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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.

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.

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.

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.