Contractor and manufacturer associations voice concerns over implications of setting specific refrigerant requirements in Ecodesign Implementing Measures.
The European association of refrigeration, air conditioning and heat pump contractors (AREA); and the European Partnership for Energy and the Environment (EPEE), representing the manufacturers of Refrigeration, Air Conditioning and Heat Pump (HVACR) equipment in Europe, have issued a statement highlighting three key concerns in respect to the Ecodesign Directive for energy-related products, and the setting specific refrigerant requirements.
In a joint statement, they said: “Ecodesign rules significantly contribute to Europe’s energy efficiency policy, but are also closely linked with other policy objectives, such as climate change. In this regard, AREA and EPEE have noted a growing tendency to address direct refrigerant emissions through energy policy.
An example is the bonus schemes based on the Global Warming Potential (GWP) of refrigerants. Such a scheme has been adopted under the Ecodesign Regulation for air conditioners and comfort fans (Regulation 206/2012) and has since then been considered as a potential way forward within the framework of a number of other Ecodesign Product Lots.
However, even though facilitating the uptake of low GWP refrigerants by setting lower energy efficiency requirements or by introducing GWP thresholds may seem a realistic and manageable policy option, such measures may not necessarily lead to the desired effects on both technological innovation and reduction of total CO2 emissions. Indeed, they may even turn out to be counter-productive in terms of emissions, energy consumption and safety.
AREA and EPEE therefore call upon decision-makers to look at the following three key implications and risks of setting specific refrigerant requirements in Ecodesign Implementing Measures:
1. The principle of better and smarter regulation: It is contradictory to the EU principle and objective of better and smarter regulation to regulate the same subject in different pieces of legislation. In addition, it would severely limit the opportunity for manufacturers to innovate and to fully exploit the benefits of the full range of available refrigerants in specific applications.
We firmly believe that the refrigerant issue should be dealt with under the F-gas regulation, to avoid complications, inconsistencies and regulatory overlap, and to ensure clarity on how these aspects will be covered. Otherwise, there is a distinct risk of increased energy consumption and emissions.
2. The primary objective of the Ecodesign Directive: The Ecodesign Directive seeks to reduce total CO2 emissions by promoting energy efficient products.
This aim could be undermined by placing unwarranted and unproven restrictions on the availability of highly efficient and safe refrigerants used widely in the global HVACR industry.
We understand that all environmental aspects of HVACR products including refrigerants should be evaluated in preparatory studies; however, we do not support that the type of refrigerant should serve as a basis for an Ecodesign requirement.
3. Energy efficiency and safety: The performance and energy efficiency of HVACR products is not simply related to the GWP of the contained refrigerant, but depends on a complex combination of design parameters.
Restricting one of those factors will inevitably affect the optimum performance of the product. In addition, any incentive for low GWP refrigerants may lead to the choice of a refrigerant that has a low global warming potential, but that may increase the energy consumption of the equipment.
For example in commercial refrigeration applications, using CO2 as a refrigerant will prove to be a very energy efficient solution in Northern and Central Europe but will lead to an increase in energy consumption in the hot climates of Southern Europe.
Finally, the use of lower GWP refrigerants due to their physico-chemical properties may give rise to safety related issues during the whole lifecycle stages such as use, maintenance, servicing and end of life.