A-Gas Replies to F-Gas Directive Inception Impact Assessment
[September 2020] A-Gas has put forward its ideas to improve the current working of the F-Gas Directive, plus a suggested link through to the recently announced European Green Deal.
In the first part of our submission we offer our solutions to the ‘known’ problems experienced so far within the existing F-Gas Directive, primarily the large-scale illegal trade in virgin HFCs.
Looking to the future, as a long-term participant in the circular economy A-Gas welcomes the policies within the European Green Deal to promote the recovery, reclamation, and re-use of existing products and to reduce waste and pollution. All of these are achievable, along with reducing the need for quantities of virgin products to be manufactured, by incentivising the recovery and reclamation of the substantial quantities of existing refrigerants, which are already on the European market.
By incentivising the greater use of reclaimed refrigerants, the amount of virgin refrigerant required to be put on the market would decrease. This accelerates the existing F-Gas step down phases and along with greater use of all lower GWP refrigerants, would solve the potential imbalance between the Kigali amendment and F-Gas Directive.
As the quantity and value of reclaimed refrigerant increases, its potential to be released to atmosphere diminishes, delivering a substantial emission saving (CO2e decrease). This is then combined with a further emission saving (CO2e decrease) by replacing the need to manufacture, ship and distribute the equivalent quantity of virgin refrigerant, the potential emission saving gets even larger.
Eventually, when there is no further requirement for the older generations of reclaimed refrigerant, these could be included into the existing EU Emissions Trading Scheme, or a similar Green House Gas (GHG) reduction instrument. By adding value to a product at the end of its intended lifespan there is even less reason for the product to be discarded and potentially be emitted to the atmosphere. The need for managed, verifiable and locally produced voluntary carbon reduction instruments will only increase as we aim to be a carbon neutral continent by 2050, as per the European Green Deal ambition.
A-Gas believes combining the important environmental policy initiatives of the European Green Deal to work in harmony with the F-Gas Directive will produce the best outcome for all parties.