Fluorinated gases regulation

EFA welcomes the determination of the European Commission to reduce greenhouse emissions generated in the European Union. Climate change negatively affects human health, and more especially the health of vulnerable people such as allergy, asthma and COPD patients. Asthma affects 30 million children and adults under 45 years of age in Europe and it is estimated that COPD affects 10% of the European population.

Siemens AG welcomes the opportunity to provide its feedback and recommendations on the European Commission’s proposal, released April 5th., to revise the Fluorinated Greenhouse Gases (F-gas) regulation to prevent further F-gas emissions and foster the uptake of climate and environmentally friendly solutions.

As a Head of an Anaesthesia and Intensive Care department I am shocked about the plan, that the inhalation anaesthetic gases are on the same page than other fluorinated gases. I am sure that the most people do not have a clue about these gases (anaesthetic gases), but if these gases going to be removed from the daily anaesthesia routine, it is going to be a disaster.

The European Phenolic Foam Association (EPFA) would like to submit the following comments on the proposed Regulation on Fluorinated Greenhouse Gases. They refer specifically to Article 8 of the draft and notably subparagraphs 4 & 5 which relate to the management of insulation foam products at renovation, refurbishment or demolition.

Reducing F-Gas emissions from life-saving inhaled medicines in a responsible way AstraZeneca supports the goals of the proposed EU F-Gas Regulation, recognising the positive impact it could have on climate and health. Yet, it is critical that the draft Regulation evolves to avoid the risk of limiting life-saving inhaled medicines used by people with asthma and chronic obstructive pulmonary disease (COPD).

The Italian Association of Pharmaceutical Industry (Farmindustria) supports the EU’s goal of net carbon neutrality. We would call on EU legislators to devise the phase-down of medical F-gases in the EU in a way that maintains access to critical medicines for patients, allows for adequate time for a truly sustainable transition to a new generation of propellants for metered-dose inhalers (MDIs), and safeguards…

The Deutsche Atemwegsliga e.V. (German Respiratory League) was founded in 1979 Some of its obligations are • raising awareness in public and patients for all lung diseases • continuous medical education for physicians about new developments in medicine and health care • designing and supporting programs for screening, prevention and early diagnosis of all respiratory diseases • support of quality management in…

I am Head of Department of Anesthesilogy and Intensive Therapy , Medical University of Lodz , Poland, member of board of European Society for Peri-Operative Care of Obese Patient. I am working in bussy bariatric center for more than 20 years. I am scientist and clinician. I confirm from my clinical and research practice that desfluran is prefered anesthetic in patients with obesity.

Founded in 2013, ADC3R members are key players in the distribution, collecting and treatment of refrigerants in Europe. We fully support the F-Gas review as well as other related EU climate change and decarbonisation initiatives, such as Green Deal, Fit for 55 and most recently REpowerEU.

The Dehon Group welcomes many of the provisions of the European Commission's proposal , in particular the extension on requirements on leak checks, containment, reporting and certification and training to all refrigerants (fluorinated or not), F-Gas end-of-life management by promoting recovery, reclamation, strengthening traceability of movements and fighting illegal trade.

UFE thanks the Commission for the opportunity to share its analysis on the proposed revised Regulation. Please find attached our detailed feedback. 1. Placing on the market prohibition * For voltage level 12-24kV, a transition time up to 1st January 2028 would be more appropriate, considering the existing market deployment. 2.

Dear Madam, dear Sir, Please find our contribution attached. Our general messages: - EHI is committed to reduce CO2 emissions from heating appliances, including from fluorinated gases used in our heat pumps. - The hydrofluorocarbons (HFCs) phase down needs to consider the projected growth in REPowerEU of the heat pump market and the need for servicing and maintenance.

Honeywell products contribute meaningfully to the safe and efficient functioning of many modern applications such as chillers, heat pumps and air conditioning systems for residential, industrial and commercial buildings as well as cars and trucks.

ABB welcomes the opportunity to provide its feedback and recommendations for the European Commission's proposal to review the Regulation on fluorinated greenhouse gases (F-Gas regulation). We strongly support the effort to substantially reduce potent and harmful greenhouse gas emissions by two-thirds by 2030 compared to 2014 levels.

E.ON welcomes the publication of the proposal on fluorinated greenhouse gases by the European commission aiming to complement the current version of the regulation. Distribution System Operators (DSOs) of E.ON operate critical infrastructure in order to distribute power safely, efficiently and reliably to customers. Reliable, tested and proved switchgear are critical to a secure power system operation.

CIDE COMMENTS ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON FLUORINATED GREENHOUSE GASES, AMENDING DIRECTIVE (EU) 2019/1937 AND REPEALING REGULATION (EU) NO. 517/2014 Article 11 of the Proposal for a Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 (hereinafter the…

SPECTARIS, the German Industry Association for Optics, Photonics, Analytical and Medical Technology, welcomes the possibility to give feedback. SPECTARIS supports all measures that effectively reduce overall greenhouse gas emissions to meet the objectives of the Paris Agreement on Climate Change. However, the use of F-Gases is essential to some medical as well as analytical and laboratory technolgy and equipment.

Members of the Forum of International Respiratory Societies (FIRS)* - specifically the American College of Chest Physicians, American Thoracic Society, Asian Pacific Society of Respirology, Asociación Latino Americana De Tórax, Global Initiative for Asthma, Global Initiative for Chronic Obstructive Lung Disease, International Union Against Tuberculosis and Lung Diseases, and Pan African Thoracic Society - appeal to…

PU Europe is the European Federation of manufacturers of thermal insulation products, from construction products manufactured in factories to in-situ formed PU foam, based in the European Union and the UK. Our members provide long lasting products and solutions (over 50 years for most of them) that are essential to cut energy use and therefore fight climate change.

Official Communiqué of Sedar (Sociedad Española de Anaesesiology, Reanimación y Terapia del Dolor) regarding the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014, affecting the use of desflurane (approved by the Executive Committee and Management Board on 21 June 2022) * * please…

Filed in Spanish · English published by the European Commission

Deutsche Umwelthilfe e.V. calls for more ambition in the current proposal of the EU F-Gas regulation. Please find our detailed comments in the document attached. We would like to emphasize that this is the crucial moment to set the course for a genuine sustainable transformation instead of, again, replacing one problem with the next: First, ozone-depleting chlorofluorocarbons and hydrochlorofluorocarbons were…

The aim of limiting the global temperature rise is at the heart of climate change mitigation and can only be achieved by reducing greenhouse gas emissions and ultimately becoming carbon neutral. This requires a fundamental transformation of our energy system. The key to a reliable, affordable and sustainable integrated energy system is energy infrastructure.

Solvay is a world leader in Fluorine Chemistry and maintains this position through innovation, utilizing its distinct knowledge for highend applications. Based on its state-of-the art manufacturing technologies Solvay offers a wide product portfolio of special fluorinated gases and liquids.

FULL CONTRIBUTION IN DOCUMENT ATTACHED This position paper presents: - EHPA's concern about an EC F-gas Regulation proposal that risks jeopardising the EU’s overall ambition to achieve its decarbonisation and energy security goals. o The phase-down trajectory suggested in the F-gas Regulation proposal is incompatible with an accelerated massive deployment of heat pumps (REPowerEU targets).

As a global umbrella organization in respiratory and immunology, we represent the more than 800 Million people living with asthma, COPD & related conditions. We have 74 member organizations globally with 36 organizations from 22 European countries included. The attached letter expresses our concerns regarding the F-gas proposed EU Rules & its potential impact on access to life-saving inhalers.

A gas-insulated switchgear (GIS) is a high-voltage facility consisting of a circuit breaker to interrupt fault current on a transmission line to prevent it from affecting other power equipment, a disconnector to switch the transmission system, a lightning arrester, and an instrument transformer.

The Dehon Group welcomes many of the provisions of the European Commission's proposal , in particular the extension on requirements on leak checks, containment, reporting and certification and training to all refrigerants (fluorinated or not), F-Gas end-of-life management by promoting recovery, reclamation, strengthening traceability of movements and fighting illegal trade.

GSK welcomes the opportunity to comment on the revised EU F-gas proposal. For over 50 years GSK has led the field in respiratory research, developing medicines that have transformed treatment and helped people across the world to breathe more easily. We have ambitious sustainability goals including a net zero impact on climate and net positive impact on nature by 2030.

ASERCOM is not supporting the proposed phase down. We think the phase down is a phase out and not phase down. The proposed phase down is unconsistent due to : Only quota for maintenance and service [EPEE HFC model] The number of units in general are increasing : Datacenters/Heat pumps/Air con. High uncertainty based on regulations which are not synchronised.

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry supports the European Union’s climate and energy objectives, including controlling and reducing CO2eq emissions through the implementation of the revised F-gas Regulation. Their members would like to present the following feedbacks and remarks in the attached document:

The European Network of Transmission System Operators for Electricity (ENTSO-E) welcomes the opportunity to provide feedback on the recast draft published by the European Commission (EC) on 5 April 2022. ENTSO-E is the association representing 39 European transmission system operators (TSOs) Members from 35 countries and would like to bring to the attention of the EC and co-legislators the following three topics of…

The F-Gas Regulation is one of the most successful measures to directly reduce greenhouse gas emissions. Danfoss welcomes the opportunity to further finetune it, building on the success of the past years and adapting it to changing circumstances and requirements.

AREA represents the European refrigeration, air conditioning and heat pump (RACHP) contractors. RACHP contractors are the essential link between end users and manufacturers. They design, install and maintain RACHP equipment using every available solution with complete neutrality towards equipment and refrigerants, in the sole aim of ensuring the highest level of reliability, energy efficiency and cost-effectiveness.

SEMI members recognise that the existing F-Gas Regulation has been very successful in reducing the damaging effect of high GWP gases entering the atmosphere. The Regulation strikes a careful balance between encouraging industry to switch to lower GWP gases (where technically possible) and the potential negative impact to EU industry competitiveness on the world market.

CEDEC members are evidently committed to reduce GHG emissions linked to their activities, including those regarding fluorinated gases. The availability of suitable and reliable alternatives to SF6 switchgear for use in the distribution networks is evidently a prerequisite to gradually shift away from SF6-use.

ERS submission to F-gases revision The European Respiratory Society welcomes and supports the proposed revision of the F-gases regulation by the European Commission. The scale of climate change impact on the planetary and human health, that is now, irreversible necessitates such ambition. The World Health Organization (WHO) has warned that climate change is the biggest global threat to humanity in the 21st century.

JBCE represents the interests of about 90 multinational companies of Japanese parentage active in Europe. Our members operate across a wide range of sectors, and include companies that are active in developing, producing and marketing refrigeration, air conditioning and heat pump (RACHP) equipment.

Siemens Energy, as one of the leading manufacturers of high-voltage (HV) switchgear, welcomes the opportunity to give feedback on the review of the Fluorinated Greenhouse Gas Regulation (F-Gas Regulation) regarding F-gases in switchgear. Siemens Energy supports the European Commission’s proposal for a regulatory framework that enables an F-gas free power grid.

Koura is a global producer and supplier of F-gases including having a significant presence in the global supply of F-gases for use in MDIs. Koura supports the purpose of the F-gas Regulation to transition to lower GWP solutions. Koura supports the strengthening of measures to tackle the threat of illegal trade of HFCs to the successful accomplishment of the Europe’s climate objectives.

In principle, we welcome the tightening of the F-gas Regulation, as many environmentally friendly technologies are not possible without them and we see further positive developments in the market towards natural refrigerants. In our view, the main problem for the effectiveness of illegal trade is that it can only be contained through bans or stricter controls and a task force.

Filed in German · English published by the European Commission

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration, air conditioning and heat pump (RACHP) equipment in Japan would like to thank the Commission for the effort for revision of the EU F-Gas Regulation and the opportunity to provide our comments. In this paper, we would like to comment on the proposed revision of the Regulation.

Ladies and gentlemen I hereby present the opinion (in English) of a member of the Polish Employers on the Regulation. F-gases. It is important to take into account the situation of several industries, i.a. pharmaceuticals, to ensure the security of supply of medicines.

Filed in Polish · English published by the European Commission

EdEn welcomes the objective set by the Commission to reduce the GHG emissions associated with the use of HFCs. It is however essential that the revision of F Gas Regulation 517/2014 does not hinder the deployment of heat pumps, which is a key aspect of the Commission’s strategy to decarbonise the EU building sector.

Boehringer Ingelheim (BI) welcomes the European Commission’s ambition to reduce the use of substances with Global Warming Potential (GWP) and to comply with recent international obligations on HFCs (Montreal Protocol).

SYNEG (Syndicat National de l'Équipement des Grandes Cuisines) is an industrial union created in 1973. It regroups and represents French manufacturers of professional kitchen and laundry equipment. SYNEG welcomes the alignment of the F-gas Regulation with the European Green Deal, European Climate Law, obligations on HFCs under the Montreal Protocol.

Dear Policy Officer at the European Commission, dear stakeholders, Please find herewith attached the feedback from the Clean Cooling Coalition on the proposed amendments to the EU F-Gas Regulation. The Clean Cooling Coalition (CCC) is coalition of progressive European companies from the heating, ventilation, air-conditioning and refrigeration (HVAC&R) industry.

Assocold feedback on the EC proposal for the F-Gas Regulation review Assocold welcomes several key measures introduced in the EC proposal and would like to submit some additional suggestions to raise the ambition in the light of the market ready technologies currently adopted in the European market.

Feedback of GHC Gerling, Holz & Co. Handels GmbH on Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on HFCs, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 GHC Gerling, Holz & Co. Handels GmbH (GHC) is an importer and distributer of chemical gases, including Hydrofluorocarbons (HFCs) and their alternatives.

Our association RESPIRLIBRE (patients speaking different languages) would like to express our concern about the timing of the transition to new inhalers. The patients with asthma, COPD and other diseases need the treatment every day We think that it is important to give enough time for this transition in order to avoid the lack of inhalers and also enough time for patients of all ages to master the new devices

Dear Sir or Madam, the European Green Deal is a major growth strategy for the EU, undoubtedly! All efforts should be made to achieve the ambitious goals of the climate-neutral continent by 2050. As anaesthesia doctors, we can make a significant contribution to this, and our specialist society, the German Society for Anaesthesiology and Intensive Medicine DGAI, has already taken a position paper in 2020.

Filed in German · English published by the European Commission

The International Primary Care Respiratory Group is a charity registered in Scotland, working internationally. Our vision is A global population breathing and feeling well through universal access to right care. Right care includes universal access to inhaled medicines for people with COPD and asthma.

ZERO - Associação Sistema Terrestre Sustentável is an Environmental NGO working on a broad range of issues where Climate Change and Energy are major action priorities. As a member of several European NGO networks - such as ECOS (European Environmental Citizens Organisation for Standardisation), EEB (European Environmental Bureau), CAN-Europe (Climate Action Network), etc.

Baxter is a leading global pharmaceutical & medical device company committed to delivering life-saving and sustaining products. We have been working with clinicians and hospitals across Europe for years to provide anaesthetic agents (inhaled & intravenous) that allow clinical treatment to be tailored to specific patient needs.

This is a statement by Daikin Chemical Europe GmbH and focuses on the topic of MDIs only. Daikin Chemical Europe GmbH (Dusseldorf, Germany) belongs to the Daikin Group together with Daikin Europe N.V.. While Daikin Europe N.V. produces equipment such as air-conditioning, heat pumps and refrigeration, Daikin Chemical Europe is one of the largest suppliers of high performance fluorochemical products in Europe.

ZeoSys Medical is a German pharmaceutical and medical device company that focuses on the capture and recycling of fluorinated anesthetic gases in human and veterinary medical applications. The ZeoSys CONTRAfluran Anesthetic Gas Capture System allows complete and convenient absorption of sevoflurane, desflurane, and isoflurane in the ICU or operating theatre.

ZVEI Statement on the EU COM Draft F-Gas Regulation (EU) Nr. 2014/517 of 05 April 2022 Statement of the Power Engineering Association for the "Switchgear" sector, 28 June 2022 Fluorinated greenhouse gases ("F-gases") and most ozone depleting substances (ODS) have a global warming potential that is many times higher than that of carbon dioxide.

The proposal to reduce the use of fluorinated gases (HFC/HFO) is a huge challenge for our industry and has an impact on manufacturers, installers, maintenance and maintenance services for refrigerating appliances. The proposed further quota reductions and quota coverage for inhalers will significantly reduce the quantity and availability of fluorinated greenhouse gases on the market.

Filed in Polish · English published by the European Commission

The Global Initiative for Asthma (GINA) is an international non-profit organization that works with health care professionals (HCPs), health officials and the general public to raise awareness of and improve the management of asthma worldwide.

In April 2022, the EU Commission presented a draft for the new version of the F-Gas Regulation (EU Regulation 517/2014). VDE FNN, as a national rule maker and recognized platform for grid technology and grid operation, supports the Commission's climate protection goals especially with regard to a climate neutral energy system.

Ormazabal develops customised and high-tech solutions aimed at digitalising the electrical grid to integrate more renewable energy generation, enabling more sustainable mobility and guaranteeing supply for buildings and infrastructures with critical power needs.

We fully support the Paris climate agreement to the intermediate REPowerEU and 2030/2050 climate targets as part of the European Green Deal objectives. We also broadly welcome the Commission proposal of a revised F-Gas Regulation.

Asthma + Lung UK is the UK’s largest lung health charity, representing approximately 12 million people in the UK who will be affected by a lung condition during their lifetime. We share the goal of addressing climate change and significantly reducing air pollution.

Revise and change the wording to delete the requirement to recovery for reuse or destruction of the foams and the gases contained therein from metal faced panel and laminated boards (see article 8.4. & 8.5). Change these two paragraphs deleting this requirement (see our arguments in the file attached )

EFCEM (European Federation of Catering Equipment Manufacturers) supports the alignment of the F-gas Regulation with the European Green Deal, European Climate Law, obligations on HFCs under the Montreal Protocol, progress and lessons learned. Professional products represented by EFCEM have a small share on the market, in percentage terms, compared to other market sectors covered by the proposed regulation.

APPLiA, the EU trade Association representing manufacturers of home appliances, including, ventilating and air conditioning and heat pump equipment, would like to share with the European policy-makers its stance and views on the new proposal for a Regulation on F-Gases revising (EU) No 517/2014 published on 5 April 2022. Please find our position paper attached.

Enel Group welcomes the Regulation proposal presented by the EU Commission on Fluorinated Greenhouse Gases in April 2022. As Enel Group, we are strongly committed to the objectives of the Paris Agreement and the achievement of a 2050 zero emission goal, alongside an ambitious science based certified reduction target by 2030.

Netze BW GmbH is the largest DSO within the EnBW Group with over 5,000 employees. It operates the distribution grid in large parts of Baden-Württemberg (southwest of Germany) for the electricity and gas sectors. Approx. 4,800 MW of installed capacity has already been connected to the distribution grid of Netze BW GmbH so far.

The Association of Innovative Medicines (VIG) is the trade association of pharmaceutical and vaccine companies in the Netherlands. For the consultation on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014, the VIG would like to share their insights.

Eurelectric fully embraces the European Commission’s decarbonisation objectives and its ambition to cut F-gas emissions, which have a very high global warming potential. DSOs and electricity generation companies are committed to adopting a sustainable approach to the development and operation of their assets.

With reference to the F-Gas revision proposal recently published, we would like to submit our feedback as follows. Seifert Systems is one of the leading manufacturers of control cabinet air conditioners. Currently most of the control cabinet air conditioners placed on the market contain refrigerant R134a (A1, GWP=1430). The market is transitioning to refrigerant R513A (A1, GWP=631).

EFCTC representing fluorocarbons manufacturers fully supports the objectives of the F-gas Regulation to encourage transition to lower GWP refrigerants. Our industry remains committed to do its part to comply with the already ambitious phasedown schedule for HFCs.

My name is Dr. Stephanie Snyder-Ramos, I am an anaesthesiologist and climate manager at the Salem Hospital in Heidelberg, Germany. Due to the increasing speed of climate change it is mandatory to take efficient and immediate measures to reduce greenhouse gas emissions.

The EU F-Gas Regulation is a landmark piece of European Union (EU) climate legislation for reducing emissions of fluorinated gases (F-gases) such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). The Environmental Investigation Agency (EIA), European Environmental Bureau (EEB), ECOS, CAN-Europe, Climate Advisers Network, 2 Celsius, ECODES, Deutsche Umwelthilfe, Legambiente and ZERO) welcome the Commission…

ECOS is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies and laws. We ensure the environmental voice is heard when they are developed and drive change by providing expertise to policymakers and industry players, leading to the implementation of strong environmental principles.

The revision of the F-Gas Regulation 517/2014/EU must strike a balance and be consistent with the various environmental objectives of the European Union in order to combat climate change. Summary of our analysis and position: The revision of the F-Gas Regulation 517/2014/EU, together with other important initiatives such as the Green Deal, Fit for 55 and more recently REpowerEU, is part of a climate change objective…

Filed in French · English published by the European Commission

Dear Sir or Madam, please refer to the attached document. Oesterreich’s energy supports efforts to combat climate change and at the same time draws attention to the special responsibility of the e-economy to secure electricity supply.

Filed in German · English published by the European Commission

Dear Ladies and Gentlemen, The attached statement is dedicated to the use and handling of SF6 . DILO Armaturen und Anlagen GmbH is a global market leader for SF6 and alternative gas handling, measuring and reconditioning equipment. We have been working very successfully with OEMs in this segment for over 50 years.

Refrigerants, Naturally! is a global, non-profit initiative committed to combating climate change and ozone layer depletion. We promote the use of natural refrigerants and provide a platform to engage with the business community, political decision makers, NGOs and other parties.

Dear Sir or Madam, Desflurane is an inhalation anesthetic that enables rapid anesthetic withdrawal and a safe postoperative period, especially in obese and elderly patients, due to its special pharmacokinetics. Patients are more quickly oriented and more confidently able to avoid respiratory complications, e.g., due to too shallow breathing or lack of cough reflex.

Dear Sir or Madam, Desflurane is an inhalation anaesthetic that allows rapid anaesthesia and a safe post-operational phase, especially in obese and elderly patients through its special pharmacokinetics. Patients are quicker and safer to avoid respiratory complications, e.g. by too shallow breathing or lack of cough reflex. On the other hand, the use of desfluranes results in unacceptable atmospheric pollution.

Filed in German · English published by the European Commission

As a consultancy company which daily deal with manufacturer and contarctors we have identified the following hints/issues about the document and the strategy. 1) Since the standards (such as EN 60335-2-89 and EN 60335-2-40) are already feasible for low GWP refrigerants such as “propane”, they require strict safety design rules such that it is mandatory to deal with a clear difference between “hermetically sealed”…

my name is Roland van Wandelen. i work in a large hospital in the netherlands as anesthesiologist. I am writing in concern of the plan to ban use of desflurane in clinical use. The use of all inhalational anesthetics in combination with gas-gapturing techniques and ultra low flow(end tidal guided) has to stay available for us as anesthesiologists in our daily practice.

Considering the approach to the phasing out of SF6 used in electrical switchgear at transmission voltages, the proposed regulations raise concerns in two key areas: (1) robust assessment of whole life carbon impact and (2) the ability to meet net-zero targets in a timely & efficient manner.

As Inhalation Institute Netherlands a foundation aiming to improve the lives of patients by increasing the correct use of inhaled medication, we fully support the statement posted on this website by the ADMIT group.

We write collectively as the ADMIT members (Aerosol Drug Management Improvement Team):R Dekhuijzen (NL),S Pedersen (DK),P Barnes (UK),R Buhl (Germany),L Corbetta (IT), C Corrigan (UK),B Garcia-Cosio (ESP), J Kocks (NL),F Lavorini (IT), M Levy (UK), N Roche (FR),J Scullion (UK),O Usmani (UK), a pan-European, multi-professional, respiratory expert group who advise and publish to provide evidence-based best clinical…

While we are advocates of environmental protection and the reduction of the fluorinated greenhouse gases in order to comply with the Montreal Protocol, we call for the careful consideration of the proposal since in our experience at the Petz Aladár University Hospital, volatilic anesthetic gases are effective and safe for most patients.

Hitachi Energy (formerly ABB Power Grids), a joint venture between Hitachi and ABB, is a global technology leader with roots in Europe and a history of innovation spanning more than 130 years. The company is committed to advancing a sustainable energy future for all. We welcome the opportunity to submit our feedback on the European Commission’s proposal for the revision of the F-gas regulation.

We are writing on behalf of the COPD Foundation to provide our views on the proposed revision of the European Union (EU) Fluorinated greenhouse gases (F-gas) Regulation to phase-down the available F-gas quota for medical inhalers beginning in 2027.

The International Pharmaceutical Aerosol Consortium (IPAC) and its members support the EU’s goal of net carbon neutrality. As detailed in the attached Position Paper, we call on EU legislators to devise the phase-down of medical F-gases in the EU in a way that maintains access to critical medicines for patients, allows for adequate time for a truly sustainable transition to a new generation of propellants for…

I am a Consultant Respiratory Nurse and have worked for over 34 years with people with chronic lung conditions. I feel passionately about getting the right medication into the lungs of those people with asthma and COPD that require it, and have spent my working life educating and teaching both patients with these diseases and the people that care for them about the right inhaler device for the right patient.

•It is very important to take into account the situation of several industries, i.a. pharmaceutical one, to ensure the security of supply of medicines. •The proposed Regulation could lead to a short-fall in availability of F-gases for metered dose inhaler (MDI) production, raising serious concerns about availability of this life-saving medication at a global scale with the EU being a major global supplier of…

Good afternoon, in the attached file you can find comments and hints from Assoclima about the "Proposal for a Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014".

I am Head of the Anaesthesia Service at Puerta del Mar University Hospital, Cádiz, Spain, with more than 40 years of experience, Professor of Anaesthesia at the University of Cádiz. Several publications on inhalatory anaesthesia.

Filed in Spanish · English published by the European Commission

VIK opinion on the Proposal for a Regulation on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 Positions/Requirements: —Technically practicable and mature SF6 alternatives for use in industrial switchgear are limited. SF6 alternatives have sometimes different electrical properties.

Filed in German · English published by the European Commission

Dometic Group, as a main provider of products and equipment for mobile and recreational use, is hereby commenting the draft review F-gas Regulation. Our main concern is the aggressive time line on the two general product bans in Annex IV (ban (12) and ban17)).

EPEE – representing the Refrigeration, Air Conditioning and Heat Pump (RACHP) Industry in Europe – supports the F-Gas Regulation as an essential tool to reduce emissions of F-gases. To tackle the global climate change crisis, F-gases such as HFCs, must be contained, their consumption phased down and their emissions reduced as much and as fast as possible.

The Global Initiative for Chronic Obstructive Lung Disease (GOLD) is an international organization that works with health care professionals (HCPs), health officials and the general public to raise awareness for Chronic Obstructive Pulmonary Disease (COPD) and to improve prevention and treatment for this lung disease.

Enedis, the main electricity DSO in France, has always been committed to reduce its GHG emissions especially through new equipment purchase adopting a strong and voluntary policy on shifting progressively, and following a positive robust assessment of existing solutions, to SF6-free equipment. Starting from 2021, Enedis’ new medium voltage switchgears in primary substations are SF6-free solutions.

Lufthansa Technik Group supports the EU’s ambition to increase its climate targets and make Europe the first climate-neutral continent by 2050 and the approach to further develop the existing regulation on fluorinated greenhouse gases regulatory framework.

Dear Sir or Madam, I welcome the initiative to rapidly reduce potential greenhouse gas emissions. On the subject of volatile anaesthetics, and in this case to ban drug deflurane in particular, we have regard to both medical and fundamental considerations. In our opinion, we would buy a beneficial medicine in the context of general anaesthesia with positive properties and thus a poorer care for our patients.

Filed in German · English published by the European Commission

Naturgy welcomes the opportunity to give feedback on the review of the Fluorinated Greenhouse Gas Regulation (F-Gas Regulation, 517/2014) regarding the phase out of SF6. Naturgy Group, which includes its electricity distribution system operator UFD, is fully committed with the emission reduction goals established by the EC. Please find below our considerations regarding this public consultation.

Guarantee the rights of respiratory patients by Shane Fitch, Lovexair Foundation According to experts who met during the Spanish Pulmonary and Thoracic Society SEPAR webinar: Climate Change and Respiratory Health & published by Fenaer (Spanish Federation of Associations of Patients with Allergy and Respiratory Diseases), inhalers account for 0.05% of all greenhouse gases; and fluorinated gases for pharmaceutical use…

The heat pump industry is facing a massive and large-scale market expansion. For reasons of energy security and climate protection, policy frameworks are being put in place in such a way that heat pumps become new standard heating within a few years and potentially cover the full range of the building stock.

Filed in German · English published by the European Commission

VDKF Joint opinion on the Commission proposal to recast the F-gases Regulation (Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 of 5 April 2022) Verband Deutscher Kälte- Klima-Fachbetriebe e.V.

Filed in German · English published by the European Commission

Dear sirs, My name is Manuel de la Matta Martín, I work as anaesthesiologist in a tertiary care teaching hospital (Hospital Universitario Virgen del Rocío, Seville, Spain), and have been involved for years in teaching and research in the field of inhalation anaesthesia.

On the occasion of the Directive (EU) 2019/1937 The European Society of Anaesthesiology and Intensive Care (ESAIC), provides its feedback as follows: THE ANAESTHESIA CONTEXT General anaesthesia is a medically induced coma with loss of protective reflexes, resulting from the administration of either intravenous or inhalational general anaesthetic medications, often in combination with an analgesic and neuromuscular…

Dear all. My name is Dr. Friedrich Pühringer, I am Professor in Anaesthesia and Chairman at the Dept. of Anaesthesiology and Intensive Care Medicine in Reutlingen, an Academic Hospital at the University of Tübingen in Germany. I am writing to you in deep concern, that Desflurane should be banned from clincal use in 2026.

Eviny AS welcomes the proposal to prohibit installation and replacement of electrical switchgear containing SF6 within the timeframe suggested in the proposal. In our opinion the suggestion will expand the market for climate friendly alternatives, speed up the technological development among manufacturers, create more competition and thus lead to a cost-effective transformation.

Joint statement on Commission proposal for the recast of the F-Gases Regulation (Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 of 5 April 2022) ___ Verband Deutscher Kälte- Klima-Fachbetriebe e.V.

Filed in German · English published by the European Commission

Dear Sir or Madam, as the largest European manufacturer of cabinet refrigerating appliances, we are faced with the deadlines in Annex IV too early with a ban on placing on the market. Electrical cabinet refrigerating appliances are not covered by the definition of ‘self-limited AC’ but are not covered by that of ‘indoor air conditioners’; therefore, depending on the language used, the applicability of the…

Filed in German · English published by the European Commission

I fully agree with the guidelines of the new F-Gas, but I believe that this plan is too ambitious to implement, considering that the only alternative for HVCR is the last resort to the fine-tuning of medium and highly flammable refrigerants. The individual European states are often characterised by a very slow implementation of new legislation, such as EN378, against the green transition proposed by F-Gas.

Filed in Italian · English published by the European Commission

WACKER supports the draft proposal presented by the EU Commission and believes it strikes the right balance between increasing the ambition of the quota system on the one side, and allowing for justified exemptions where no technological options are available on the other.

Commission values, in the view of the Österreichische Gesellschaft der Kältetechnik (ÖGKT), we are currently undergoing a change in the use of refrigerants on the basis of the ‘F-Gase-Verordnung’ (F-Gase-Verordnung). On the one hand, natural refrigerants are increasingly used which are toxic, combustible, air-displacement or have high operating pressures.

Filed in German · English published by the European Commission

AstraZeneca is a global, science-led, biopharmaceutical company that focuses on the discovery and development of prescription medicines for the treatment of disease in three therapy areas: Oncology, Cardiovascular, Renal & Metabolism, and Respiratory & Immunology. It has been recognised for its efforts on sustainability, incl.

E.DSO fully supports Green Deal objectives the European Commission intends to achieve. Becoming the first carbon neutral continent in 2050 is an ambitious target which can only be achieved through massive electrification of uses. European DSOs are by the nature of their activities contributing to achieve the energy transition.

Dear Sir/Madam, In the view of the Deutsche Kühl- und Klimatechnische Verein (DKV) e.V., the following points should be noted: • The current F@-@ Gas Regulation is being consistently implemented, in the three years 2015 @-@ 2018 a reduction of 37 % has been achieved and after 6 years (up to 2021) 55 % will be achieved. The quota system achieves a significant reduction in F-gases placed on the market.

Filed in German · English published by the European Commission

FULL CONTRIBUTION IN DOCUMENT ATTACHED 1) The multiple benefits of heat pumps are based on the refrigerant cycle which needs refrigerants to function. Key component of heat pump technology, refrigerants are required to fully exploit the heat pumps’ potential in decarbonising heating and cooling – they are the working medium that absorbs heat in a cooling process at low temperature and low pressure and emits heat at…

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation for transitioning away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). However, from ECODES, we consider that in the years since its adoption, it has become clear it requires significant improvements to safeguard our climate system by: accelerating the HFC phase-down schedule, in particular by…

ENTSO-E supports the EU to reduce the global greenhouse gas emissions towards climate neutrality in 2050 and is willing to commit further efforts to reduce SF6 emissions. SF6 is currently widely used in TSO high voltage (HV) applications such as gas-insulated lines and substations.

Dear Sir or Madam I represent Sinteco Srl, an Italian company in the distribution of gases HFC, HFO, HC in various applications and historical operator of Fgas (Incumbent). Surely the European Regulation CE517 / 2014 was and will be an important regulation in reducing the use of many gases in different applications, and is a milestone towards climate sustainability and a reduction in CO2 emissions.

3M response on the European Commission Public Consultation: Fluorinated greenhouse gases – review of EU rules (2015-20) 3M welcomes the European Commission’s roadmap targeted to review the EU-rules on fluorinated greenhouse gases. We believe that the impact assessment should include the following topics: Feasibility assessment on the introduction of a phase-down of sulfur hexafluoride (SF6) in electrical equipment.

The Swedish Refrigeration & Heat Pump Association (SKVP) would like to draw attention to the following two important issues in the continued work on a recast of the regulation on fluorinated greenhouse gases. Mandatory certification for installers of natural refrigerants crucial for the phase out of F-gases A successful introduction of products using natural refrigerants is key for a successful phase out of F-gases.

Bacharach welcomes the opportunity to provide feedback related to EU 517/2014. Please refer to the attachment for our detailed submission addressing Article 5 for leakage detection systems and the ability to achieve further HFC reductions through the inclusion of minimum performance, system, and imlementation requirements.

The F-Gas Regulation is a landmark piece of the EU climate legislation for moving away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). In the years since its adoption, however, it has become clear that it requires significant improvements to safeguard our climate system namelly:  accelerate the HFC phase-down schedule, in particular by adjusting the penultimate step in 2027…

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation aimed at reducing fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). In the years since its adoption, however, it has become clear that it requires significant improvements to improve compliance and enforcement and safeguard our climate system, including by: -- accelerating the HFC phase-down…

In this document you will find some questions related to the revision of the F-gas Regulation (517/2014). We would increase the efficiency of the F-gas Regulation. These first years of implementation of the Regulation have laid down the foundations for a correct management of chilling and to raise awareness of installation/mainainer and End Users to the pollution potential of HFCs.

Filed in Italian · English published by the European Commission

Response from the European Fluorocarbons Technical Committee (EFCTC) to the Inception Impact Assessment on the revision of Regulation No. 517/2014 (Ref. Ares (2020) 3402178 - 29/06/2020) is detailed in the attached document. While contributing to this consultation we remain very aware we are all still experiencing unprecedented times. As Cefic, we aim to maintain a high standard in our responses.

The European Federation of Allergy and Airways Diseases Patients’ Associations (EFA) is the voice of over 200 million people living with allergy, asthma, and chronic obstructive pulmonary disease (COPD) in Europe.

Confartigianato Imprese, the largest Italian network that represents Crafts and SMEs and delivers services to entrepreneurs, believes that the revision of the EU F-Gas Regulation must take into consideration two fundamental concepts: - exclusion of combustible gases from refrigerant gases as future alternative for F-Gas (for safety reasons); - obligation for producers and importers to track units (e.g.

TECNEA Cecobaroid has an independent experience in the field of cooling supply chain, refrigeration and air-conditioning for more than 70 years. TECNEA Cegobaroid carries out certification activities under the F-Gas Directive in France since 2008 and in Italy since 2014 with almost 14.000 certificates of capacity (holdings) and 80 certificates of competence (persons) issued.

Filed in Italian · English published by the European Commission

Siemens Energy welcomes the opportunity to give feedback on the review of the Fluorinated Greenhouse Gas Regulation (F-Gas Regulation, 517/2014) regarding the phase out of SF6 in high-voltage (HV) applications. Siemens Energy fully supports the European Union’s ambition to become the world’s first carbon-neutral continent by 2050, the Paris Agreement and the UN Sustainable Development Goals.

We as ASERCOM, the Association of European Refrigeration Component Manufacturers, reaffirmed in 2018* our commitment and engagement to accompany our industry to reach the 2030 F-gas target of CO2 emission réductions: 1.- Containment & Safety Measures:  Our industry has always led standardization committees and followed standards concerning tightness of components and safety requirements.

AREA, the European association of refrigeration, air conditioning and heat pump (RACHP) contractors, welcomes the timely publication of the combined roadmap / impact assessment. An evaluation of the performance of the existing Regulation is necessary to identify opportunities for clarifying and simplifying the rules and strengthening their enforcement.

Eurelectric welcomes the publication of the combined Evaluation Roadmap and Inception Impact Assessment on Fluorinated gases (F-gases). The European power sector supports the EU commitment to reduce the global greenhouse gas emissions towards the achievement of climate neutrality by 2050, as part of the European Green Deal objectives, and is willing to commit further efforts to reduce F-gas emissions as far as…

The F-Gas Regulation is a landmark piece of European Union (EU) climate legislation for transitioning away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). As an environmental civil society organisation, ECOS strongly welcomes the initiative of the European Commission to anticipate the update of the legislation and calls for significant improvements to safeguard our climate…

German Environment Agency (UBA) response to the combined evaluation roadmap/Inception Impact Assessment for the Review of EU rules on fluorinated greenhouse gases (Ares(2020)3402178 - 29/06/2020) UBA welcomes the review of the F-gas Regulation and the intent to improve actions to avoid emissions of fluorinated greenhouse gases.

CEDEC, the European Federation of Local Energy Companies, represents the interests of more than 1500 local and regional energy companies, active in every part of the electricity and gas value chain. CEDEC fully supports the Green Deal objectives the European Commission intends to achieve.

The F-gas Regulation is a key and guiding part of the European Union (EU) climate legislation for the transition from the use of fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6) to the use of natural refrigerants. Having been in force for five years, the Regulation is now being reviewed with a view to improving it.

Filed in German · English published by the European Commission

We welcome the F Gase Regulation. The approach of reducing F-gases to reduce equivalent CO2 emissions is very good. The F Gase Regulation has so far led to a change of mindset and temporary turbulence on the market in the field of refrigeration. In addition to the positive switch to natural refrigerants, HFO refrigerants are increasingly used. The long-term effects of these, e.g.

Filed in German · English published by the European Commission

The F-Gas Regulation is a landmark piece of the EU climate legislation for moving away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6). In the years since its adoption, however, it has become clear that it requires significant improvements to safeguard our climate system namelly:  accelerate the HFC phase-down schedule, in particular by adjusting the penultimate step in 2027…

ABB feedback on the review of EU rules on the F-Gas regulation EU 517/2014 addressing SF6 in gas-insulated switchgear – ABB welcomes the opportunity to provide its input to the update of the F-Gas regulation EU 517/2014 regarding SF6 in gas-insulated switchgear.

With the EU climate neutrality target, the F-Gas Regulation requires revision to strengthen its contribution to the target and to improve the Regulation’s implementation. The Regulation is a landmark piece of EU climate legislation for transitioning away from fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6) – gases with considerably high global warming potential profiles.

The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the review of rules on flourinated greenhouse gases consultation and wants to draw attention to the following key points: • We must ensure via study that any restriction caused by policy results in a net improvement in overall sustainability.

Chiesi welcomes the public consultation and the opportunity to share its views and plans to achieve the goals as stated by the Montreal Protocol and the Kigali Amendment. Chiesi Group is a research-led mid-size European pharmaceutical company, registered as a Benefit Corporation since 2018. It is the largest global biopharmaceutical group to be awarded B-Corp Certification.

Agoria, the Belgian federation for the technology industry, supports the objectives of the European Green Deal in which technological innovations will have an important role to play to make the EU the world's first climate neutral continent by 2050. We are grateful to assist the Commission during the entire review process of the F-gas regulation.

Enel Group welcomes European Commission initiative for the review of Fluorinated Greenhouse Gases rules. Enel is strongly committed to the objectives of the Paris Agreement and the achievement of a 2050 zero-emission goal, alongside an ambitious science based certified reduction target by 2030.

The International Pharmaceutical Aerosol Consortium (IPAC) represents major pharmaceutical companies – AstraZeneca, Boehringer Ingelheim, Chiesi Farmaceutici, GlaxoSmithKline, and Kindeva – which research, develop, and manufacture products for the treatment of respiratory illnesses such as asthma and chronic obstructive pulmonary disease (COPD).

Dear Sir or Madam, Regulation (EU) No 517/2014 of the European Parliament and of the Council (F Gas-Regulation) aims to protect the environment by reducing emissions of fluorinated greenhouse gases (F Gases). Many F Gases show a high global warming potential (GWP).

Executive Summary As a supporter of the F-Gas Regulation and the European Green Deal, EPEE, representing the refrigeration, air-conditioning and heat pump industry, emphasizes that the heating and cooling sector can make an important contribution to achieving climate neutrality in Europe by 2050.

Already in 2017 it was obvious that the availability of crucial f-gases in the internal market would become limited. Prices were exploding, supply could not be guaranteed for many applications. Only between March and October 2017 prices in central Europe increased to ~750% for common cooling agents. This trend continued into 2018 and stabilised then.

Eurovent is committed to the success of the F-Gas Regulation and appreciates the opportunity to submit feedback on its improvement. The review of the F-Gas Regulation should focus on avoiding circumvention, removing barriers to flammable and reclaimed refrigerants, and retrofitting existing equipment, without compromising energy efficiency, reliability, and safety.

Dear Sir/Madam, Please find attached our document where our vision concerning the refrigeration market, the corresponding impact of the current EU laws and some suggestions of amendments. It is our strong opinion that minor amendments on current European Legislation could produce major positive impacts on leakage and emissions reduction.

Siemens AG likes to address 3 topics regarding aspects of SF6 management in its feedback to (EU) No 517/2014. For further details and annotations please refer to the attachment. A. Countries that adopted a self-commitment on SF6 emissions reduction, show significantly higher reductions from 2.G.1 sector than others. We recommend implementing the content of these well-working commitments into a regulation recast. B.

As early as 2017, it became clear that the availability of the main F-gases in the internal market will be limited. Prices were exploded and supply could no longer be guaranteed for many applications. Only between March and October 2017 did the prices of common refrigerants in Central Europe increase by ~750 %. This trend continued until 2018 and then stabilised.

Filed in German · English published by the European Commission

The current F-Gas Directive is being undermined by the large and continued import of illegal HFCs. Stronger enforcement plus dissuasive penalties are required to stop the illegal trade of HFCs. Wider incentives for the recovery and reclamation of existing HFCs could significantly reduce the need for virgin production and lower overall atmospheric emissions.

Dear EU Colruyt Group would like to share its’ extensive experience with all natural refrigerants, as a distribution company and as a retailer, because we find that natural refrigerants can replace chemical refrigerants economically in all our applications. Uniquely, Colruyt Group is also a registered refrigeration company and we would like to share our experiences with the F-gas regulation as such.

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry welcomes the opportunity to present its feedback experiences from the current 517/2014 “F-Gas regulation”, specifically regarding aspects of SF6 management. Please see the attachment

Technical Statement Review of EU rules on fluorinated greenhouse gases The present statement summarizes the technical evaluation of the EU rules regarding fluorinated greenhouse gases, with focus on refrigerant application on chilled water and provision cooling units from the point of view of Engie Axima Germany GmbH, as supplier of refrigeration plants for the maritime sector.

Please find our comments attached. About the European Heating Industry The European heating industry brings together companies that are leaders in the production of efficient heating systems. Our members produce advanced technologies for heating in buildings, including: heating systems, boilers, heat pumps, burners, components and system integrators, radiators, surface heating & cooling.

Enedis, as the main DSO in France, operating approximately 95% of the French territory and connecting more than 36 million customers, fully supports Green Deal objectives the European Commission intends to achieve. Enedis operates 57,000 primary MV circuit breakers and more than 300,000 gas insulated MV secondary switchgears. The company constantly committed to reduce its GES emissions in its own activities.

WACKER is the world market leader and the only European manufacturer of high-purity polysilicon – the basic material for photovoltaic cells and semiconductor chips – and thereby holds a strategic position in the industrial value chains for enabling the green energy and digital transition in Europe.

Dear EU, thank you for the opportunity to present views from the day-to-day national work of checking F-gas approvals. The current F-gas regulation is very good - if there is a new regulation now, the work will start all over again to implement it all the way to the consumers - a work that will take many years. The two biggest challenges right now are partly the price increases on HFC refrigerants.

Dear EU, I was involved in the role out of the FGAS regulation in the transport refrigeration sector in the UK. We employed c150 engineers who all entered and gained the correct FGAS accreditation and it help provide them with a level of professionalism which has been lacking in our sector of the Cold Chain.