maritime sector.

The 3 July 2012 letter to Commissioner Hedegaard from a coalition of environmental groups called for the new proposal to display the appropriate level of ambition by adopting subsector-specific “placing on the market” (POM) prohibitions for new HFC-based equipment. It also outlined the reasons why relying on economy-wide quantitative limits without subsector-specific POM prohibitions is inadequate. Subsector-specific POM prohibitions are the only way to ensure the elimination of HFCs where there are technically feasible, cost-effective, energy-efficient and safe alternatives available or expected to be available in the near future. We believe there is a strong case to include the maritime sector in such provisions.

There are only a very few ship types for which any barriers exist that could warrant an exclusion from a POM prohibition. Where the penetration rate is under 100%, there may be a need for clearly defined exceptions for discrete applications where alternatives are inappropriate but these exceptions need not be adopted until just before the POM prohibition is to take effect. This will allow the Commission plenty of time to engage in a thorough analysis of the subsector to ensure the exception is truly necessary.

We strongly urge the Commission to expand the application of containment (Article 3) and ensure the application of recovery measures (Article 4) to the maritime sector given the extremely high leakage rates (up to 200% i.e. the entire system requiring refilling twice within one year) from equipment in the current fleet of ships. The maritime sector was evidently excluded from the recovery provisions at time of adoption of the current regulation in 2006 in the belief that marine HFCs would be better addressed under an anticipated EU GHG maritime measure (Öko-Recherche, 2011). It is now clear that no such HFC provisions are being considered in the current work program and moreover any such legislation is unlikely to be forthcoming for some time. The IMO has also indicated to us that they have no plans to address HFCs at present. Importantly no technical barriers to applying containment and recovery to the maritime industry have been identified in the various studies. For these reasons, the containment measures in the current F-Gas Regulation should be extended to the maritime sector and the recovery measures should be enforced on the basis of port State control so that all ships entering EU ports are captured (see attached annex). These measures are now long overdue and we urge the Commission to address this omission in the forthcoming proposal.

The benefits of tackling HFC emissions in the maritime sector are many. The application of containment and recovery measures to equipment already on the market will bring a 40% reduction in maritime HFC emissions by 2020 compared to BAU. Further, this will cost just €22/tonne (BIPRO, 2008) which is well under the feasible reduction cost threshold and lower than the average cost of €41/tonne for other the HFC reduction measures (Öko-Recherche, 2011). Leakage rates could be substantially lowered even in rough seas by the maintenance of basic requirements for air conditioning/refrigeration equipment and the training of at least one crew member in basic techniques (Öko-Recherche, 2011 and Ecofys, 2007). In addition to their climate benefits, subsector-specific POM prohibitions will have a positive effect on jobs (CE Delft, 2009). Finally, it should be noted that POM prohibitions are less expensive than applying containment and recovery measures and thus should be the primary measure to reduce HFCs in the EU.

We urge the Commission to provide leadership on this important climate issue.

Yours sincerely,

  • Jos Dings, Director, Transport & Environment on behalf of the Clean Shipping Coalition
  • Eva Filzmoser, Programme Director CDM Watch
  • Clare Perry, Senior Campaigner, Environmental Investigation Agency


ANNEX: Part I: Technical provisions in relation to the maritime sector (in pdf)