The European Commission and Öko-Recherche recently presented the preliminary findings of the F-Gas review study. The study notably models the degree to which F-Gases could be substituted in RACHP equipment until 2050.
Eurovent considers the substitution scenarios unrealistic and has expressed skepticism about the modeling assumptions used by the study consultant.
Review of the study
The study notably foresees that hydrocarbons could be used in up to 90% of small heat pumps as of 2025, and in all large split air conditioners and VRFs as of 2030. Eurovent data on the current market penetration of non-fluorinated refrigerants show that this modeling is completely unrealistic, raising questions on the assumptions that underpin it. Review study would form the basis for potential amendments to the F-Gas Regulation
Moreover, the study consultant appears not to have considered the regulatory and standardization barriers which still significantly prevent flammable refrigerants from being used in heating and air conditioning equipment in many EU countries, unlike for the commercial refrigeration sector where these restrictions have already been eased.
These preliminary results are worrisome because the review study would form the basis for potential amendments to the F-Gas Regulation, which could result in unfeasible requirements.
Authority Comments
Francesco Scuderi, Deputy Secretary-General of Eurovent: “Facilitating the transition to lower-GWP refrigerants is one of Eurovent’s core ambitions and, in this context, we have always been big advocates of the F-Gas Regulation. With the review ongoing, we have been working closely together with European Commission and the study consultants to see how to further improve the current framework. That said, we are puzzled by the preliminary findings of the review study."
"Except for the commercial refrigeration sector, where non-fluorinated refrigerants already represent a preponderance of new products brought to the market, we see no realistic pathway from the current situation to the substitution milestones that were conjured up by the models. The study puts the global competitiveness of our industry on shaky grounds, which would be a big win for fossil fuels.”
Concerns
Eurovent has submitted its concerns to the European Commission and study consultants and is working with partner associations to mobilize a common industry response.
The European Commission is expected to publish its proposed amended F-Gas Regulation still in 2021, which would be followed by an F-Gas Consultation Forum meeting 6 weeks after.