EUROPE: The tendency for the European Commission to address direct refrigerant emissions through energy policy may not have the desired effect, say industry groups representing the European air conditioning and refrigeration industry.
In a joint statement, the European contractors' organisation AREA and the manufacturers group EPEE have said that this policy may have a detrimental effect on technological innovation and might not even produce the desired reduction in total CO2 emissions. Further, the two groups say that these policies may even turn out to be counter-productive in terms of emissions, energy consumption and safety.

As an example, AREA and EPEE point to the bonus schemes based on the GWP of refrigerants as adopted under the Ecodesign Regulation for air conditioners and comfort fans (Regulation 206/2012). According to AREA and EPEE, this has since then been considered as a potential way forward within the framework of a number of other Ecodesign Product Lots. Under the new regulation, lower energy efficiency requirements are set for equipment running on low GWP refrigerants. Such measures, say EPEE and AREA, may not necessarily have the desired effects.

AREA and EPEE argue that 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, they say, 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. The groups maintain 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,' say AREA and EPEE in a joint statement.

AREA and EPEE also maintain that the intention of the Ecodesign Directive to reduce total CO2 emissions by promoting energy efficient products could be undermined by placing unwarranted and unproven restrictions on the availability of highly efficient and safe refrigerants.

'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,' they say.

The two groups also point out that 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, they argue.

'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,' says the joint statement. '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.'