Minimum requirements for certification programmes and training attestations for RACHP equipment

The Clean Cooling Coalition (CCC) welcomes the opportunity to send feedback following the publication of the draft implementing regulation implementing F-Gas Regulation (EU) 2024/573 with regard to the minimum requirements for the issuance of certificates to natural and legal persons and the conditions for the mutual recognition of such certificates.

ATMOsphere welcomes the opportunity to send feedback following the publication of the draft implementing regulation implementing F-Gas Regulation (EU) 2024/573 with regard to the minimum requirements for the issuance of certificates to natural and legal persons and the conditions for the mutual recognition of such certificates.

ADC3R has summarised in the attached file some points that need to be adjusted, in particular the scope and particularities of the categories of professional qualifications. Regulation (EU) 2024/573 (Art. 2 ) applies : (a) fluorinated greenhouse gases listed in Annexes I, II and III, whether alone or in mixtures; and b) products and equipment and parts thereof containing, or whose functioning relies upon…

The EU F-gas regulations raison d'être is to reduce emissions from F-gases in the EU. This implies that the F-gas regulation needs to support the professional handling of F-gases and the increased usage of alternatives, predominantly natural refrigerants. The present Commission proposal will unfortunately add to many burdens to the industry.

REAL ALTERNATIVES 4 LIFE CONSORTIUM of 22 partners from 17 EU Member Countries and Beyond. As part of the EU F-Gas Regulation revision, new certification requirements for personnel handling flammable fluids, CO2, and ammonia have been introduced. In response, European industry leaders and experts developed a training program in 2020 that includes a technician evaluation for CO2 and flammable refrigerants.

ASERCOM welcomes the opportunity to give feedback on establishing minimum requirements for the issuance of certificates to natural and legal persons and the conditions for the mutual recognition of such certificates pursuant to Regulation (EU) 2024/573.

Japan Business Council in Europe (JBCE), representing companies of Japanese parentage operating in Europe, appreciates the opportunity to provide feedback on the Draft Implementing regulation [Ares (2024)3437233] on the RACHP certification requirements extended to organic Rankine cycles and refrigerated units in mobile equipment.

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 and would like to bring its contribution to this implementing act on on training and certification requirements and on its draft annex. EPEE thanks the Commission for giving the opportunity to deliver feedback on this draft implementing act.

The Norwegian Heat Pump Association (NOVAP) and VKE The Norwegian HVAC and Refrigeration Association represent all relevant stakeholders in the heat pump and the refrigeration sector in Norway, from technicians and contractors to consultants and distributors. Both natural and flammable refrigerants have been used extensively for heating, comfort cooling and refrigeration in Norway for years.

In our view, it is important to point out that the transition from the previous regulations in Commission Implementing Regulation (EU) 2015/2067 to a possible new categorisation with categories A - D in accordance with the current draft does not create any additional hurdles for the current holders of certification.

CNA, National Confederation of Craft and Piccola and Media Enterprise, associates 620.000 entrepreneurs who provide jobs to 1.2 million people. The CNA represents and protects the interests of micro, small and medium-sized enterprises active in manufacturing, construction, services, transport, commerce and tourism. As part of the installation of installations, the CNA associates around 40.000 companies.

Filed in Italian · English published by the European Commission

SNEFCCA, the French Trade Association of Refrigerating, Catering and Air Conditioning Equipment installers read with interest the draft submitted by the Commission for consultation. SNEFCCA considers that this project does not fall within the scope of the F-GAS regulation because it deals with the use of refrigerants whose potential impact in the event of release into the atmosphere is not regulated under F-Gas…

We have taken note of the draft text in consultation until June 10 2024 which proposes minimum requirements for the issuance of certificates to natural and legal persons and the conditions for the mutual recognition of such certificates, as regards stationary refrigeration, air conditioning and heat pump equipment, organic Rankine cycles and refrigeration units of refrigerated trucks, refrigerated trailers…

Deutsche Umwelthilfe would like to thank the European Commission for preparing this draft certification requirements in line with the F-Gase Regulation (EU) 2024/573, as well as for the possibility to comment. We see the enforcement of natural refrigerants instead of F-gases as an important milestone in achieving climate objectives while at the same time being environmentally friendly by avoiding regrettable…

Filed in German · English published by the European Commission

Dansk Køl & Varme is representing more than 200 installers and service companies and is the single largest representative of danish companies specialized in refrigeration. We welcome the aspiration of the f-gas regulation to secure the education of the work force in such a manner that it will support the transition into alternatives to f-gasses.

NVKL, the Dutch association of enterprises in the field of cold engineering and air treatment, supports the transition from fluorinated gases to alternative refrigerants. At the same time, it is clear that in many cases knowledge is lacking, especially when it comes to working safely with these alternatives (in practice these are ammonia, carbon dioxide and hydrocarbons such as propane).

Filed in Dutch · English published by the European Commission

The Landesinnung Kälte-Klima-Technik Hessen-Thüringen/Baden-Württemberg (KdöR) (Refrigeration and Air Conditioning Technology Guild of Hesse-Thuringia/Baden-Württemberg), based in Maintal, Germany, has been a recognised certification and evaluation body since 2008 and has been awarding certificates based on the previous F-Gas Regulation and the national Chemical Climate Protection Regulation…

The natural refrigerants CO2 and NH3 are not subject to F-gas regulation. Nevertheless, persons who care for these refrigerants in the service are subject to heavy red tape in the implementing regulation on F-gas regulation. This does not encourage the widespread use of natural refrigerants. The work with CO2 and NH3 should be exempted from the certification requirement in this Implementing Regulation.

Filed in German · English published by the European Commission

Energibranchens Service Association, ESS (The Energy Industry Service Association) advises you for the appropriateness to comment on the draft of the EU F-gas implementation regulation. We find the proposal changing to Interpret and Unclear in places. Regarding the existing Danish legislation and certification, we obtained and Interpret the for us most important importing points as follows: 1.

Filed in Danish · English published by the European Commission

This feedback has been formulated in cooperation with the Danish educational institutions for refrigeration technicians, The Technical College of Jutland, Copenhagen School of Marine Engineering and Technology Management, and TEC Technical Education Copenhagen, as well as KMO, the Danish evaluation and certification body in accordance with the implementing regulation (EU) 2015/2067.

The European Heating Industry (EHI) thanks the European Commission for preparing this draft implementing act that will update the certification requirements, in line with F-Gas Regulation (EU) 2024/573. We agree that an update is needed to include non f-gas alternatives (hydrocarbons, ammonia, CO2).

Comment on EDF F-gas Implementing Regulation. 1. We would like to confirm that the EDF gas implementation scheme does not cover persons installing heat pumps with hermetically sealed cooling circuit, where the installation does not require tampering with the closed cold circuit. 2.

Filed in Danish · English published by the European Commission

Response to EUs F-gas implementing regulation. TEKNIQ Arbejdsgiverne is the driving force behind sustainable and digital growth in Denmark. We represent the technical business sector: i.e., installers, electrical, plumbing, cooling, heating, blacksmithing, and metal industries. We favor the green transition and support at CO2-nutral society.

As a member of the Real Alternative consortium (contact point in France), Cemafroid Formation established this proposal: As part of the revision of the EU F-gas Regulation, new certification requirements have been introduced for personnel handling flammable fluids, CO2 and ammonia.

Filed in French · English published by the European Commission

We think that a separate certificate should remain available for smaller companies and independent installers, which only deal with smaller systems in the residential sector. This approach, that is similar to current Category II, would also be very important in view of the uptake of heat pumps foreseen by RePowerEU.

1) Title of draft commissioning Implement Regulation It is suggested that the following classes of equipment be added, Coaches, Buses, Metros, Trams, Agricultural machinery, Cranes, Train Carriages and Excavation Equipment. 2) Changes in F Gas Regulation proposed. a) Currently distributors of pre-charged F Gas equipment can supply equipment without a need to see/ record a legal persons Certificate.

AREA, the European association of refrigeration, air conditioning and heat pump (RACHP) contractors, fully supports an ambitious transition to alternatives to f-gases. However, AREA members have been voicing concerns regarding the very low level of training on alternative refrigerants among F-gas trained personnel and on the risk of a shortage of contractors trained in the use of low GWP refrigerants for years.

In the two attached files you will find AFCE’s comments and proposals concerning the proposed text of the Regulation laying down the procedure for implementing Regulation (EU) 2024/573 concerning the certification of undertakings and persons.

Filed in French · English published by the European Commission

Feedback to Draft implementing regulation - Ares(2024)3437233 (Attached the full Feedback document) Confartigianato Imprese Apa Milano Monza Brianza is part of the most representative Italian organization of crafts and micro and small businesses (MSEs).

We have read the draft text for consultation until 10 June 2024, which proposes an update of the minimum requirements for issuing certificates to natural and legal persons and the conditions for mutual recognition of such certificates. ATLANTIC Group recommends revising the requirements for training and certification of operators (natural persons) and businesses (legal persons).

Filed in French · English published by the European Commission

Article 4(2)(a) Personal certificates already have the validity periods laid down in Regulation (EU) 2024/573, so there is no need to add if any. We propose to delete this. Article 4 paragraph 3 The exemption of applicants from the requirement to pass the examination should have a time-frame for acquiring equivalent qualifications in order to prevent persons with outdated knowledge from being certified (e.g.

Filed in Polish · English published by the European Commission

EHPA believes a separate category should remain available for smaller equipment, similar to today's Category II. This is particularly important in view of the uptake of heat pump systems supported by the REPowerEU targets, which require the amount of newly installed heat pumps to double every four years. Furthermore, EHPA suggests certificates also indicate which Regulation the certificate refers to.

The EEB welcomes the EU Commissions draft establishing minimum requirements for the issuance of certificates for stationary and mobile refrigeration. Article 3(2) 360º training We hold that all training and certification should be automatically extended to both fluorinated and hydrocarbons.

ECODES welcomes the European Commission’s proposal on extending certification requirements and would like to share the following comments on the same proposal: Article 4 (certification of natural persons): Include a provision in Article 4 to ensure that certification and training programmes are economically accessible and geographically available to all technicians, including the possibility to run these programmes…

Filed in Spanish · English published by the European Commission

JRAIA(The Japan Refrigeration and Air Conditioning Industry Association) would like to submit following comments. 1) General Comment The Article 1 of the F-Gas regulation mentions laying down rules on related ancillary measures, such as certification and training, which includes the safe handling of fluorinated greenhouse gases and of alternative substances that are not fluorinated.

What to suppose! The European Commission already regulates expertise in the construction of refrigeration systems. Why does the electrician or heating system builder not need EU certification? If I have the hair cut the next time, I will ask for the EU certificate issued for this!

Filed in German · English published by the European Commission

Please see below comments and question regarding implementing regulation. Regards, Brian. General Recommendations from the LCETB All EU countries should be required to set up an online portal. This could be used for all engineers to upload their certificates. This central data base would be of benefit to ensuring compliance and good workmanship within the sector.

Good afternoon, please see our comments regarding the annex's and the implementing regulation. Regards, Brian. Responses to F-Gas Regulation EU 2024/573 repealing regulation 517/2014 ANNEX 1 Page 2, part 1.03. Please include the letter T for the box that currently blank under the D category. Page 3, part 1.07. Should the letter T be present on all five of the categories?? Page 4, part - 3.03.

ZERO – Associação Sistema Terrestrial Sustainable, is a Portuguese environmental NGO working on a number of topics, with priority being given to the areas of climate change and energy. He is an active member of several networks of European NGOs, such as: ECOS (European Environmental Citizens Organisation for Standardisation), EEB (European Environmental Bureau), CAN-Europe (Climate Action Network) and RGI (Renewable…

Filed in Portuguese · English published by the European Commission

APPLiA, the European Trade Association representing manufacturers of home appliances, including ventilation, air conditioning and heat pump equipment, would like to share the following comments as a response to the consultation on the draft implementing regulation laying down rules for the application of Regulation (EU) 2024/573 of the European Parliament and of the Council establishing minimum requirements for the…

Referring to the draft Commission Implementing Regulation (EU) establishing, pursuant to Regulation (EU) 2024/573 of the European Parliament and of the Council, minimum requirements regarding the issuance of certificates to natural and legal persons and the conditions for mutual recognition of such certificates in the field of stationary refrigeration, air conditioning and heat pumps, organic Rankine cycles and…

Article 2 Scope Clause 1 (b) The definition of Installation is not adequate for the purposes of the regulation. To correct this clause 1(b) his should be expanded as follows Placing in position and/ or installation of the equipment listed in Article 1 containing fluorinated greenhouse gases listed in Annex 1 and Section 1 of Annex II to Regulation (EU) 2024/573 or the alternative substances, ammonia (NH 3 ), carbon…

We would like to send you a feedback on the implementing regulation on behalf of the Slovak Refrigeration and Air Conditioning Technology Association (SZCHKT). Due to technical problems on the SZCHKT side, it is not possible for SZCHKT to send the feedback directly at the moment. Therefore, SZCHKT has delegated this task to us and we hereby submit it to the Commission.

CONAIF comments are stated in the attached file, which is in both Spanish and English, the header of the page contains which version are you at. From our perspective, it should be taken into consideration that Spanish legislation provide a framework of knowledge for installers and many topics are redundant to the basic skills and knowledge of a entitlement spanish installer.

The project repeals Commission Implementing Regulation (EU) 2015/2067 on the same matter. Commission proposes a new categorisation of certificates (Article 3 Certification of natural persons). The current categories have been retained to some extent.

This feedback refers to · Art. 2, point 1 (b), (c) · Art. 2, point 2 · Art. 3, point 2 (b), (c) The draft specifies in Art. 3, point 2 that natural persons carrying out activities referred to in Art. 2(1) shall hold a certificate of types B or C when working with CO2 or NH3 respectively. What is the problem? Regulation EU 2024/573 does not include in its scope equipment operating with CO2 or NH3.

Finnish Safety and Chemicals Agency (Tukes) certifies natural persons and companies in Finland in accordance with the F-gas regulation. The proposal for Commission implementing regulation contains requirements for natural persons with existing certificates. These persons shall update their knowledge and skills with a refreshment training course.

REAL ALTERNATIVES 4 LIFE CONSORTIUM of 22 partners from 17 EU Member Countries and Beyond. As part of the EU F-Gas Regulation revision, new certification requirements for personnel handling flammable fluids, CO2, and ammonia have been introduced. In response, European industry leaders and experts developed a training program in 2020 that includes a technician evaluation for CO2 and flammable refrigerants.

Dear Members of the European Commission, I am writing to express my concerns regarding a specific provision in the draft of the Commission Implementing Regulation (EU) 2024/573 establishing minimum requirements for the issuance of certificates to natural and legal persons related to stationary refrigeration, air conditioning, heat pump equipment, and other related devices containing fluorinated greenhouse gases or…

We (AGFR- The Romanian General Association of Refrigeration) agree with 17.05.24 V.B. German position. It is not possible to cover with F-Gas certificate the skills for NH3 and CO2 Systems. Must be done changes regarding minimum requirements from this draft act proposal : - 07.06 .

Regarding Hydrocarbons, I feel that Real Alternatives Certification for handling Flammable refrigerants should be specifically recognized under this regulation as it is already the accepted certification across many EU countries and already includes both a practical and theory assessment, Why re invent the wheel ?

Re: Article 7 - certificates for Legal Persons (Company Certification) It is important that this certification is standardized across the EU in order to allow for mutual recognition in all EU states. Individual states or certifying bodies must not add or subtract from the certificate. This has and will continue to cause problems for companies across the member states.

Certification for working with equipment containing dnatural refrigerants only makes sense in terms of personnal safety and operational safety. Ths has nothing to do with F-Gases. Including the certification under the F-Gas-Regulation is worthless and absurd.

Regarding Ammonia (NH3) Certification, as pre-understanding in many member states, they do not have the tools or the equipment to take practical exams. For CO2 practical exams will it be considered the Transcritical Process, the Subcritical Process and/or the Cascade Systems? Or will be only Transducers and other present applied means of security, that is only control knowledge?

luorinated gasses and the environment Refrigeration systems had long been in use before the development of F-gasses, with natural refrigerants taking the helm. However, the collaboration between earlier systems and natural refrigerants had its issues, with flammability, toxicity and the corrosive nature of some natural refrigerants causing big problems.