F-Gas 2022 0099 COD 4 column table RACHP and foam industry analysis

The RACHP and foams industry Alliance which already shared in the past common positions has assessed the three proposals of the F-gas Regulation Revision. The assessment of the industry is made in the fourth column of this document where relevant. Beforehand, the industry representatives would like to highlight three preliminary general comments to this analysis.

1. To be aligned with the Montreal Protocol, we suggest replacing the term ‘natural refrigerants’, when it is used in the proposals, by ‘non fluorinated refrigerants’.
2. Where the text of the proposals set provisions concerning Substances from Annex I, it should also be accompanied by “and mixtures containing any of those substances”.
3. Parliament proposal phases out all F-gases in majority of RACHP systems and insulation foams. This is not achievable in our industry.