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 Transparency Consistency Reporting Recycling Labelling
Review

6. Transparency
Involvement of stakeholders when deciding on implementation measures
At national level
At EU level .

7. In more detail Reporting Consistency Transparency Recycling Labelling
Review

8. 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

9. In more detail Recycling Consistency Transparency Reporting Labelling
Review

10. 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

11. In more detail Labelling Consistency Transparency Reporting Recycling
Review

12. 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 Review Consistency Transparency Reporting Recycling
Labelling
Review

14. 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

15. Thanks for listening!