The Fgas Regulation The Producers views on Implementation

1
The F-gas Regulation The Producers views on
Implementation

• Nick Campbell
• Chairman, EFCTC
• 9 October 2006

2
Overview
Topics to be covered

• Consistency
• Transparency
• Reporting
• Recycling
• Labelling
• Review

3
In more detail

• Consistency
• Transparency
• Reporting
• Recycling
• Labelling
• Review

4
Consistency

• Implementation in EU should be consistent across
  MS and with ODS regulation
• Proper enforcement mechanisms are required
• Harmonisation of licensing system

5
In more detail

• Consistency
• Transparency
• Reporting
• Recycling
• Labelling
• Review

6
Transparency

• Involvement of stakeholders when deciding on
  implementation measures
• At national level
• At EU level

7
In more detail

• Consistency
• Transparency
• Reporting
• Recycling
• Labelling
• Review

8
Reporting

• Need clarification on who needs to report
• In many cases the final use cannot be determined
  (eg MAC or stationary)
• In many cases reclamation/destruction is
  performed by non producers
• Reporting cannot provide accurate data on uses or
  emissions

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In more detail

• Consistency
• Transparency
• Reporting
• Recycling
• Labelling
• Review

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Recycling

• Definition of waste is a key issue
• F-gases transferred between license
  operators/producers and importers should be
  exempted
• Used refrigerants to be purified and reused
  (Recycled or Reclaimed) should qualify as
  products
• Only contaminated refrigerants for Destruction
  should be declared as waste
• Highly bureaucratic and costly procedures for
  cross border transfers (between EU Member States)
  are a major hurdle for efficient reclamation and
  environmentally optimized destruction

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In more detail

• Consistency
• Transparency
• Reporting
• Recycling
• Labelling
• Review

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Labelling

• ADR sets out legal labelling requirements for
  containers
• Proper shipping name, UN number
• In addition ASHRAE designation (accepted industry
  nomenclature)
• EU Risk Supply phrases for supply are not
  required for bulk transport containers
• MSDS
• Appropriate place to provide F-Gas Regulatory and
  GWP information

13
In more detail

• Consistency
• Transparency
• Reporting
• Recycling
• Labelling
• Review

14
Review

• Complex issue due to number of refrigerants on
  the market (F-gases and alternatives) as well as
  numerous very different applications and
  operating conditions
• to compare equivalent systems including energy
  efficiency, safety, technological as well as
  economic aspects
• to use life cycle approach according to available
  standards in order to properly include energy
  related emissions
• Focus on total system performance instead of GWP
  value

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Thanks for listening!