National trade associations, environmental NGOs and European trade bodies have joined wider industry calls for tighter enforcement of the F-Gas legislation over fears about illegal trade.
Initial responses to a roadmap review of the flagship environmental legislation, which was undertaken by the European Commission earlier this year, has seen a range of trade organisations and pressure groups providing feedback on their concerns and potential areas for reform.
Asercom said it welcomed the introduction of the phase down mechanism introduced as part of the last F-Gas review. The organisation said that phasedown had over the last six years encouraged industry to transition to using alternative lower GWP refrigerants. Despite this support, Asercom said it was worried about the illegal trade of HFCS that it warned risked undermining European and global targets,
The Swedish Refrigeration and Heat Pump Association said in its own response that an estimated 25 per cent of HFCs currently in use within the EU were believed to hasvebeen illegally imported.
The organisation said, “Although the responsibility lies upon member states customs to enforce border protection it is clear that the F-gas regulation needs to be adjusted to help curb this unacceptable development.”
The association expressed particular concern about loopholes within the existing value chain that it claimed allowed companies trading in F-Gas to not have to provide comprehensive records if they did not provide installation, servicing, maintenance or repair work.
Record keeping should therefore be made obligatory at every step of the supply chain and market in future legislation so that records can be provided on request to stamp out illegal trade in Europe, the association added.
The Environmental Investigation Agency (EIA) NGO meanwhile said in its submission that it shared support for “significant improvements” to be made concerning compliance and enforcement of F-Gas rules.
Another recommendation of the EIA was for an acceleration of the existing phase down schedule to more drastically reduce quota targets for the level of HFCs on the market to be cut by 2027 and 2030.
The European FluoroCarbons Technical Committee (EFCTC) said that 18 responses to the roadmap identified illegal trade as a particular concern. Major concerns among these responses included what the EFCTC said was a supply chain “disconnect” that allowed organisations that only buy and sell F-Gas to avoid having to provide detailed sales records as required by other parts of the cooling sector.
Another major concern in the responses was the existing procedures to verify the legality of HFC quota shipments. The EFCTC also reiterated long- standing concerns among stakeholders and registration groups such as Refcom about the lack of controls for online sales.
The EFCTC added, “All of these issues have been raised over the past two years and measures to address them have been suggested as part of the stakeholder submissions.”
The responses to the roadmap closed last month ahead of the launch of a public consultation on the future of the F-Gas regulation that is open until late December.
Feedback from these consultation periods will then be used to amend and update existing F-Gas legislation in line with other vital EU and international policy and programmes such as the European green deal, as well as the Montreal Protocol.