The proposal to ban pre-charged equipment under the F-gas revisions has received environmental backing.
Although still in favour of an ultimate ban on HFCs, the Environmental Investigation Agency (EIA) has confirmed that it agrees with the proposal that would require air conditioning and refrigeration equipment to be charged in-situ.

'We tend to agree with the European Commission and the contractors on this particular issue,' said EIA senior campaigner Clare Perry. 'We see the pre-charged ban as necessary to preserve the integrity of the phase-down mechanism, since the phase-down is based on bulk quantities.'

The EIA has other concerns with producing and importing pre-charged equipment within the framework of an HFC phase-down timetable: 'The phase-down is based on reported data,' explains Clare Perry, 'And, since importers of pre-charged equipment did not report under the original F-gas regulation, no concrete information exists for phase-down schedule or allocation purposes.'

The EIA, which continues to carry out investigations into illegal refrigerant smuggling operations worldwide, is also concerned that a failure to enforce a pre-charge ban could encourage an illegal trade to bypass the phase-down mechanism.

'The high number of importers and ports of entry considerably complicates enforcement and compliance and would be wide open to mislabelling and illegal trade,' says Clare Perry.

The EIA also has concerns that a phase-down without a pre-charging ban could create loopholes that would encourage pre-charging abroad or moving production outside the Union to avoid the phase-down. And a pre-charge ban could also have energy efficiency benefits: 'Pre-charged equipment is packaged in standard sizes, meaning that it is not necessarily tailored to the specific application for which it will be used, resulting in the inefficient use of resources and potentially reduced energy efficiency in comparison to equipment charged on site.'