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Published byMichael Henry Modified over 6 years ago
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The F-gas Regulation The Producers’ views on Implementation
Nick Campbell Chairman, EFCTC 9 October 2006
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Overview Topics to be covered: Consistency Transparency Reporting
Recycling Labelling Review
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In more detail Consistency Transparency Reporting Recycling Labelling
Review
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Consistency Implementation in EU should be consistent across MS and with ODS regulation Proper enforcement mechanisms are required Harmonisation of licensing system .
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In more detail Transparency Consistency Reporting Recycling Labelling
Review
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Transparency Involvement of stakeholders when deciding on implementation measures At national level At EU level .
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In more detail Reporting Consistency Transparency Recycling Labelling
Review
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Reporting cannot provide accurate data on uses or emissions
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 Recycling Consistency Transparency Reporting 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 Labelling Consistency Transparency Reporting Recycling
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
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In more detail Review Consistency Transparency Reporting Recycling
Labelling Review
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Focus on total system performance instead of GWP value
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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