Country’s environment agency recommends tighter limits on refrigerant use as work gets underway to review current EU regulations
The German Environment Agency, Umweltbundesamt (UBA), has backed a stricter approach to curbing the use of ozone depleting substances (ODS) that would go beyond those identified in the Montreal Protocol. The calls were made ahead of a broader review of current European regulations.
The calls were made to the European Commission in response to a consultation on setting out a roadmap to evaluate its ozone depleting substances regulation (No 1005/2009) in order to decide if the legislation is “fit for purpose”. Outcomes of the evaluation could have significant impacts on refrigeration at a time when the industry is already wrestling with a switch to low-GWP gas.
The UBA, in response to the roadmap consultation, called for a “consistent strict ban of ozone depleting substances” that it says should include the refrigerant 1233zd. This is based on recent research suggesting the substance has an ozone depleting potential of 0.00034 - meaning it can still have negative environmental impacts.
“Despite the ODP>0 the substance will be produced and promoted for several new applications in the field of refrigeration,” UBA said.
The agency’s response also cited recently published research indicating that halogenated very short lived substances (VSLS) such as dichloromethane have a stronger impact on stratospheric ozone depletion than was previously thought.
“Based on these findings in our opinion a broader consideration of non-Montreal Protocol compounds and the evaluation of an additional inclusion of halogenated VSLS would be beneficial to improve the protection and regeneration of ozone layer,” added the UBA.
With the submission deadline to provide feedback to the European Commission’s consultation on ODS regulations now having closed, the agency says that updates on this process and the broader evaluation exercise will be provided later next month.
The European Environment Agency (EEA), which is not directly involved in the evaluation process, has said the review of the ODS regulation was a “standard interim evaluation of a piece of EU legislation”.
As part of the upcoming regulation review process, the EEA will provide data to support the evaluation as is required under Article 27 of the existing ODS regulations. This information is then put together in an annual report published by the EEA concerning ODS output.
“Article 27 of the ODS regulation requires that each company producing, importing and/or exporting into the EU, feedstock user, process agent user and destruction facility must annually report their activities concerning controlled substances (ozone-depleting substances covered by the Montreal Protocol),” the agency said.
The EEA, in considering the future for ODS use in Europe, said that the substances were, to a large extent, being replaced by F-Gas. Use of these products is covered by a separate piece of European legislation (NO 517/2014).
“The F-Gas regulation implements an EU-wide HFC phase-down. Large reductions in F-Gas use and emissions are expected to result from this phase-down measure, and will progressively cap sales of HFCs allowed on the EU market, bringing maximum sales down to 21 % of baseline levels by 2030” said the agency.
“Reductions are also expected to result from bans on the use of F-Gases that have high GWPs. EEA’s role is to compile the data reported under Article 19 of the F-Gas regulation.”