We are writing to express our grave concern that the Commission may eliminate or weaken the proposed bans on the use of HFCs in refrigeration from its proposal to revise the F-Gas Regulation. It is our view that any weakening or omission would seriously undermine EU ambition and the overall regulatory framework. It would also go against the legislative mandate from Parliament and the Council to the Commission to propose additional bans where technically feasible, cost-effective and energy-efficient alternatives are available.
The arguments for bans in refrigeration are well-known, and are supported by an unparalleled body of technical evidence234 and an abundance of real-world experiences.5 They are essential components of a package of policies to reduce HFC emissions in this sector, which comprises the highest proportion of HFC emissions, and serve as key elements to any phase-down schedule. A phase-down schedule without bans will needlessly lock in HFC infrastructure and prolong reliance on costly containment and recovery measures for decades. Given the energy efficiency gains from transitioning away from HFC-based equipment in refrigeration, bans will also achieve much-needed indirect GHG reductions by reducing the demand for electricity. Our strong view is that the inclusion of bans in refrigeration is the only way forward. While a phase-down is a valuable part of an overall package, it is not in itself sufficient, and gives ample opportunity for non-compliance and overallocation of quotas while providing little pressure on laggard sectors.
Outside commercial interests should not be allowed to dictate EU climate policy. The Commission must stand strong against the self-interest of multinationals that simply seek to delay meaningful action in order to boost profits at the expense of the climate system and smaller European companies making alternatives that have much to gain by early EU action. At this critical stage in the proceedings we look to you to provide leadership and a positive outcome for the climate.