COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT Review of Regulation (EC) No 842/2006 on certain fluorinated greenhouse gases Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL on fluorinated greenhouse gases
Date: 2012-11-07
Institutions: European Commission
Subjects: climate change, disclosure of information, environmental monitoring, environmental standard, greenhouse gas, marketing standard, reduction of gas emissions, stratospheric pollutant

EUROPEAN 
COMMISSION 

Brussels, 7.11.2012  
SWD(2012) 364 final 

COMMISSION STAFF WORKING PAPER 

IMPACT ASSESSMENT 
Review of Regulation (EC) No 842/2006 on certain fluorinated greenhouse gases 

Accompanying the document 

Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL 

on fluorinated greenhouse gases 

{COM(2012) 643 final} 
{SWD(2012) 363 final} 

EN 

   EN 

 
 
 
 
  
 
TABLE OF CONTENTS 

1. 

2. 

2.1. 

2.2. 

2.3. 

2.4. 

3. 

3.1. 

3.2. 

3.3. 

Background .................................................................................................................. 1 

Procedural issues and consultation of interested parties .............................................. 3 

Consultations of other Commission Services............................................................... 3 

External expertise ......................................................................................................... 3 

Stakeholder consultation and conference ..................................................................... 4 

Scrutiny by the Commission Impact Assessment Board.............................................. 6 

Problem definition........................................................................................................ 7 

The problem that requires action.................................................................................. 7 

Underlying drivers of the problem ............................................................................... 9 

Evolution of the problem in the EU ........................................................................... 10 

3.4.  Who is affected, in what ways and to what extent? ................................................... 12 

3.5. 

EU right to act ............................................................................................................ 13 

4. 

4.1. 

4.2. 

4.3. 

4.4. 

5. 

5.1. 

5.2. 

5.3. 

5.4. 

5.5. 

5.6. 

5.7. 

6. 

Objectives................................................................................................................... 14 

General policy objectives ........................................................................................... 14 

Specific policy objectives........................................................................................... 14 

Operational policy objectives..................................................................................... 14 

Consistency with other policies and objectives.......................................................... 15 

Policy options ............................................................................................................. 15 

Policy option A: No policy change at EU level (baseline option) ............................. 15 

Policy option B: Voluntary agreements by industry (non-regulatory)....................... 16 

Policy option C: Extended scope of containment measures....................................... 16 

Policy option D: Establishment of a phasedown mechanism for placing HFCs 
on the EU market........................................................................................................ 17 

Policy option E: Bans of production, use or placing on the market of F-Gases 
in certain applications................................................................................................. 19 

Combination of policy options ................................................................................... 20 

Options discarded from further analysis .................................................................... 20 

Analysis of impacts .................................................................................................... 22 

EN 

i 

   EN 

 
6.1. 

Environmental impacts............................................................................................... 22 

6.1.1.  Approach used............................................................................................................ 22 

6.1.2.  GHG emission reductions .......................................................................................... 23 

6.1.3.  Ecotoxicity.................................................................................................................. 25 

6.2. 

Economic impacts ...................................................................................................... 25 

6.2.1.  Abatement costs and direct costs to industry ............................................................. 26 

6.2.2. 

Impacts on sectors ...................................................................................................... 27 

6.2.3.  Administrative costs ................................................................................................... 35 

6.2.4. 

Impacts on regions...................................................................................................... 37 

6.2.5. 

Impacts on the functioning of the internal market and competition........................... 38 

6.2.6. 

Impacts on competitiveness, trade and investment flows .......................................... 38 

6.2.7.  Third countries and international relations................................................................. 42 

6.2.8. 

Impacts on consumer prices ....................................................................................... 43 

6.2.9. 

Impacts on innovation and research ........................................................................... 43 

6.2.10.  Impacts on small and medium enterprises (SMEs: see also Annex III)..................... 44 

6.3. 

Social impacts............................................................................................................. 45 

6.3.1.  Employment impacts and labour market.................................................................... 45 

6.3.2.  Safety, occupational and health risks ......................................................................... 48 

7. 

8. 

Comparing the options ............................................................................................... 49 

Monitoring and evaluation ......................................................................................... 52 

ANNEX I: Glossary of Terms .................................................................................................. 54 

ANNEX II: Stakeholder Consultations .................................................................................... 57 

1. 

1.1. 

1.2. 

1.3. 

1.4. 

1.5. 

Conference Report on Stakeholder Meeting in Brussels, 13 February 2012 ............. 57 

Conference Objectives ............................................................................................... 57 

Summary of Presentations and Interventions............................................................. 57 

Concluding remarks ................................................................................................... 61 

Agenda of meeting ..................................................................................................... 63 

Registered Participants ............................................................................................... 64 

EN 

ii 

   EN 

 
2. 

2.1. 

2.2. 

2.3. 

2.4. 

2.5. 

Executive Summary of the Analysis of the On-Line Stakeholder Consultation........ 70 

Participation................................................................................................................ 70 

Methodology .............................................................................................................. 70 

Policy action addressing F-gas emissions .................................................................. 71 

Impacts of policy options ........................................................................................... 71 

General Conclusions................................................................................................... 72 

ANNEX III: Consultations of SMEs ........................................................................................ 73 

ANNEX IV: Background Information on the Business as Usual Scenario (No Further 
Action – Option A) ................................................................................................................... 79 

1. 

2. 

3. 

4. 

F-Gas Emissions......................................................................................................... 79 

The Model AnaFgas ................................................................................................... 81 

HFC demand and emissions in EU-27 until 2050 for different sectors ..................... 82 

F-Gas sources currently not addressed by EU legislation.......................................... 85 

ANNEX V: Technical Assessment of Environmental Impacts................................................ 86 

1. 

2. 

Emissions for Policy Options B, C, D, E vs. Baseline (Option A) ............................ 86 

Replaced units in each sector As a result of Policy Options B, C, D and E in 
2030 ............................................................................................................................ 91 

ANNEX VI: Assessment of cost impacts on sectors (Competitiveness proofing)................... 93 

1. 

2. 

3. 

4. 

Abatement and direct costs......................................................................................... 93 

Abatement cost curve ................................................................................................. 96 

Investment and Service costs, employment effects.................................................... 96 

Impacts on service companies.................................................................................. 100 

ANNEX VII: Detailed results of Screening of Policy Options .............................................. 102 

1. 

2. 

3. 

Discarded policy options .......................................................................................... 102 

Discarded sub-options of policy options B, C, D and E........................................... 103 

Screening of sub-options for Policy options B, C, D & E........................................ 106 

EN 

iii 

   EN 

 
ANNEX VIII: Sensitivity Analysis of Cost Estimation ......................................................... 124 

1. 

2. 

2.1. 

2.2. 

2.3. 

3. 

3.1. 

3.2. 

3.3 

4. 

4.1. 

4.2. 

4.3. 

General ..................................................................................................................... 124 

Option B "Voluntary agreements in certain HFC applications" .............................. 125 

Effects of prices for unsaturated HFCs .................................................................... 125 

Effects of discount rate............................................................................................. 126 

Conclusions .............................................................................................................. 127 

Option D "Quantitative limits for the Placing on the Market of certain HFCs" ...... 128 

Effects of prices for unsaturated HFCs .................................................................... 129 

Effects of discount rate............................................................................................. 129 

Conclusions .............................................................................................................. 130 

Option E "Ban the placing on the market of certain open and closed 
applications of F-Gases"........................................................................................... 131 

Effects of prices for unsaturated HFCs .................................................................... 132 

Effects of discount rate............................................................................................. 132 

Conclusions .............................................................................................................. 133 

ANNEX  IX: Model Description of the EmIO-F Europe Input-Output model and 
Sensitivity Analysis of Employment impacts......................................................................... 134 

1. 

2. 

3. 

Introduction .............................................................................................................. 134 

The  Input-output model........................................................................................... 134 

Sensitivity analysis of employment impacts ............................................................ 138 

ANNEX X: Mechanism for the Placement of HFCs on the EU Market................................ 141 

1. 

2. 

2.1. 

2.2. 

2.3. 

2.4. 

2.5. 

Introduction and Summary....................................................................................... 141 

Scope ........................................................................................................................ 142 

Coverage of substances ............................................................................................ 142 

HFCs to be specified individually in a list ............................................................... 142 

Considered alternative(s).......................................................................................... 143 

Coverage of mixtures/preparations .......................................................................... 144 

Recovered, recycled and reclaimed HFC ................................................................. 144 

EN 

iv 

   EN 

 
3. 

3.1. 

3.2. 

3.3. 

3.4. 

4. 

5. 

5.1. 

5.2. 

5.3. 

5.4. 

5.5. 

5.6. 

5.7. 

6. 

6.1. 

6.2. 

6.3. 

Activities subject to quantitative restrictions ........................................................... 144 

HFCs in imported equipment ................................................................................... 144 

Options for taking measures on pre-charged equipment.......................................... 153 

Export of products containing HFCs........................................................................ 155 

Sectors covered......................................................................................................... 156 

Reduction schedule for a phasedown for placing HFCs on the market ................... 156 

Implementation mechanism and quota allocation .................................................... 164 

Quota allocation – allocation through grandfathering or auctioning ....................... 164 

Grandfathering or allocation on demand.................................................................. 165 

Determination of the baseline................................................................................... 166 

Treatment of exports ................................................................................................ 166 

Implementation and required data............................................................................ 166 

Transferability of quotas .......................................................................................... 167 

Administrative costs for companies ......................................................................... 168 

Monitoring, reporting and verification..................................................................... 168 

Reporting .................................................................................................................. 168 

Verification............................................................................................................... 170 

Compliance and enforcement ................................................................................... 171 

ANNEX XI: Schedule for the Introduction of Bans .............................................................. 173 

ANNEX XII: Analysis of Administrative Costs .................................................................... 174 

1. 

2. 

3. 

3.1. 

3.2. 

3.3. 

Methodology ............................................................................................................ 174 

Policy Option A: No policy change ......................................................................... 176 

Policy Option B: Voluntary Agreements ................................................................. 176 

Overview of information requirements for the option of voluntary agreements ..... 177 

Annual report on HFC use........................................................................................ 180 

Independent verification of HFC use reports / submission to trade association / 
monitoring institution ............................................................................................... 183 

3.4. 

Annual monitoring report to EU .............................................................................. 184 

EN 

v 

   EN 

 
3.5. 

3.6. 

4. 

5. 

5.1. 

5.2. 

5.3. 

5.4. 

5.5. 

5.6. 

5.7. 

5.8. 

6. 

6.1. 

6.2. 

6.3. 

6.4. 

Communication with stakeholders ........................................................................... 187 

Summary of administrative costs of voluntary agreements ..................................... 189 

Policy Option C: Extended Scope of containment measures ................................... 190 

Policy Option D: Establishment of quantitative limits for placing certain F-
Gases (HFCs) on the EU market (phasedown) ........................................................ 190 

Overview of information requirements for the phasedown option .......................... 190 

PD03 - Registration in F-Gas database .................................................................... 199 

PD04 - Submission of verified baseline report ........................................................ 202 

PD05 - Verification of baseline report ..................................................................... 203 

PD18 - Report (Art. 6) on placing on the market, import & export, reclamation, 
recycling & destruction ............................................................................................ 204 

PD 19 – Verification of Reporting & submission to MS or central authority.......... 206 

PD 30 – Reporting on reclamation and destruction ................................................. 207 

Summary of administrative cost of the phasedown option ...................................... 211 

Policy Option E: Regulatory Bans ........................................................................... 212 

Overview of information requirements for the ban option....................................... 213 

B02 - Carry out audits/inspections ........................................................................... 215 

B 03 – MS reports on implementation ..................................................................... 218 

Summary of administrative cost of the ban option................................................... 220 

ANNEX XIII: Questionnaire assessing Administrative Costs of Stakeholders ..................... 221 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

Introduction .............................................................................................................. 221 

General guidance to the users................................................................................... 222 

Questionnaire addressing companies with experience under the ODS 
Regulation ................................................................................................................ 225 

Questionnaire addressing reclamation and/or destruction facilities currently not 
covered by reporting obligations.............................................................................. 226 

Questionnaire addressing MS authorities with experience in F-Gas bans ............... 227 

Questionnaire addressing MS competent authorities under the ODS regulation..... 228 

Questionnaire addressing companies currently falling under reporting 
requirement in the F-Gas regulation......................................................................... 229 

EN 

vi 

   EN 

 
8. 

Questionnaire addressing trade associations experienced with a voluntary 
agreement (VA) ........................................................................................................ 231 

ANNEX XIV: Macroeconomic Analysis  of F-Gas Policies with GEM-E3 ......................... 233 

1. 

2. 

3. 

Methodology ............................................................................................................ 233 

Scenarios .................................................................................................................. 233 

Detailed results ......................................................................................................... 235 

ANNEX XV: Differences between the EmIO-F and the GEM-E3 model............................. 240 

Annex XVI: State and potential of technology in the different sectors.................................. 241 

1. 

2. 

2.1. 

2.2. 

2.3. 

2.4. 

2.5. 

2.6. 

2.7. 

Common technology by sectors ............................................................................... 241 

The market potential of abatement technology ........................................................ 243 

Selection of sector abatement options ...................................................................... 243 

Energy efficiency ..................................................................................................... 243 

The concept of penetration rates .............................................................................. 243 

Constraints to market penetration............................................................................. 244 

Determination of penetration rates ........................................................................... 246 

Combination of penetration rates (“penetration mix”)............................................. 247 

Key abatement options by sectors ............................................................................ 249 

Annex XVII: Assesment of indirect impacts on sales............................................................ 255 

EN 

vii 

   EN 

 
1. 

BACKGROUND 

Hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur hexafluoride (SF6), 
commonly  called  fluorinated  gases  or  "F-Gases",  are  very  potent  greenhouse  gases 
(GHG)  whose  climate  impact  is  up  to  23.000  times  higher  than  CO2.  Their  emissions 
are  therefore  covered  by  the  Kyoto  Protocol.  Currently,  they  account  for  2%  of  the 
GHGs in the EU. In 2010, 98% (by weight) of F-Gases placed on the EU market were 
HFCs, 2% was SF6 and about 0.3% were PFCs. 

F-Gases  are  commodities used in a large variety of  products  and  equipment  including 
refrigeration, air conditioning (AC), insulation foams, electrical equipment, aerosols and 
fire  protection.  Most  F-Gases  have  been  developed  by  industry  specifically  to  replace 
ozone-depleting  substances  (ODS)  that  are  being  phased  out  under  the  Montreal 
Protocol and for this reason F-Gases are being increasingly used at world-wide scale. 

Whereas  other  GHG  emissions  are  mainly  a  by-product  resulting  from  production 
processes, heating or transport, F-Gas emissions primarily occur either during emissive 
uses  (e.g.  as  aerosol  or  solvent)  or  due  to  leaks  during  the  use  period  and  improper 
waste treatment of products and equipment.1  

In order to limit the rapid growth of F-Gas emissions and contribute to the Kyoto target, 
the EU adopted in 2006  

– 

– 

a Regulation focusing on preventing leakage during use ("containment") and at 
end of life of (mostly) stationary equipment as well as a limited number of F-
Gas  bans  in  narrowly  defined  niche  application  areas  ("F-Gas  Regulation")2, 
and  

a  Directive  introducing  restrictions  on  the  use  of  F-Gases  with  a  global 
warming  potential  (GWP)  above  150  in  AC  systems  of  new  motor  vehicles 
("MAC directive")3.  

There are two ways of reducing F-Gases emissions from equipment and products. First, 
the  use  of  F-Gases  in  applications  can  be  completely  avoided  or  replaced  by  F-Gases 
with a lower GWP and secondly, emissions during the use period or at the end of life of 
products and equipment can be reduced. Except for the MAC Directive, which focuses 
on AC in new passenger cars only, existing EU F-Gas legislation barely discourages the 
use of highly climate-relevant F-Gases. On the other hand, alternative substances to F-
Gases  can  be  used  in  nearly  all  fields  of  application  and  are  readily  available  already 
today.4,5  Annex  XVI  gives  a  sector-by-sector  overview  over  available  alternative 

1 

2 

3 

4 

With the exception of e.g. HFC-23 (Trifluoromethane), which is formed as by-product of HCFC-
22 (Chlorodifluoromethane) synthesis 
Regulation (EC) No 842/2006 on certain fluorinated greenhouse gases, OJ L161, 14.6.2006,  p. 1 
("F-Gas Regulation") 
Directive 2006/40/EC of the European Parliament and of the Council of 17 May 2006 relating to 
emissions from AC systems in motor vehicles, OJ L161, 14.6.2006, p. 12 ("MAC-Directive") 
Becken  et  al.  (2010).  "Avoiding  Fluorinated  greenhouse  gass  -  Prospects  for  Phasing  Out." 
Umweltbundesamt. Dessau, Germany. www.umweltbundesamt.de/uba-info-medien-e/3977.html 

EN 

1 

   EN 

 
                                                 
technologies and by what time 100% of applications in each sector can be fully replaced 
by safe and energy-efficient alternatives based on today`s technologies.6 

In  some  Member  States  national  legislation  exists.  By  way  of  example,  the  Danish 
legislation bans the use of F-Gases for certain purposes and includes F-Gas taxation and 
support for R&D of alternative technology. As a result, the import of bulk F-Gases was 
reduced to a third between 2000 and 2010 and Danish emissions of F-Gases have been 
declining in recent years, while emissions are rising at EU level.7 Austria has similarly 
maintained additional bans on specific appliances using HFCs. 

In  September  2011  the  Commission  published  a  report  on  the  application,  effects  and 
adequacy of the existing F-Gas Regulation8. It concluded that there is scope for further 
action to reduce emissions from F-Gases in the EU, in particular by avoiding the use of 
F-Gases  where  alternative  technologies  with  no  or  lower  impact  on  climate  change 
exist. A decrease of up to two-thirds of today's emissions by 2030 is cost-effective due 
to  the  availability  and  maturity  of  alternatives  in  many  sectors.9  However,  policies  in 
this area have to address a high level of complexity. Apart from taking into account the 
large  variety  of  products  and  equipment  using  F-Gases,  the  feasibility  and  cost-
effectiveness  of  reducing  emissions  in  specific  application  areas  may  depend  on  e.g. 
equipment size and where it is intended to be used. In this context energy efficiency and 
safety require particular attention. 
In  September  2011  the  European  Parliament  adopted  a  Resolution10  stating  that  "fast-
action regulatory strategies are available  to  phase down production and consumption 
of  HFCs  [..]"  and  urged  the  "Commission  to  come  forward  with  a  revision  of  F-Gas 
regulations  and  make  proposals  for  a  rapid  phasedown  of  the  production  and 
consumption of HFCs". In March 2012 this position was reaffirmed in the Parliament's 
resolution11  on  the  2050  Roadmap,  calling  for  an  ambitious  proposal  to  reduce 
emissions of F-Gases by the end of 2012. 

The  EU  is  clearly  at  the  forefront  internationally  as  regards  the  phasing  out  of  ODS 
under  the  Montreal  Protocol  and  in  addressing  the  resulting  F-Gas  problem  through 
legislation. However, the EU is not at all alone in calling for urgent action on F-Gases: 
In 2009, 2010, 2011 and 2012 several Parties to the Montreal Protocol including the US 

5 

6 
7 

8 

9 

10 

11 

TEAP (2009). "Assessment of alternatives to HCFCs and HFCs and update of the TEAP 2005 
supplement report data". Montreal Protocol. Report of the Technical and Economic Assessment 
Panel (TEAP). UNEP, Nairobi.  
ozone.unep.org/teap/Reports/TEAP_Reports/teap-may-2009-decisionXX-8-task-force-report.pdf  
Furthermore, costs of introducing alternatives are given in Annex VI 
Danish  Ministry  of  the  Environment:  Environmental  Protection  Agency.  "Denmark  is  going 
natural – The Danish road towards natural refrigerants." Brochure, 2011. 
COM (2011) 581 final. "Report from the Commission on the application, effects and adequacy of 
the Regulation on certain fluorinated greenhouse gases (Regulation (EC) No 842 /2006)" 
Schwarz  et  al.  (2011)  "Preparatory  study  for  a  review  of  Regulation  (EC)  No  842/2006  on 
certain fluorinated greenhouse gases." Öko-Recherche et al.  
European  Parliament  Resolution  of  14  September  2011.  "A  comprehensive  approach  to  non-
CO2 climate-relevant anthropogenic emissions." P7_TA-PROV(2011)0384. 
European Parliament resolution of 15 March 2012. "Competitive low carbon economy in 2050 – 
EP  resolution  on  a  Roadmap  for  moving  to  a  competitive  low  carbon  economy  in  2050" 
(2011/2095(INI)), P7_TA-PROV(2012)0086 

EN 

2 

   EN 

 
                                                                                                                                               
 
submitted proposals to phasedown supply and consumption of HFCs globally, which is 
supported  by  at  least  108  countries12.  Such  action  is  projected  to  avoid,  in  a  cost-
effective  way,  more  than  100  Gigatonnes  of  CO2  equivalents  (CO2eq)  by  205013.  For 
perspective, this cumulative figure is roughly 3-4 times the total annual anthropogenic 
CO2  emission  at  this  point  in  time.  The  EU  has  supported  these  proposals  as  a 
complement  to  climate  mitigation  action  under  the  United  Nations  Framework 
Convention on Climate Change (UNFCCC).14 So far little progress has been achieved in 
the  negotiations  since,  inter  alia,  China,  India  and  Brazil  have  refused  to  discuss  this 
issue under the Montreal Protocol. However, recently a new  initiative called "Climate 
and Clean Air Coalition to Reduce Short-Lived Climate Pollutants" has been launched 
which calls for action on HFCs as one of five priority focal areas and is quickly gaining 
momentum.15  This  initiative  has  been  joined/endorsed  so  far  by  Bangladesh,  Canada, 
Colombia, Ghana, Japan, Mexico, Nigeria, Norway, Sweden, the USA, as well as EC, 
World  Bank,  UNEP  and  most  recently  the  G8  countries.  More  countries  have  already 
expressed their interest in joining. 

2. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  

2.1. 

Consultations of other Commission Services  

This  Impact  Assessment  for  the  review  of  the  F-Gas  Regulation  (Agenda  Planning 
2012/CLIMA/003)  was  developed  by  DG  CLIMA  in  close  co-operation  with  relevant 
Commission  Services.  The  following  DGs  were  invited  to  an  Interservice  Steering 
Group:  COMP,  EMPL,  ENER,  ENTR,  ENV,  JRC,  LS,  MOVE,  RTD,  SANCO,  SG, 
TAXUD  and  TRADE.  This  group  met  eight  times  from  April  2010  to  March  2012 
where  it  provided  input  to  a  preparatory  study  as  well  as  the  follow-up  work  and  the 
drafting  of  the  impact  assessment.  DG  JRC  was  asked  to  carry  out  a  comprehensive 
macro-economic  analysis  of  possible  policy  options  with  the  GEM-E3  model  (Annex 
XIV).  The  final  meeting  on  the  draft  Impact  Assessement  on  29  March  2012  was 
attended  by  CLIMA,  ENER,  ENTR,  JRC  and  SG.  Written  comments  to  this  meeting 
were provided by SANCO and TRADE. 

2.2. 

External expertise 

DG CLIMA commissioned the following studies to underpin the review: 

(1) 

12 
13 

14 

15  

A comprehensive study was carried out by a consortium led by Öko-Recherche 
("preparatory  study").9  This  study  inter  alia  assessed  the  effectiveness  of 
current policies, the feasibility and cost-effectiveness of the replacement of F-
Gases in all main application areas (see Annex XVI), and discussed options for 
further  action  to  reduce  F-Gas  emissions.  The  analysis  was  based  on  a 

ozone.unep.org/Meeting_Documents/mop/22mop/MOP-22-9E.pdf   
Velders  et  al.  (2009).  "The  large  contribution  of  projected  HFC  emissions  to  future  climate 
forcing." Proceedings of the National Academy of Sciences 106(27): 10949-10954. 
Council Conclusion from 10 October 2011 on Preparations for the COP17 to the UN Framework 
Convention on Climate Change and MOP7 of the Kyoto Protocol in Durban. 
www.unep.org/ccac/ 

EN 

3 

   EN 

 
                                                 
thorough bottom-up analysis, involving the development of a model based on 
market  data,  including  production,  import,  exports  and  sales,  for  both 
substances and products/equipment (referred to as AnaFgas model, Annex IV). 
The study assumes a conservative approach using today`s costs for alternatives 
and considering only available, safe and energy-efficient technologies. Future 
reductions in investment costs that are expected from economies-of-scale and 
learning-by-doing  were  not  factored  into  the  analysis.  This  study  forms  the 
main evidence base for this impact assessment. 

As  a  follow-up  to  the  preparatory  study,  a  consortium  led  by  Öko-Institut 
assisted DG CLIMA in further refining the social and economic effects of the 
most promising policy options considered for a review, and examining in more 
detail the possible design of the option to set quantitative limits for the placing 
on the market of F-Gases in the EU.   

A complementary study on policy options for the management and destruction 
of  ozone-depleting  substances  and  F-Gases  contained  in  equipment  and 
products (so-called "banks") was carried out by SKM ENVIROS.16 

(2) 

(3) 

Three other large and relevant studies by other parties were used for the drafting, thus 
reinforcing the validity of the results presented in this document. A study commissioned 
by EPEE (a European umbrella group representing members who produce, design and 
technologies),  was  carried  out  by 
install  heating,  cooling  and  refrigeration 
Armines/ERIE17 and estimated the timeframe and feasibility of introducing gases with 
lower GWP. Secondly, a study published by the German Umweltbundesamt4 examined 
the  availability  of  alternatives  and  their  appropriateness  in  the  individual  sectors. 
Finally,  the  Technical  and  Economic  Assessment  Panel  (TEAP)  of  the  Montreal 
Protocol published a report5 on the assessment of alternatives at global level. 

In addition, DG CLIMA set up an expert group consisting of 47 experts from different 
industrial  sectors  (24  high-level  representatives),  Member  States  (20  nominated  a 
representative),  and  NGOs  (3)  to  provide  guidance  and  technical  input  to  the 
preparatory  study.  The  group  met  twice  between  October  2010  and  May  2011  and 
provided written advice to DG CLIMA in the preparatory phase of the review. 

2.3. 

Stakeholder consultation and conference 

An internet-based consultation was open to individuals and organisations on the website 
of DG CLIMA from 26th September to 19th December 2011. 261 replies were obtained, 
of which 164 came from organisations. 75% of the latter were related to industry (see 
Fig.1).  Less  than  2%  of  these  stakeholders  chose  the  option  "no  further  action"  in 

16 

17 

SKM Enviros (2012). "Further assessment of policy options for the management and destruction 
of banks of ODS and F-Gases in the EU"  
http://ec.europa.eu/clima/policies/ozone/research/docs/ods_f-gas_destruction_report_2012_en.pdf 
Clodic et al. (2011). "1990 to 2010 Refrigerant inventories for Europe - Previsions on banks and 
emissions from 2006 to 2030 for the European Union." Armines/ERIE  
http://www.epeeglobal.org/refrigerants/F-Gas-review/ 

EN 

4 

   EN 

 
 
                                                 
 
 
response  to  a  question  on  the  most  appropriate  action  at  EU  level  to  contribute  to 
reducing GHG emissions in the absence of global action on HFCs. 

Fig. 1: Respondents to the on-line stakeholder consultation representing organisations  

The findings of the consultation were presented at an open stakeholder conference18 on 
13 February 2012, which was attended by over 130 participants from industry, Member 
States, NGOs and the European Parliament. This meeting gave participants ample time 
and  opportunity  to  deliver  feedback  and  state  their  views  regarding  options  for 
reviewing the Regulation. Almost all stakeholders agreed there was a need for further 
action on F-Gases compared to the status quo. A large majority of industry preferred or 
could live with a phasedown of supply of F-Gases as it would allow industry flexibility 
in  cases  where  alternative  technologies  were  not  considered  suitable.  Bans  were 
considered to be too rigid by those industry players relying on F-Gas technology, while 
NGOs  and  industrial  participants  engaged  in  alternative  technologies  considered  cost-
effective  bans  to  be  essential  and  saw  a  phasedown  as  a  complementary  measure  to 
bans.  A  few  participants  preferred  to  focus  on  better  application  of  the  current 
Regulation only. Member States had no official positions yet, but indicated support for a 
phasedown  measure  (see  Annex  II).  The  consultations  involved  a  large  number  of 
organisations  and  umbrella  groups.  At  least  47  stakeholders  out  of  161  consulted 
represented  the  views  of  SMEs  (see  Annex  III).  Industrial  users  of  F-Gas  equipment 
such as FoodDrinkEurope, representing  many SMEs,  wanted reassurance  that existing 
equipment is not made redundant. 

18 

http://ec.europa.eu/clima/events/0049/index_en.htm 

EN 

5 

   EN 

 
 
 
                                                 
Subsequently,  a  number  of  European  Protection  Agencies  have  positioned  themselves 
on the review, considering that the preparatory study8 is an appropriate basis for further 
action,  especially  as  energy  efficiency  and  economic  impacts  are  already  taken  into 
account in the analysis. They recommend a mixture of measures based on a phasedown 
drawing on the experience of the ODS phase-out, and additional bans.19 

Given these extensive consultations and expert involvement, DG CLIMA exceeded the 
European Commission's minimum consultations standards in the process of drafting this 
Impact Assessment.  

2.4. 

Scrutiny by the Commission Impact Assessment Board 

The Impact Assessment Board of the European Commission assessed a draft version of 
the  present  impact  assessment  and  issued  its  opinion  on  25/05/2012.  The  Impact 
Assessment  Board  made  several  recommendations  and,  in  the  light  of  the  latter,  the 
final impact assessment report: 

– 

– 

– 

– 

Describes the wider policy context in more detail, in particular as regards the 
context  of  the  roadmap  (see  section  3.1),  the  alternatives  available  (see  1  & 
Annex XVI), the most affected interests (see e.g. 3.4, 6.2.2 and summary table 
7), as well as the international context (see 1); 

Clarifies  the  objectives  and  their  link  to  concrete  monitoring  indicators  (see 
4.3, 8); 

Gives  more  detail  on  the  policy  options  (section  5.1-5.5),  especially  the 
mechanism of a phasedown (see 5.4, Annex X);  

Clarifies  the  assessment  of  impacts  on  competitiveness,  SMEs,  consumers, 
employment,  health  and  safety,  as  well  as  the  effects  on  market  players, 
distributional  and  regional  effects  i.e.  by  providing  more  detail  on  costs  by 
sector  in  section  6.2.2  and  Table  3,  by  extending  the  competitiveness  impact 
section  6.2.6  and  addressing  price  impacts  for  consumers  for  the  affected 
products; 

– 

Adds views of stakeholders throughout the text. 

19 

Letter  of  European  Network  of 
Commissioners Potoçnik, Heedegaard, Tajani, and Öttinger. 15. Mai 2012 

the  Heads  of  Environment  Protection  Agencies 

to 

EN 

6 

   EN 

 
 
                                                 
3. 

PROBLEM DEFINITION  

3.1. 

The problem that requires action 

The 4th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) 
stated that developed countries would need, on the basis of existing science, to reduce 
GHG emissions by 80 to 95% below 1990 emissions by 2050 to achieve the objective of 
limiting  global  climate  change  to  a  temperature  increase  of  2˚C  and  thus  avoid 
undesirable climate effects.20 To reach this target, the European Commission (EC) has 
laid out a cost-effective pathway to achieve the necessary overall emission reductions in 
the  EU  by  2050.21  This  low  carbon  roadmap  establishes  the  necessary  sectoral 
contributions in 6 areas consistent with an 80% EU reduction in GHG in 2050 on the 
basis of 1990, namely the power sector, residential & tertiary, industry, transport, non-
CO2 agriculture and other non-CO2 sectors. To achieve the climate objective at lowest 
costs, non-CO2 emissions (including  F-gases but excluding non-CO2 from agriculture) 
should be reduced between 72-73% by 2030 and 70%-78% in 2050, compared to 1990 
levels. If based on the reference year 2005, the roadmap requires a reduction in non-CO2 
emissions (except agriculture) of 60-61% by 2030.22 F-gases emissions were estimated 
at 90 Mt CO2eq in 2005 (see Annex IV). A 60% reduction implies that emissions would 
have to be reduced to a level of 35 Mt CO2eq by 2030. Given estimated levels of 104 
Mt CO2eq emission in 2030 based on a full application of current legislation, this would 
mean a further decrease of ca. 70 Mt CO2eq is required. The roadmap shows that to be 
cost-effective  the  marginal  costs  of  abating  emissions  should  not  be  higher  than  ca. 
€50/t CO2.23  

F-Gases, generally, are very potent GHGs with high to very high GWPs of up to several 
thousand  times  that  of  CO2.24  F-Gases  are  used  in  a  large  variety  of  products  and 
equipment  including  refrigeration,  AC,  foams,  electrical  equipment,  aerosols  and  fire 
protection (Fig. 2); there are 28 diverse main application areas (Fig. 6).  

20 

21 

22 

23 

24 

IPCC, 4th Assessment Report, Climate Change 2007: Working Group III: Mitigation of Climate 
Change, chapter 13.3.3 Proposals for climate change agreements, box 13.7. Scenario category 
for greenhouse gas concentration levels of 450 ppm CO2 eq. 
http://www.ipcc.ch/publications_and_data/ar4/wg3/en/ch13.html  
COM (2011) 112final: "A roadmap for moving to a competitive low carbon economy in 2050." 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52011DC0112:EN:NOT  
See  Table  17,  page  79  of  Impact  Assessment  "A  roadmap  for  moving  to  a  competitive  low 
carbon economy in 2050.  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SEC:2011:0288:FIN:EN:PDF . 
See  Table  31,  page  117  of  Impact  Assessment  "A  roadmap  for  moving  to  a  competitive  low 
carbon economy in 2050.  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SEC:2011:0288:FIN:EN:PDF . 
IPCC,  4th  Assessment  Report,  Climate  Change  2007,  chapter  2.10.2:  Direct  GWPs. 
http://www.ipcc.ch/publications_and_data/ar4/wg1/en/ch2s2-10-2.html 

EN 

7 

   EN 

 
                                                 
Fig. 2:  Sectors using F-gases in new equipment/products in the EU. 2010 data reported under 

the F-Gas Regulation 

Fig. 3:   Global estimated consumption of HFCs in CO2eq by various sectors. Rapid growth after 
1990  is  clearly  evident.  HFCs  constitute  the  largest  quantitative  percentage  of  all  F-
Gases. Source: UNEP25 

EN 

8 

   EN 

 
 
 
 
 
 
With  the  successful  phase-out  of  ODS,  the  production  and  use  of  F-Gases  as  ODS 
replacements has been growing strongly in recent years (see Fig. 3 for HFCs, the 
bulk  of  F-Gases)  and  will  eventually  lead  to  considerable  emissions  into  the 
atmosphere, with the potential to substantially influence climate in the future.25 To 
better appreciate the significance: Future HFC emissions could be equivalent to 18-45% 
of CO2 emissions  based  on  the  IPCC's  "450ppm  CO2 emissions  pathway"-scenario  by 
2050.25 Since equipment and products containing F-Gases have a long lifetime of up to 
50  years  (e.g.  building  insulation  foams),  a  lack  of  public  intervention  today  would 
result in higher emissions up to several decades into the future.  

In 2010, emissions from F-gases in the EU were estimated to be ca. 110 million tonnes 
(Mt)  CO2eq8,  corresponding  to  ca.  2%  of  all  GHG  emissions.  Alternatives  to  F-Gases 
exist  in  many  applications4,5,  at  costs  well  below  50€  per  tonne  CO2  abated9  (Annex 
XVI). In fact, 95% of the overall reduction potential of HFCs (without motor vehicles) 
can  be  reached  at  abatement  costs  lower  than  20€  per  tonne  CO2.  Analysis  shows 
further that F-Gas emissions could be reduced cost-efficiently by more than two-thirds 
by 20309 (see also Fig. 7 below), which would amount to cumulated emission savings 
of  ca.  625  Mt  CO2eq.  in  the  period  from  2015  until  2030.26  If  reductions  in  F-Gas 
emissions  will  not  contribute  to  the  EU  2050  climate  targets  in  a  consistent 
manner, the EU will either risk missing these targets altogether or would have to 
require  more  expensive  emission  reductions  in  other  industrial  sectors.  A  two-
thirds  reduction  of  emissions  by  2030  would  also  be  fully  compliant  with  proposals 
made  in  the  international  context  of  the  Montreal  Protocol  by  Micronesia  and  North-
American  states  (US,  Canada,  Mexico),  thus  preparing  Europe  for  a  potential 
international  agreement.  EU  action  on  F-Gases  would  also  strongly  support  recent 
climate action at international level promoted by the "Climate and Clean Air Coalition 
to Reduce Short-Lived Climate Pollutants".  

3.2. 

Underlying drivers of the problem 

– 

– 

25 

26 
27 
28 
29 

Phasing  out  of  ozone-depleting  substances  (ODS)  under  the  Montreal 
Protocol:  In  order  to  phase-out  ODS,  the  Montreal  Protocol  controls  their 
production  and  consumption.  As  the  choice  of  alternatives  to  ODS27  is  not 
regulated,  a  shift  towards  the  production  and  use  of  F-Gases  is  taking  place 
world-wide.  

Increasing use of F-Gas containing equipment and products: The most relevant 
uses  for  F-Gases  are  in  refrigeration  &  AC  (RAC28),  foams,  aerosols  and 
electrical equipment.29 Many of these application areas, in particular the RAC, 

UNEP (2011). "HFCs: A critical link in protecting climate and the ozone layer."  
http://www.unep.org/dewa/Portals/67/pdf/HFC_report.pdf 
Based on AnaFGas (Schwarz et al., 2011; cited in footnote No. 9) 
ODS are also very strong climate gases with high GWPs 
RAC includes heat pumps. 
European Commission (2011). "Factsheet: EU statistics on fluorinated greenhouse gases 2010." 
DG CLIMA.  http://ec.europa.eu/clima/policies/F-Gas/docs/statistical_factsheet_2011_en.pdf 

EN 

9 

   EN 

 
                                                 
 
– 

– 

are expected to grow strongly in the future9,30. This higher demand is a result of 
economic  growth  and  increasing  life  standards,  a  strive  for  energy  efficiency 
(e.g.  heat  pumps,  foams)  and,  in  the  developing  countries,  also  population 
growth.25,31  

Today`s  use  are  the  emissions  of  the  future:  F-Gases  are  used  in  appliances 
such as RAC equipment that have ordinary lifespans of 10-20 years for smaller 
and  20-30  years  for  larger  systems,  throughout  which  leakage  may  occur,  as 
well as at the end-of-life treatment. Typical leak rates for larger equipment are 
5-15%  per  year  (but  smaller  for  hermetically  sealed  equipment  such  as 
domestic  fridges:  <1%  per  year).  Foams  have  lifetimes  of  15  (if  used  in 
domestic  appliances)  to  50  years  (for  building  insulation),  and  emissions 
usually occur at end-of-life and thereafter (e.g. from waste dumps). Recovery 
of  F-gases  from  foams  is  rather  costly.  The  use  of  F-Gases  in  aerosols,  as 
solvents and in electrical equipment mostly does not create significant banks of 
potential  emissions.  Use  in  fire  equipment  does  create  banks  but  leakage  is 
very tightly controlled due to safety regulations.16 

Demand for and innovation of alternative technologies is hampered by market 
failures:  Climate  effects  of  F-Gases  are  not  factored  into  the  price.  Industry 
requires  a  clear  signal  in  order  to  switch  towards  investments  into  alternative 
technologies  (and  to  invest  into  R&D  where  still  needed).  Demand  increase 
would  also  lead  to  economies  of  scale  for  alternative  equipment.  The  current 
absence  of  a  clear  regulatory  signal  leads  to  a  lower  market  penetration  of 
green products than would be optimal from a societal perspective. 

3.3. 

Evolution of the problem in the EU 

F-Gas  emissions  can  be  prevented  by  avoiding  their  use  in  the  first  place  and/or  by 
reducing losses during the lifetime and at the end of life of F-Gas containing equipment. 
The current F-Gas Regulation mainly focuses on the latter. It includes provisions on  

– 

– 

– 

– 

– 

30 

31 

containment  (preventing  leakage  of  F-Gases  from  stationary  equipment)  and 
recovery of F-Gases from end-of-life equipment (Art. 3/4); 

training and certification requirements for personnel handling F-Gases (Art. 5); 

reporting in order to monitor the sales of F-Gases (Art. 6); 

labelling of equipment containing F-Gases (Art. 7); and 

bans  and  market  restrictions  in  a  few  niche  areas  where  superior  alternatives 
were already common place (Art. 8 and 9). 

US-EPA (2011). "Global Anthropogenic Non-CO2 greenhouse gas Emissions: 1990-2030." EPA 
430-D-11-003. U.S. Environmental Protection Agency, Washington D.C. 
EEA  (2012).  "Annual  European  Union  greenhouse  gas  inventory  1990–2010  and  inventory 
report  2012".  Technical  report  No  3/2012.  http://www.eea.europa.eu/publications/european-
union-greenhouse-gas-inventory-2012  

EN 

10 

   EN 

 
                                                 
The  report8  on  the  application  of  the  F-Gas  Regulation  showed  that,  while  these 
measures  have  the  potential  to reduce emissions, there are unfortunately shortcomings 
in  the  current  application  of  the  training  and  certification  as  well  as  the  containment 
provisions,  while  compliance  with  Art.  6,  7,  8  and  9  was  found  to  be  satisfactory  or 
better.  Training  and  certification  apply  to  approximately  600,000  persons  and  66,000 
companies (of which 98% in the RAC sector), posing a challenge to Member States to 
swiftly implement the necessary vocational training and certification systems in a timely 
manner,  especially  where  such  systems  had  not  existed  previously.  Consequently,  in 
some  sectors  more  than  50%  of  personnel  and  companies  had  not  been  certified  by  4 
July  2011.  Compliance  by  companies  with  the  schedules  for  leakage  checks  and  the 
obligation to install leakage detection systems was found to be unsatisfactory, as there 
was  low  awareness  among  operators  due  to  deficiencies  in  enforcement.  However,  it 
must  be  noted  that  many  of  these  shortcomings  may  be  considered  initial  effects, 
especially since some requirements became applicable only in 2011, allowing little time 
for  proper  application.  There  is  also  a  growing  potential  for  recovery  from  systems 
containing  F-gases  in the coming years, as such  systems  will  be  reaching  their  end  of 
life.  In  the  stakeholder  consultation,  84%  of  respondents  expressed  the  view  that  the 
current  status  quo  of  implementing  the  existing  regulation  was  not  sufficient.  While 
some stakeholders believed that better implementation would suffice, others wanted to 
see further legal action.  

The  MAC  Directive  introduced  restrictions  on  the  use  of  F-Gases  with  a  GWP  above 
150 in mobile AC of new passenger cars. In other sectors, current legislation does little 
to  support  an  increased  use  of  viable  alternatives  to  F-Gases  in  new  products  and 
equipment. 

Potentially, considerable emission reductions are achievable through the existing F-Gas 
Regulation  and  MAC  Directive.8  Assuming  full  application  of  the  two  pieces  of 
legislation, the total emissions of F-Gases would stabilise around today's level of 110 
Mt CO2eq in the EU-27 as a result of existing EU policy (Fig. 4, solid line). Without 
any legislation, F-Gases emissions in the EU would grow to over 200 Mt CO2eq in 2050 
(Fig.  4:  dotted  line),  almost  doubling  today's  levels  (see  Annex  IV  for  details). 
However,  the  observed  shortcomings  in  the  application  of  the  F-Gas  Regulation  risk 
undermining  these  projected  benefits  and,  if  not  sufficiently  addressed,  could  lead  to 
forfeiting 38 Mt CO2eq of cost-efficient emission reductions, ending up at ca. 150 Mt 
CO2eq  in  2050.  While  it  is  important  to  step  up  efforts  to  ensure  full  compliance, 
observed  low  compliance  on  existing  containment  measures  is  a  further  argument  for 
also reducing use of F-Gases in equipment in the first place. 
Furthermore, the SKM study16 on F-Gas banks concluded that switching to alternatives 
is  key  to  addressing  F-Gas  emissions  in  the  waste  stream.  Although  improved 
implementation  of  waste  legislation  can  contribute  to  emission  reductions,  it  can  only 
address an overall small proportion of the problem and cannot substitute for measures 
addressing the origin of the problem. 

EN 

11 

   EN 

 
 
Fig. 4:   Projections of F-Gas emissions in the EU with and without the measures in the F-Gas 

Regulation and the MAC Directive. Source: Schwarz et al. (2011)9 

Last  but  not  least,  a  full  application  of  the  current  F-Gas  Regulation  would  at  best 
achieve a stabilisation of emissions, which is fully insufficient to reach the EU's climate 
goals requiring a fair share reduction in the F-Gas sector of 60% by 2030, compared to 
2005. Nor would the current Regulation be anywhere near sufficient if an international 
agreement to phase down F-Gases is reached, on the basis of the proposals currently on 
the  table.  Therefore,  action  to  complement  the  existing  measures  in  the  F-Gas 
Regulation is absolutely essential. 

3.4.  Who is affected, in what ways and to what extent?  

– 

– 

– 

32 

33 

Climate change affects everybody. During the first ten years of this millennium 
temperatures  were  the  highest  ever  recorded,  confirming  the  finding  of  the 
IPCC  that  total  temperature  increased  already  by  0.76°C  from  1850–1899  to 
the  period  2001–200532.  Evidence  is  rising  strongly  that  a  warming  of  the 
climate results in more frequent and more intense "extreme weather events".33 

The overall economy and non-F-Gas European industries may suffer a loss of 
price competitiveness if they must abate emissions at higher costs than possible 
within the F-Gas sector. 

Too  little  innovation  and  market  penetration  of  alternative  technologies 
represent a missed opportunity to stimulate innovation, green jobs and growth. 

IPCC,  4th  Assessment  Report,  Climate  Change  2007:  Working  Group  I,  Summary  for 
Policymakers. 
IPCC,  4th  Assessment  Report,  Climate  Change  2007:  Working  Group  II,  Summary  for 
Policymakers. 

EN 

12 

   EN 

 
 
 
                                                 
– 

– 

Many  of  these  "green  growth"  companies  are  SMEs34,  who  find  it  hard  to 
market their products under current market conditions (see Annex II).    

The F-Gas sector comprises a number of different market players who may be 
affected  in  different  ways  by  any  policy  changes;  these  players  include 
producers of F-Gas, manufacturers of equipment, electricity companies, service 
companies,  importers  and  exporters,  users  of  equipment,  the  retail  sector  and 
raw  material  sectors  (e.g.  metals  and  products).  Currently,  industrial  sectors 
relying on F-Gases are affected in different ways. While producers of F-Gases 
and  of  equipment  and  products  are  only  to  a  very  limited  extent  subject  to 
restrictions  related  to  F-Gases,  users  of  F-Gas  equipment  are  subject  to  the 
containment  requirements.  If  more  alternative  technologies  were  deployed, 
end-users of equipment could in several cases have lower costs overall e.g. for 
small industrial refrigeration, which is relevant for SMEs in particular.  

Emissions  from  F-Gases  are  covered  by  the  "Effort  Sharing  Decision" 
establishing  annual  binding  GHG  emission  targets  for  Member  States  for  the 
period  2013–2020.  Some  Member  States  consider  that  the  current  EU 
legislation does not provide sufficient tools to ensure cost-effective reductions 
of  F-Gas  emissions.  Therefore,  several  Member  States  have  adopted  national 
laws  that  are  more  stringent  than  the  EU  legislation,  e.g.  in  Austria  and 
Denmark  the  use  of  F-Gases  for  certain  purposes  is  prohibited.  While  such 
prohibitions  have  driven  innovation,  unilateral  action  is  not  favoured  by 
business and may pose challenges, in particular for SMEs. 

3.5. 

EU right to act 

The right for the Union to act in this field is set out in Articles 191 and 192 of the Treaty 
on the Functioning of the European Union (TFEU) which in Article 191 explicitly refers 
to  the  objective  of  combating  climate  change  as  part  of  the  Union  policy  on  the 
environment.  

Action  in  this  field  also  respects  the  principle  of  subsidiarity.  Climate  change  is  a 
transnational  issue  and  since  the  EU  has  a  common  emission  reduction  target,  Union-
wide  action  is  necessary.  Such  action  can  better  be  taken  at  EU  level  compared  to 
diverse  actions  taken  at  Member  State  level,  thereby  achieving  a  high  degree  of 
environmental protection while also taken into account the need to minimise distortions 
in  the  internal  market  by  introducing  a  level-playing  field  for  all  enterprises  affected. 
Where  appropriate  the  right  of  Member  States  is  preserved  to  implement  some 
provisions,  such  as  the  training  and  certification  requirements  or  penalties,  through 
provisions at Member State level taking into account their national circumstances. 

34 

Shecco  (2012).  "GUIDE  2012:  Natural  refrigerants  –  market  growth  for  Europe". 
http://guide.shecco.com/ 

EN 

13 

   EN 

 
                                                 
4. 

OBJECTIVES  

4.1. 

General policy objectives 

It  is  the  general  objective  of  this  initiative  to  contribute  significantly  to  meeting  the 
global  challenge  of  keeping  climate  change  below  2º  C  of  pre-industrial  levels  by 
reducing GHG emissions in the EU by 80 to 95% in 2050 compared to 1990. This target  
correspond to the necessary reduction levels identified by the Intergovernmental Panel 
on  Climate  Change  (IPCC)  for  developed  countries  and  was  endorsed  both  by  the 
Council and the European Council as the EU 2050 emission reduction target.  

4.2. 

Specific policy objectives 

It  is  the  specific  objective  of  this  initiative  to  contribute  to  the  achievement  of  the  EU 
2050 reduction target by reducing CO2eq-emissions from F-Gases in the EU, in particular 
by: 

– 

– 

– 

– 

– 

– 

discouraging  the  use  of  F-Gases  with  high  GWP  in  the  EU  where  suitable 
alternatives exist; 

encouraging the use of alternative substances or technologies when they result 
in  lower  GHG  emissions  without  compromising  safety,  functionality  and 
energy efficiency, and achieving higher market shares for these technologies; 

preventing leakage from equipment and proper end of life treatment of F-Gases 
in applications; 

facilitating  convergence  towards  a  potential  future  agreement  to  phase  down 
HFCs under the Montreal Protocol; 

enhancing  sustainable  growth,  stimulate  innovation  and  develop  green 
technologies  by  improving  market  opportunities  for  alternative  technologies 
and gases with low GWP; 

creating  efficient  and  proportionate  mechanisms 
the 
environmental objectives while limiting any undesirable effects on SMEs and 
employment,  the  administrative  burden  for  companies  and  authorities,  the 
abatement costs per tonne CO2 and preserving the competition in the Internal 
Market, to the extent possible.  

reaching 

for 

4.3. 

Operational policy objectives 

Consistent with the specific and general objective, the operational objective is to reduce F-
Gas emissions in the EU by 60% in 2030 compared to 2005.  

A second operational objective is to do so in a cost-effective manner by taking consistent, 
and  cost-efficient  measures  (up  to  a  maximum  of  50€/t  CO2eq),  at  reasonable  costs  to 
industry and with minimum administrative effort.  

In  addition,  an  upgrading  of  the  existing  legislation  through  clarifications  as  well 
improving  the  enforceability  of  legislation  should  contribute  to  achieving  better 
implementation  and  application  of  the  legislation  and  contribute  to  achieving  the 
objectives above.  

EN 

14 

   EN 

 
4.4. 

Consistency with other policies and objectives 

The objectives of this initiative are consistent with and reinforce the following policies 
and objectives: 

– 

– 

– 

– 

– 

– 

The  required  emission  reductions  are  consistent  with  the  pathway  outlined  in 
the  2050  EU  Low  Carbon  Roadmap.  The  selected  sub-options  are  also  cost-
effective  since  they  are  estimated  to  have  (marginal)  abatement  costs  of  less 
than 50€/t CO2 by 2030; 

support  to  novel  alternatives  will  help  maintain  the  competitiveness  of  the 
European economy and in particular support green growth as demanded by the 
EU 2020 priority sustainable growth: building a more competitive low carbon 
economy, protecting the environment and capitalising on Europe's leadership in 
developing new green technologies35; 

improving  the  legislative  text  will  ensure  simplification  and  clarification  of 
existing  policy  to  enable  better  implementation  in  the  spirit  of  better 
regulation36; 

measures  are  introduced  to  safeguard  the  interests  of  SMEs  along  the  "think 
small first" principle37; 

special attention is paid to impacts on energy efficiency to ensure consistency 
in line with EU efforts of eco-design38 and energy efficiency39; 

taking action now at European level will lend support to the negotiations for an 
international agreement under the Montreal Protocol to phase down HFCs. 

5. 

POLICY OPTIONS  

5.1. 

Policy option A: No policy change at EU level (baseline option) 

This option includes the existing legislation and assumes, in particular, full application 
of the provisions of the F-Gas Regulation in all Member States and sectors. This implies 
that  current  shortcomings  are  effectively  addressed.  84%  of  respondents  to  the  online 
stakeholder  survey  thought  the  current  status  quo  (i.e.  existing  legal  rules  and 
implementation) was not sufficient. The steps to remediate current shortcomings include 
rigorous  persecution  of  non-compliance  by  Member  States  as  well  as  measures  of 
encouragement  at  European  level  through  non-legislative  actions  such  as  awareness 
raising, exchange of best practices and assistance which may take many shapes, e.g. the 
Commission  is  currently  incorporating  labelling  rules  into  the  Integrated  Tariff  of  the 
European Communities to support Member States in enforcing the labelling provisions 
of the F-Gas Regulation. Numerous suggestions were made by stakeholders during the 
on-line  survey,  many  of  which  require  better  control,  policing  and  enforcement  at 

35 
36 
37 
38 
39 

http://ec.europa.eu/europe2020/priorities/sustainable-growth/index_en.htm 
http://ec.europa.eu/governance/better_regulation/key_docs_en.htm#_br 
http://ec.europa.eu/enterprise/policies/sme/small-business-act/index_en.htm 
http://ec.europa.eu/enterprise/policies/sustainable-business/ecodesign/index_en.htm 
http://ec.europa.eu/energy/efficiency/index_en.htm 

EN 

15 

   EN 

 
                                                 
Member State level. Stakeholders and Member State representatives also made several 
suggestions  for  clarifications  and  simplification  in  the  Regulation,  in  particular  on 
definitions,  in  reaction  to  a  pertinent  question  in  the  stakeholder  survey,  which  are 
similarly addressed under this option.  

Hence,  Option  A  is  the  baseline  that  includes  current  legislation  as  well  as  some 
necessary measures to approve its application. Options B to E describe further measures 
that are additional to this baseline. 

5.2. 

Policy option B: Voluntary agreements by industry (non-regulatory) 

This option considers additional or enhanced voluntary agreements in the EU to reduce 
F-Gas  emissions.  Such  action  was  preferred  in  particular  by  industrial  stakeholders  in 
the online survey, with the exception of F-Gas producers. Stakeholders reported mixed 
experiences  with  voluntary  agreements  in  the  past,  some  reported  on  successful 
examples whereas others did not consider voluntary agreements to be adequate and/or 
enforceable.  Such  agreements  could  be  considered  realistic  in  the  following  areas, 
considering  that  abatement  costs  for  these  applications  are  estimated  to  be  relatively 
low40 (see Annex VI for more details): 

– 

– 

– 

– 

– 

– 

phase-out  HFCs  in  commercial  refrigeration  (centralised  systems, 
commercial hermetics, condensing units); 

replace HFC-134a in XPS foams; 

replace HFC-23 in fire protection; 

destroy HFC-23 emissions from halocarbon production; 

replace SF6 and NF3 in photovoltaic industry; 

and reach an enhanced agreement on the use of PFCs, NF3, HFC-23 and 
SF6  in the semiconductor industry. 

5.3. 

Policy option C: Extended scope of containment measures  

This  option  foresees  an  extension  of  the  current  F-Gas  Regulation  in  its  main 
provisions,  i.e.  the  requirements  on  containment  (Art.  3)  and  recovery  (Art.  4).  Such 
action  was  strongly  supported  by  many  industrial  players  in  the  online  stakeholder 
survey. 

A  number  of  potential  extensions  were  screened  in  terms  of  e.g.  effectiveness  and 
efficiency (see details in Annex VII). Eventually, the only sub-option considered to be 
relevant was an extension of the scope of these requirements to AC in some transport 
modalities.  

40 

3.1€  or  less  per  t  of  CO2eq  abated  except  for  centralised  refrigeration  systems  (23.7€  per  t 
CO2eq) (see Annex VII) 

EN 

16 

   EN 

 
                                                 
In  order  to  improve  containment,  improved  product  standards  on  leak  tightness  of 
applications  containing  F-Gases  are  desirable  and  should  be  further  pursued.41  This 
development of mandatory technical standards is part of the work under the Ecodesign 
Directive  (2009/125/EC)  and,  possibly,  in  the  future  also  under  the  proposed  Energy 
Efficiency  Directive42.  However,  considering 
large  number  of  appliances, 
corresponding  standards  and  the  timeframes  involved,  this  relevant  approach  cannot 
substitute for measures addressing the origin of the problem. Impacts of such standards 
were hence not explicitly considered under this option. 

the 

5.4. 

Policy  option  D:  Establishment  of  a  phasedown  mechanism  for  placing 
HFCs on the EU market 

This option involves a phasing down of the supply of bulk HFC substances in the EU 
complemented  with  measures  to  cover  quantities  imported  inside  of  equipment  ("pre-
charged").  In  the  online  survey,  a  phasedown  was  supported  by  producers  of  F-Gases 
and  producers  of  equipment  (both  alternatives  and  F-Gases)  as  well  as  users  of 
equipment, in addition to strong support from public authorities and many individuals. 
In  the  ensuing  stakeholder  conference  meeting  on  13  February  2012,  there  was 
widespread  support  for  such  a  measure  by  industry  as  it  was  considered  to  be  more 
flexible  than  bans  and  would  allow  industry  to  adapt  and  continue  using  F-gases  in 
applications  where  this  was  considered  to  be  the  optimal  solution.  However,  in 
particular NGOs considered that bans were also necessary. 

The  phasedown  mechanism  assessed  implies  a  gradually  declining  "cap"  for  the  total 
placement of bulk HFCs (in tonnes of CO2eq) on the market in the EU with a freeze in 
2015, a first reduction step in 2016 and reaching 21% of the levels sold in 2008-2011 by 
2030. These levels have been determined so as to fully respect current market needs and 
the possibilities of replacements in all sectors (compare Annex XVI) with proven, safe 
and  energy-efficient  technologies  already  available  today.  The  expected  accelerated 
future development of alternative technologies will provide an additional safety margin. 

Entities  placing  HFCs  on  the  EU  market  must  hold  rights  to  "place  on  the  market" 
(POM). ‘Placing on the market’ means the supplying of or making available to a third 
party  within  the  EU  for  the  first  time  and  includes  imports  of  bulk  substances.  The 
Commission  allocates  free  quotas  of  rights  to  POM  to  stakeholders  based  on  past 
reporting data ("grandfathering"). Stakeholders must ensure that they hold enough rights 
to cover their actual placing on the market and they may transfer rights between them. 
Compliance  checks  are  carried  out  by  the  Commission  in  the  following  year,  with 
independent verification of reports. As the participating entities are known through the 
existing reporting from the F-Gas Regulation and their number is a manageable size of 
ca. 100 companies, the phasedown is fully implementable through setting of limits by 

41 

42 

The  relevant  standard  EN  378  on  safety  and  environmental  requirements  for  refrigerating,  AC 
and  heat  pump  (RACHP)  systems  describes  the  charge  limits,  and  considers  toxicity  and 
flammability,  sets  design  requirements,  where  tightness  and  leak  tests  are  considered  together 
with safety requirements. It also covers requirements for installation sites and describes how the 
refrigeration  systems  have  to  be  maintained,  serviced,  dismantled.  This  standard  is  currently 
under revision. 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0370:FIN:EN:PDF  

EN 

17 

   EN 

 
                                                 
the  Commission  at  EU  level,  making  use  of  the  experience  gained  through  the  ODS 
phase-out. A reserve will be available to new market entrants.  

imported 

to  address  quantities 

in  pre-charged  RAC  equipment  are 
Measures 
indispensable for the environmental integrity43 of the phasedown mechanism and a level 
playing field in the market. Here one must differ between hermetically sealed and non-
hermetically sealed equipment. For the latter, a requirement of filling on the installation 
site  only  (instead  of  being  factory  pre-charged)  is  the  preferable  way  to  subject  these 
HFCs  to  the  quantitative  restrictions  of  a  phasedown  (see  also  Annex  X).  This 
requirement  is  non-discriminatory  as  it  would  apply  in  the  same  way  to  products 
produced in the EU and to those imported. The appliances affected would essentially be 
"non-monobloc"  AC  systems  (i.e.  single-split,  multi-split  and  rooftop  systems)  and 
would  cover  ca.  86%  of  refrigerants  imported  in  AC  equipment.  By  submitting  these 
quantities to the cap, the replacement of high-GWP HFCs with alternatives is favoured 
in the vast majority of these appliances, so that over time the on-site filling requirement 
will affect less and less units. Filling of equipment during the installation on site would 
also  alleviate  the  expressed  concerns  of  the  service  industry  (mainly  SMEs)  that 
currently  the  installation  of  new  equipment  is  often  done  without  the  legally  required 
use of certified experts, leading to additional and avoidable emissions, malfunctioning 
and loss of energy efficiency.44 For the sealed equipment (e.g. AC movables), a placing 
on the market ban would safeguard the environmental performance of the mechanism as 
well  as  attaining  a  more  level  playing  field  for  importers  vs.  domestically  produced 
equipment. 

Fig.  5  shows  the  phasedown  schedule.  The  grey  area  represents  the  quantities  which 
need  to  be  placed  on  the  market  to  satisfy  the  demand  for  F-Gases  for  product  and 
equipment where cost-efficient alternatives do not exist. The schedule is calculated on 
the  basis  of  the  AnaFGas  model  and  up-scaled  to  match  the  quantities  reported  under 
the  F-Gas  Regulation.  These  quantities  do  not  account  for  the  expected  technological 
progress  on  alternative  equipment  which  will  provide  an  additional  safety  margin  to 
avoid shortage of supply for applications that are not (yet) replaceable (see Annex X for 
details). 

43 

44 

In  2030,  18%  of  the  total  EU  demand  of  HFCs  is  estimated  to  be  inside  imported  equipment, 
based on CO2eq (currently 11%). If imported equipment did not have to face the same supply 
restrictions  on  HFCs  as  equipment  produced  in  the  EU,  the  share  of  import  and  hence 
uncontrolled supply of HFCs would likely become even higher. 
AREA  (2010).  "Postion  paper:  Review  of  Regulation  842/2006  on  certain  fluorinated 
greenhouse gass – pre-charged non-monobloc AC equipment." www.area-eur.be  

EN 

18 

   EN 

 
 
                                                 
Proposed EU bulk HFC POM phase-down steps (incl. import ban)

POM  [Mt CO2eq]

Proposed phase-down steps

q
e
2
O
C
t

M

200

180

160

140

120

100

80

60

40

20

0

2010

2014

2018

2022

2026

2030

2034

2038

2042

2046

2050

Fig. 5: Key features of phasedown schedule (see Annex X for more details) 

The system should be flexible enough to allow modifying the allocation mechanism to 
improve  its  functioning  where  deemed  necessary.  To  accommodate  the  outcome  of  a 
potential  international  agreement,  amendments  to  the  phasedown  schedule  at  a  later 
state  should  be  possible.  Furthermore,  the  Commission  should  have  the  possibility  to 
exempt  HFC  quantities  produced  or  imported  for  specific  uses  from  the  phasedown 
mechanism if the supply for applications which are critical for health and safety reasons 
would otherwise not be ensured. 

5.5. 

Policy  option  E:  Bans  of  production,  use  or  placing  on  the  market  of  F-
Gases in certain applications 

This policy option bans, from a specific date onwards, the sale of certain new appliances 
with F-Gases in the EU or the use of F-Gases in the following sectors where full market 
penetration of cost-efficient alternatives was considered feasible:  

– 

– 

– 

Commercial  refrigeration  (stand-alone  systems,  condensing  units, 
centralised systems); 

Industrial refrigeration45 

Transport refrigeration (Refrigerated trucks and trailers); 

45  

Penetration  rates  do  not  fully  reach  100%  for  this  whole  sector,  but  bans  may  be  possible  for 
larger industrial systems above a certain capacity. See also Becken et al. (2010)4 

EN 

19 

   EN 

 
 
 
                                                 
– 

– 

– 

– 

Stationary AC (moveable systems, single  split  systems,  multi  split/VRF 
systems, rooftop systems, displacement chillers); 

HFC-23 in fire protection; 

SF6  in  Magnesium  die-casting  <850  kg/  y  and  recycling  of  die  casting 
alloys; 

Non-medical  technical  aerosols  (except  if  100%  inflammability  is 
required); 

– 

HFC-134a in XPS foam blowing; and  

–  Mandatory destruction of HFC-23. 

Bans  were  strongly  favoured  by  individuals,  public  authorities  and  NGOs,  but  few 
industrial players. Some noted that substantive exemptions would be necessary e.g. due 
to  local  building  codes  prohibiting  the  use  of  certain  alternatives  in  certain  areas. 
Importers of foreign equipment argued that bans would be detrimental to their business. 

5.6. 

Combination of policy options 

The  policy  options  presented  above  are  not  all  mutually  exclusive,  as  measures 
contained  in  the  options  address  e.g.  different  gases  or  different  application  areas,  so 
some  could  be  implemented  jointly,  which  is  e.g.  the  case  for  Option  C  that  is 
complementary  to  all  other  policy  options.  The  impacts  of  such  combined  options 
would therefore often be a simple addition of the individual impacts of policy options 
combined. But bans under Option E could also be combined with an HFC phasedown, 
in  particular  to  steer  the  choice  of  alternative  technologies  in  sectors  where  they  are 
most cost-efficient. In this case the environmental impact and economic costs are to a 
large extent already included in the impacts of Option D as measures overlap. 

All policy options would contain clarification and simplification of the legislative text in 
order to improve implementation in the spirit of better regulation. 

Given the complexity of the sector, many stakeholders in the online survey seemed to 
suggest  that  a  mix  of  policies  is  the  best  approach  forward.  A  number  of  European 
Environmental  Protection  Agencies  have  openly  declared  to  favour  such  a  combined 
approach, based on a phasedown accompanied by bans in certain areas, in order to meet 
the emission reduction targets in a cost-efficient way.19 

5.7. 

Options discarded from further analysis 

Additional  policy  options  were  screened  but  discarded  from  further  analysis  and  are 
therefore not presented in detail in this section (See Annex VII for details). These policy 
options were:  

– 

Suspension of the current F-Gas Regulation, as it would mean forfeiting 
significant emission savings. 

EN 

20 

   EN 

 
– 

– 

– 

Inclusion  under  the  EU-Emission  Trading  System  (ETS).  The  current 
ETS has been designed to give a price to actual emissions from activities 
such as energy production, not for gases sold to be used in equipment for 
long periods of time and with  no clear emission endpoint as is the case 
for  most  F-Gas  applications.  Also,  the  number  of  players  who  would 
have  to  acquire  licenses  would  be  prohibitively  high  and  difficult  to 
monitor. Only few stakeholders selected this measure among the 3 most 
appropriate options in the online survey (6%). 

EU  harmonized  tax  schemes.  There  are  a  number  of  reason  why  this 
option  was  discarded,  inter  alia  (i)  tax  levels  and  exemptions  should 
reflect  national  differences  and  the  risk  of  emissions,  (ii)  correct  tax 
levels  are  difficult  to  set  at  European  level,  and  (iii)  control  of  the  tax 
scheme at European level would involve a high administrative effort. A 
minority  of  stakeholders  selected  this  measure  among  the  3  most 
appropriate options in the online survey (19%). 

Deposit  and  refund  schemes.  A  number  of  existing  national  differences 
make  it  preferable  to  implement  these  at  national  level.  A  minority  of 
stakeholders selected this measure among the 3 most appropriate options 
in the online survey (18%). 

In  addition  to  discarding  these  general  options,  some  additional  sub-options  to  policy 
options B, C, D and E were screened against criteria relating to: 

– 

– 

– 

– 

Effectiveness in terms of level of emission reductions (>1Mt of CO2eq)46. 
However, to ensure consistency with requirements for similar sectors47, it 
is  appropriate  to  retain  specific  options,  even  if  the  threshold  is  not 
reached,  where  the  measure  is  cost-neutral  or  even  beneficial,  for 
example through gains in energy efficiency; 

Efficiency in terms of abatement costs (<50€ per t of CO2eq abated); 

Technical constraints like safety or loss of energy efficiency; and 

Other constraints such as consistency with other EU policies. 

By way of example, a number of sub-options under Option C as regards extending the 
scope  of  containment  were  discarded  because  the  costs  were  too  high  (e.g.  for 
refrigerated vans and rail transport marginal costs were estimated to be €291 and €340 /t 
CO2eq abated, respectively; see Table A-VII_2 to Table A-VII_7 in Annex VII). 

46 

47 

This is equivalent to 1% of current EU-27 emissions of F-Gases (as reported in greenhouse gas 
inventories 2008) or 0.02% of total EU-27 greenhouse gas emissions without contributions from 
LULUCF 
For example domestic refrigeration and small commercial stand-alone refrigeration equipment. 

EN 

21 

   EN 

 
                                                 
6. 

ANALYSIS OF IMPACTS  

F-Gases  are  used  in  many  diverse  application  areas.  Fig.  6  gives  the  main  28  (sub)-
sectors  (in  addition  to  HFC-23  by-production)  which  are  considered  in  the  following 
analysis. Refrigeration is the most relevant sector in terms of emissions (estimated 34% 
of  total  F-Gas  emissions  in  2010,  based  on  Schwarz  et  al.9),  followed  by  mobile  AC 
(30%),  stationary  AC  (13%),  other  HFC  uses  (8%),  SF6  uses  (5%),  PFCs  and  other 
halocarbons  (5%),  and  foams  (4%).  The  strongest  long-term  growth  is  expected  for 
stationary AC. A detailed assessment of costs for all sub-sectors is given in Annex VI. 

Fig. 6: Main F-Gas application areas and sub-sectors9 

6.1. 

Environmental impacts 

6.1.1.  Approach used 

Four key environmental impacts were analysed for the period 2010 until the reference 
year 2030 (vs. baseline option A): 

(1)  Reductions in direct F-Gas emissions (in Mt CO2eq); 

(2)  New  direct  emissions  resulting  from  alternative  substances  (in  Mt 

CO2eq); 

(3)  Emissions  due  to  energy  efficiency  changes  resulting  from  shifts  to 
alternative  technologies.  The  expected  difference  in  annual  energy 
consumption  (kWh)  between  abatement  technology  and  HFC  reference 

EN 

22 

   EN 

 
 
 
 
technology was estimated and converted  into CO2 emissions by using a 
specific CO2 emission factor per kWh of electricity consumption.  

(4)  The emissions of ecotoxicologically relevant substances were quantified 

in metric units of toxic substances. 

The bottom-up stock model AnaFgas48 was used to estimate emission scenarios for F-
Gases in the EU-27. Baseline emissions are expected to remain stable from 2010 until 
2050, but are higher than 1995 (see Annex IV for further details).49  

In  order  to  reduce  overall  emissions,  measures  on  direct  emissions  (use  of  F-Gases) 
should  not  lead  to  higher  indirect  emissions  (e.g.  due  to  increased  energy  use  of 
equipment). In order to avoid such a potential trade-off, only safe and energy-efficient 
(i.e. at least as efficient as conventional technology) alternatives were considered as 
feasible replacement substances in the calculation of scenarios9 (see Annex XVI).  

6.1.2.  GHG emission reductions 

The largest emission reductions (71 Mt CO2eq) in 2030 can be achieved with policy 
option  D  (phasedown  combined  with  complimentary  measures  targeting  HFC  in 
imported equipment and products) (see Table 1). For perspective, this is almost twice as 
high as the yearly reduction of 37 Mt CO2 in the ETS cap between 2008 and 2012. It is 
also a reduction of ca. 63% in 2030 compared to emissions reported in 2005, i.e. at the 
level of emission reductions needed (60-61%) in 2030 from the non-CO2 sector (without 
agriculture)  to  be  consistent  with  the  2◦  C  target  as  expressed  in  the  roadmap  for  a 
competitive low carbon economy.21 Option E (bans of placing HFCs on the EU market) 
would also achieve a substantial emission reduction of about 53 Mt CO2eq of emissions 
in 2030 but still falls short as to the emissions reductions stipulated by the Low Carbon 
Economy  Roadmap,  while  Option  B  (voluntary  agreements)  would  achieve 
considerably  lower  emission  reductions  of  22  Mt CO2eq,  which  are  insufficient  as 
regards  the  climate  goals.  Option  C  (enlarged  scope)  achieves  only  very  small 
additional emission reductions50.  

Of the two most promising options on environmental grounds (D and E), the emissions 
reductions  from  Option  E  are  lower  mainly  because  bans  can  only  be  implemented 
when  replacement  substances  are  available  for  all  applications  in  the  sector  (=100% 
penetration rate, see Annex XVI), whereas the phasedown can gradually take effect also 
in sectors where replacements are only partly available at the onset of the measure. For 
voluntary agreements (Option B) the reduction potential is relatively low compared to D 

48 

49 

50 

A detailed description of the assumptions in model AnaFgas is provided in Annex III of Schwarz 
et al. 2011. A summary is given in Annex IV. 
All data in this report are calculated with GWP (GWP) values from the Fourth IPCC Assessment 
Report.  These  GWPs  are  different  from  those  values  currently  used  in  greenhouse  gas 
inventories, but they will become mandatory from 2015 onwards. 
The impacts of enhanced product standards on emission reductions within a particular timeframe 
are difficult to quantify as they depend on market uptake of standardised products and equipment 
or on the number of personnel and companies applying the standards. As this supportive measure 
is  independent  from  the  revision  of  the  F-Gas  Regulation,  no  quantitative  assessment  of  the 
impacts was carried out. 

EN 

23 

   EN 

 
                                                 
and  E  because  a  smaller  number  of  sectors  would reduce emissions (see Annex V  for 
further detail).  

if 

indirect  emissions  reductions  occur 

Additional  emissions  due  to  replacement  substances  are  very  low  for  all  options. 
the  energy  efficiency  of 
Additional 
replacements is higher compared to conventional technologies, which is the case e.g. in 
the  refrigeration  sector,  whereas  for  others,  e.g.  foam  blowing  and  AC,  the  energy 
efficiency of the abatement technologies is the same as that of the reference technology. 
A faster replacement schedule in Option D in the refrigeration sector leads to higher 
indirect emission reductions in this case compared to the other options. The reduction 
of  indirect  emissions  is,  however,  also  very  low  compared  to  direct  emission  changes 
from replacing F-Gases in use today. 
The  study  conducted  by  ERIE/Armines17  confirms  the  findings  by  Schwarz  et  al. 
(2011)9 as it obtained very similar metric tonnes of refrigerant emissions for the main 
application sectors by 2030. While Schwarz et al. is conservative, i.e. based on available 
technologies, 
technological 
development  (i.e.  "best  non-available  technologies")  into  account.  The  ERIE/Armines 
study  is  however  much  more  limited  in  scope,  addressing  only  7  main  sectors  as 
opposed to 28 (plus HFC-23 by-production) by Schwarz et al. Regarding a phasedown 
option,  ERIE/Armines  conclude  that  it  "seems  to  be  an  effective  measure  to  reduce 
significantly  the  climate  impact  of  refrigeration,  air-conditioning  and  heat  pump 
equipment [..]".  

the  ERIE/Armines  study 

the  possible  future 

takes 

Table 1: Environmental impacts of policy options in 2030 compared to baseline (Option A)  

Option B 

Option C 

Option D 

Option E 

VA 

- 21.7 

Extend Scope 

Phasedown 

- 1.4 

- 69.2 

Bans 

- 52.7 

+ 0.02 

not occurring 

+ 0.14 

+ 0.1 

- 0.51 

not occurring 

higher efficiency 
for refrigeration  

higher efficiency for 
refrigeration  

- 22.2 

-10% 

- 1.4 

+13% 

-1.6   

- 70.7 

-63% 

 - 0.72   

- 53.3 

-44% 

low risk 

not applicable 

low risk 

low risk 

Direct  emission 
changes in  
[Mt CO2eq] 
Additional 
emissions from 
replacement 
substances 
[Mt CO2eq] 
Additional indirect 
emissions due to 
energy-efficiency 
[Mt CO2eq] 
SUM [Mt CO2eq] 
Emission reduction 
in 2030 compared to 
2005 
Ecotoxicity 

EN 

24 

   EN 

 
 
6.1.3.  Ecotoxicity 

As  regards  ecotoxicity,  F-Gases  and  other  replacement  substances  (or 
their 
decomposition  products)  used  in  abatement  technologies  could  potentially  damage  the 
environment  if  released  to  the  atmosphere  in  large  quantities.  HFCs  have  long 
atmospheric lifetimes of up to 250 years but eventually decompose in the troposphere to 
yield  hydrofluoric  acid  (HF)  and  trifluoroacetic  acid  (TFA)  which  are  washed  out  by 
rainwater. PFCs and SF6 are even more persistent (several 1000 – 50,000 years) and do 
not  decompose,  but  are  eventually  photolysed  in  the  mesosphere.4  The  release  of  HF 
and TFA could cause acidification of ecosystems, in particular aqueous ecosystems, as 
they  impact  pH  values.  Among  the  natural  alternatives,  hydrocarbon  (HCs)  emissions 
could  potentially  lead  to  ground  level  ozone  and  formation  of  photochemical  smog. 
Ammonia  which  is  toxic  to  humans  contributes  to  acidification  of  ground  and  aquatic 
systems.  

In  the  examined  policy  scenarios,  Option  B  would  lead  to  the  formation  of  small 
quantities of HF and TFA in the atmosphere. Options D and E would in addition cause 
the  release  of  hydrocarbons  (HC-290,  HC-600a),  ethanol,  and  ammonia.  Highest 
emissions  from  replacement  substances  would  be  expected  for  Option  D  and  were 
estimated as 6800t HCs, 890t ammonia and 10.300t of unsaturated HFCs, mostly from 
potential use in refrigeration and AC in 2030. It must be borne in mind that the use of 
replacement  substances  reduces  the  amount  of  HFC  in  the  atmosphere  (and  resulting 
long-term  breakdown  products).  From  a  purely  ecotoxicological  point  of  view,  the 
release  of  natural  replacement  substances  (HCs,  ammonia,  ethanol,  CO2,..)  to  the 
atmosphere is preferable to the release of HFCs as they occur naturally in much larger 
concentrations  than  would  be  released  under  any  of  the  options.  But  also  atmospheric 
concentrations  of  HFCs  are  in  the  parts-per-trillion range  which is far below effective 
ecotoxic levels.4 Ecotoxicity effects are therefore assumed to be low for all options, 
based on state-of-the-art knowledge.51,52 

6.2. 

Economic impacts 

Fig. 7 shows that F-Gas emission reductions of ca. 72 Mt CO2eq could be achieved at 
marginal costs often far below 50€ per t CO2eq. Beyond this level there are few other 
additional  possible  emission  reductions  considering  only  technologies  available  today. 
These findings are based on a very comprehensive analysis of replacebility of F-Gases 
in all main application sectors based on available technologies that are safe and energy-
efficient.  Detailed  data  and  analysis  covering  each  individual  sector  is  available  in 
Schwarz et al.9  The discussion in this section profits from this analysis (most relevant 

51 

52 

The highest concern is for TFA due to its persistence and mild phytotoxicity. A recent study has 
shown that TFA concentrations in rainwater in Europe may rise in the future but would in the 
worst  case  still  be  at  least  a  magnitude  lower  than  observed  no-effect  levels  on  organisms.52 
Compared to the latter study's assumptions (a total conversion of the European automobile fleet 
to use an unsaturated HFC that readily decomposes to TFA), future TFA production from all the 
policy  options  discussed  in  this  document  would  be  low.  Nonetheless,  the  future  use  of 
unsaturated HFCs should be closely monitored. 
Henne et al. (2012). "Future Emissions and Atmospheric Fate of HFC-1234yf from Mobile Air 
Conditioners in Europe". Environmental Science & Technology 46: 1650-1658. 

EN 

25 

   EN 

 
                                                 
background data from the latter study is summarised in e.g. Annexes IV, V, VI, VIII, 
and XVI of this document). 

EU-27 M ACC emission reduction vs. WM  scenario 2030

150

100

50

q
e
2

O
C

t

/

0

0

-50

20,000

40,000

60,000

80,000

ktCO2eq

Fig. 7:  Marginal emission abatement costs vs. achievable emission reductions by 2030. Source: 
Schwarz  et  al.  (2011)9  (MACC:  Marginal  Abatement  Cost  Curve,  WM  scenario  = 
Option A). Costs are in € at 2010 levels. 

6.2.1.  Abatement costs and direct costs to industry 

The following key direct economic impacts were analysed in a quantitative way for the 
reference  year  2030  in  comparison  to  the  baseline  scenario  (Option  A)  for  subsectors 
affected by each of the options (see details in Annex VI):  

(1) 

Abatement costs for F-Gas emissions (€ per t CO2eq, assessed for the sector-
typical  F-Gas  reference  systems  and  the  most  promising  (safe)  alternative 
technologies). The considered parameters are: 

– 

– 

– 

Emissions: GWP of substance, charge (amount) of substance used, 
emission factor for use-phase and disposal, manufacturing emission 
factor (e.g. for production of foam);  

Energy  consumption:  e.g.  refrigerating  capacity,  installed  electric 
power, annual running time;  

Cost: investment cost of equipment and of first substance fill, price 
of substance per kg, price of energy per kWh, equipment lifetime, 
discount rate. 

The average abatement costs per t CO2eq in 2030 for the three policy options with 
significant  emission  reduction  effects  (B,  D  and  E)  are  very  similar  (see  Table  2). 
The  marginal  costs  are  somewhat  higher  for  Option  D  at  €49/t  CO2eq  but 
consistent  with  the  projected  marginal  abatement  costs  for  the  implementation  of 
GHG mitigation policies and measures in 2030, namely 50€ / t CO2. For Option C, 

EN 

26 

   EN 

 
 
€
 
 
 
average and marginal abatement costs are identical (one sector) and amount to €46/t 
CO2eq. All options are therefore considered cost-efficient. This finding also holds 
for  higher  discount  rates  or  lower  prices  of  F-Gases  (see  sensitivity  analysis  in 
Annex VIII). 

(2) 

Total (annualised) net costs to industry (€ per year); these include: 

– 

– 

Capital  investment  costs:  These  costs  include  capital  investments 
(as  well  as  interest  payments)  to  install  new  equipment  or  to 
modify a production facility (in the time from 2015 to 2030); 

Operating  and  maintenance  costs:  These  costs  include  costs  to 
operate and maintain the equipment as well as changes in all other 
input costs, e.g. service costs for leakage checks, refill, and energy.  

The total net costs to sectors are highest for Option D (1,500 M€/year), due to the 
largest  number  of  sectors  affected,  closely  followed  by  Option  E  (1,330  M€/year) 
and are smaller for Option B (530 M€/year) and C (66 M€/year) (see Table 2). The 
individual costs per (sub-) sector vary considerably (see also 6.2.2). 

Costs  were  calculated  on  an  annual  basis,  using  a  general  discount  rate  of  4%  and 
product specific lifetimes varying between 10 and 30 years. 

 Table 2: Comparison of direct cost impacts in 2030 

Unit 

Option B 

Option C 

Option D 

Option E 

VA 

Extend Scope 

Phasedown 

Bans 

Average 
abatement 
costs in 2030 

Marginal 
abatement 
costs  

Total direct 
net costs to 
industry 
sectors 

€ / t CO 2eq 

€ / t CO 2eq 

17 

24 

527 

M€ / year  

(from -0,1 to 417 
per sub-sector) 

46 

46 

66 

16  

49 

1,499  

(from -66 to 
+489 per sub-
sector) 

17  

24  

1286  

(from -5 to +489 
per sub-sector) 

Source:  

Schwarz et al. (2011)9, Table 8-24 and Table 8-25.53 All costs in € at 2010 levels. 

6.2.2. 

Impacts on sectors 

According  to  Table  3,  the  direct  net  costs  differ  widely  for  the  different  subsectors 
affected by Options B, D and E (Option C only includes one sector). A large part of the 
costs  occurs  in  commercial  refrigeration  (commercial  hermetics,  condensing  units  and 
centralized systems (option B, D and E).   

Table 3: Additional annual cost by sector in 2030 

53 

Option D was recalculated to take account of measures on pre-charged equipment.  

EN 

27 

   EN 

 
 
 
                                                 
Domestic Refrigeration 

Commercial refrigeration: 

Commercial hermetics 

Condensing units 

Centralized systems 

Industrial Refrigeration: 

Industrial Ref small 

Industrial Ref large 

Transport refrigeration: 

Refrigerated Vans 

Refrigerated Trucks 

Fishing vessels 

Transport AC: 

Cargo ship AC 

Passenger ship AC 

Bus AC 

Truck AC 

Moveable AC systems 

Stationary AC: 

Split AC systems 

Multi-split AC systems 

Rooftop AC systems 

Chillers 

Centrifugal chillers 

Fire protection: 

Fire protection 227ea 

Fire protection 23 

Foam blowing: 

Aerosols 

XPS-152a 

XPS-134a 

PU other 

Other: HFC-23 by-product 

B 

0 

0 

105 

417 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

3 

0 

0 

1 

0 

1 

C 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

66 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

D 

0 

0 

105 

417 

-1 

-66 

21 

17 

2 

6 

3 

107 

244 

2 

E 

0 

-5 

276 

380 

0 

-5 

0 

1 

0 

0 

0 

0 

0 

19 

489 

489 

54 

12 

36 

1 

11 

3 

36 

-1 

1 

0 

0 

46 

12 

33 

0 

0 

3 

36 

0 

1 

0 

1 

SUM 

527 

66 

1499 

1286 

For  Option  D,  transport  AC  (trucks  and  buses)  is  also  important  as  well  as  stationary 
AC  (i.e.  single-split  AC).  Under  this  option,  the  five  subsectors  with  the  highest  net 

EN 

28 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
costs  account  for  almost  90%  of  the  costs  arising  in  all  25  subsectors  affected.  Low 
direct net costs occur for abatement in the remaining sectors (see Annex VI for detailed 
data on costs per sector). A detailed assessment of the impacts of these costs on turnover 
and competiveness for the most important sectors is given in section 6.2.6. 

– 

Direct impacts 

Key  economic  effects  have  been  assessed  comprehensively  using  two  models:  To 
analyse  the  direct  (and  indirect)  effects  on  output  resulting  from  changes  in  costs  or 
investment,  an  Input-Output  model  framework  (i.e.  the  EmIO-F  Europe  model,  see 
model description in Annex IX) was used. EmIO-F Europe can give a basic assessment 
of the effect of the additional burden a policy or measure may impose on the economy. 
Secondly, a general equilibrium model (GEM-E3) was used to complement the analysis 
(see  model  description  in  Annex  XIV).  A  comparative  description  of  the  latter  two 
models  is  given  in  Annex  XV.  Based  on  these  models,  impacts  for  the  F-Gas 
application sectors are expected to be small at less than 0.6% of total output in all 
cases (Fig. 8, Annex XIV). A sensitivity analysis was carried out and is elaborated in 
Annex VIII. The result was that even under conditions of a discount rate of 8% (instead 
of  4%)  or  halved  prices  for  unsaturated  HFCs,  cost-efficiency  and  environmental 
effectiveness of all policy options B, D and E are not distorted significantly. 

At a more detailed level, the Input-Output model shows that direct effects within each 
application sector may occur in four main areas of commercial activity: (1) equipment 
manufacturing,  (2)  supply  of  chemicals  (i.e.  F-Gases  or  replacement  substances),  (3) 
services and maintenance, and (4) energy supply (i.e. electricity).  

(1)  Equipment manufacturing:  

As  a  starting  point  manufactures  of  the  affected  appliances  are,  in  general,  facing 
growing  markets  e.g.  for  AC  or  refrigeration  equipment.  Option  B,  D  and  E  would 
impact  on  the  choice  of  substance  used  in  the  production  of  a  growing  number  of 
appliances  and  may  therefore  require  higher  investment  costs.  Given  that  the  direct 
impact in all sectors is small, it can be expected that costs per unit will also be relatively 
small.  The  analysis  with  the  I/O  model  assumed  that  costs  can  be  passed  on  to 
consumers  without  affecting  sales  (additional  investments).  Hence,  equipment 
suppliers would be able to increase their sales due to higher prices (related to the 
higher  investment  costs  of  the  equipment).  An  analysis  based  on  abatement  costs 
derived  with  the  AnaFgas  model  (Schwarz  et  al.,  20119)  shows  that  Option  D  yields 
the highest sales as it affects the highest number of appliances. Consequently, effects 
for Options E, B (and C) are lower, in this order, as fewer sectors are affected (see Table 
4). In Section 6.2.6 the assumption on passing on costs is examined further. That section 
looks at the increase in annual costs and the elasticity of demand for the major pieces of 
equipment covering more than 90% of the costs. It shows that the overall annual costs 
increases  are  small  (around  1  to  2  %)  and  demand  for  the  goods  is  rather  inelastic. 
Consequently,  the  expected  increases  in  sales  in  Table  4  (and  output)  may  be 
overestimated by around 1%. 

EN 

29 

   EN 

 
Table 4:  Comparison of the net additional sales of domestic suppliers of equipment (M€ / year)  

Unit 

Option B 

Option C 

Option D 

Option E 

Additional 
sales of 
domestic 
equipment 
suppliers 

Source:  

M€/year  

1,610 

Not applicable 

3,040  

2,060 

Annex  VI  Table  A_VI-2  based  on  Table  8.24  in  Schwarz  et  al.  (2011)9  with  additional 
adjustments 

Fig. 8 gives the EmIO-F Europe model outcome for the direct output effects as a result 
of  the  different  F-Gas  policy  options.  In  line  with  the  discussion  above,  the  model 
shows  higher  outputs  for  the  machinery  and  equipment  sector  for  all  options.  Highest 
outputs  were  modelled  for  Option  D  (+0.52%),  followed  by  Option  B  (+0.32%)  and 
Option E (+0.23%)54.  

Phase-Down

Ban

VA

0.60%

0.40%

0.20%

0.00%

-0.20%

-0.40%

-0.60%

Machinery/
equipment

Services/
maintenance

Chemicals

Electricity

Fig. 8:  Effects on output of directly impacted activities, derived with EMIO-F Europe (as % of 

2007 output; Phasedown = Option D, Ban = Option E, VA = Option B) 

These positive impacts on the equipment sector are confirmed by GEM-E3 (see Annex 
XIV). Potential advantages for EU manufacturers in terms of additional exports, having 
a  strong  position  on  the  market  for  alternative  technologies,  are  not  captured  by  the 
models  used  and  are  difficult  to  quantify  at  the  present  stage.  In  conclusion, 
manufacturers of equipment can expect to profit from policy options B, D and E, 
with strongest effects expected from a phasedown measure (Option D).   

54 

Option C was not analysed with the model as effects are limited to one application sector only 
and hence very small for all activity areas 

EN 

30 

   EN 

 
 
 
 
 
 
 
                                                 
(2)  Services/Maintenance:  

For  service  and  maintenance  companies  some  losses  may  be  expected  due  to  reduced 
service  needs  for  F-Gas  equipment  (Table  5).  Options  B,  D  and  E  focus  on  replacing 
HFCs with a high GWP as opposed to Option C and the current F-Gas Regulation, the 
latter having a strong focus on improved leakage detection and recovery at the end of 
the life. However, alternative technology using high pressure or flammable substances 
also require maintenance. Overall, the net effect on the service sector is estimated based 
on  AnaFGas  (Schwarz  et  al.,  20119)  to  be  negative  in  the  long  run  for  those  policy 
options that favour most strongly the use of alternative substances (in particular Option 
D and E; see Table 5).  

Table 5:  Comparison of losses from ceased service under Art. 3 and 4 F-Gas Regulation in the 

long run (M€ / year)  

Unit 

Option B 

Option C 

Option D 

Option E 

Losses (-) 
from ceased 
service under 
Art 3+4 

M€/year  

-290 

70 

-1,280 

-1,270 

Source:  

Schwarz et al. (2011)9 as well as Annex VI 

Results  of  the  EmIO-F  Europe  model  also  show  that  service  companies  experience 
(small)  negative  effects,  which  are  most  pronounced  for  Option  D  (-0.38%)  and  E  (-
0.37%), and less for Option B (-0.09%) (see Fig. 8). 

However,  these  effects  may  still  be  overestimated  since  the  baseline  assumes  full 
application  of  the  existing  legal  obligations.  In  reality,  these  obligations  have  not  yet 
been  fully  applied  since  implementation  and  awareness  among  users  are  delayed8. 
Moreover,  apparently  the  European  Air-Conditioning,  Refrigeration  and  Heat  Pump 
Contractors  (AREA)  are  keen  on  exploiting  the  new  business  opportunities  linked  to 
alternatives.  In  an  internal  survey55  they  conclude  that  there  is  a  potential  risk  of 
shortage  of  contractors  trained  in  the  use  of  low  GWP  refrigerants  and  advises 
compulsory training based on harmonised minimum requirements.  

In  conclusion,  maintenance  needs  due  to  the  existing  F-Gas  Regulation  might 
decrease, in particular, for the most effective options, phasedown (D) and bans (E), 
but the effects on relevant companies are expected to be small. 

(3)  Supply of chemicals:  

The replacement of HFCs with low-GWP substances would result in a shift in the sales 
of F-Gas producers and distributors. Producers and distributors of low-GWP substances 
are not always the same as those of HFCs. Current F-Gas producing companies in the 
EU (7-10 in total) are large chemical companies which have production sites distributed 

55  

AREA  internal  survey.  "RACHP  contractors’  training  in  the  use  of  low  GWP  refrigerants". 
March 2012. 

EN 

31 

   EN 

 
 
 
                                                 
globally.  In  the  transition  from  producing  high  GWP  substances  to  low  GWP 
substances,  the  impacts  will  depend  on  the  ability  of  some  producers  to  benefit  more 
from  the  HFC  replacements  through  the  development  of  alternative  substances  than 
their  competitors.  As  there  are  several  replacement  substances  (currently  two 
unsaturated HFCs, as well as mixtures of HFCs, hydrocarbons, CO2 and ammonia) and 
since  all  major  producers  are  already  developing  low  GWP  replacement  substances,  a 
situation  in  which  only  a  few  producers  benefit  from  the  lower  HFC  consumption  is 
unlikely  to  occur.  Current  F-Gas  producers  would  likely  be  the  distributors  of 
unsaturated  HFCs  which  are  expected  to  contribute  most  to  the  turnover  of  F-Gas 
producers and distributors, as a result of the comparably high prices of these chemicals.  

The EmIO-F Europe model gives small net effects on the output of the chemicals sector 
for  all  options  (Fig.  8).  A  small  positive  effect  (0.17  %)  is  obtained  in  case  of  a 
phasedown  (Option  D),  almost  no  effect  in  case  of  bans  (Option  E:  +0.03%)  and  a 
negative  impact  in  case  of  voluntary  agreements  (Option  B:  -0,19%).  The  GEM-E3 
model suggests small negative impacts on output for Option D and E for the chemical 
sector  (see  Table  6  and  Annex  XIV).  Domestic  production  decreases  slightly  as  it  is 
substituted  by  imports.  In  the  case  of  passing  on  costs  to  end-users,  the  price  of 
chemical  products  further  increases  and  hence  production  decreases  further.  Actual 
effects are likely to be even smaller (and could be even positive) as imports of F-Gases 
are  already  addressed  in  Option  D  which  is  not  reflected  by  the  model.  In  summary, 
effects on the chemical sector are expected to be small for all options. 

Table 6: Chemical Production compared to the Baseline in 2030 (% change) 

Option D 

Option E 

1.  Option D 

-0.13 

-0.06 

2.  Option D with  
costs pass-on 

-0.35 

-0.22 

Source: GEM-E3 (see Annex XIV for details) 

(4)  Energy supply: 

The output of this sector is affected by the changes in electricity consumption for new 
technologies.  The  model  EMIO-F  Europe  forecasts  an  output  reduction  of  -0.59%  for 
Option D, -0.26% for Option E, and -0.19% for Option B (Fig. 8). This output reduction 
is  explained  by  a  reduced  electricity  demand  (and  further  emission  saving,  see  also 
Table 1) of replacement technologies. The effect is highest for Option D as this option 
stimulates  replacement  in  most  sectors,  followed  by  E  and  B.  Several  stakeholders  in 
the  on-line  survey  similarly  expected  that  end-users  would  profit  from  reduced 
electricity consumption. The negative impact of Option D and E is confirmed by GEM-
E3. In conclusion, electricity demand will decrease, in particular for Option D, and 
will lead to small output reductions in this area. 

EN 

32 

   EN 

 
 
– 

Indirect impacts 

Since  equipment  manufacturers  are  expected  to  pass  on  costs  to  consumers,  the 
industrial  users  of  such  equipment,  e.g.  supermarkets  and  the  food  and  drink 
manufacturing  industry,  could  be  indirectly  affected  by  potentially  higher  investment 
costs  and  changes  in  annual  operating  costs  for  new  equipment.  The  difference  in 
annualized  net  costs  for  operators  investing  in  new  equipment  based  on  alternative 
technologies  range  widely.  Considerable  annualised  savings  were  estimated  for  new 
investments in large industrial refrigeration (€ -22,642) which is affected by Option D 
and E and in many other subsectors new investments would incur only small direct costs 
for  the  operators.  The  highest  costs  (€  2,876)  for  operators  were  estimated  for  new 
centralised  commercial  systems  (supermarkets),  affected  by  Options  B,  D  and  E  (see 
Annex VI, Table A_VI-1).  

Phase-Down

Ban

VA

0.09%

0.07%

0.05%

0.03%

0.01%

-0.01%

-0.03%

Basic
metals

Metal
products

Retail
trade

Tobacco

Clothing Hotel and
restaurant

Fig.  9:  Effects  on  output  of  selected,  indirectly  impacted  sectors  determined  with  EmIO-F 
Europe  (%  of  2007  sector  output;  Phasedown  =  Option  D,  Ban  =  Option  E,  VA 
(voluntary agreement = Option B) 

Fig.  9  displays  the  impact  on  selected  sectors  that  are  indirectly  affected,  as  obtained 
with  the  model  EmIO-F  Europe.  The  indirect  effects  range  from  small  but  positive 
effects on sectors that deliver inputs to the machinery and equipment sector (e.g. 
basic metals, metal products) to very small but negative effects on sectors providing 
services or products to final consumers (e.g. retail, clothing, luxury consumption such 
as  tobacco,  hotels  &  restaurants  etc.).  The  latter  effects  are  explained  by  the  fact  that 
consumers  would  have  less  money  in  their  pockets  to  spend  on  services  and  end-
products, if higher prices of F-Gas equipment are passed on to them. These effects are 
observed for all Options B, D and E, but are generally most pronounced for Option D, 
followed by B and E. The reduced consumption pattern leads to a very small reduction 
in aggregate output of -0.011% in case of Option B, -0.014% in output for the case of 
Option  D,  and  -0.004%  in  case  of  Option  E.  Results  in  Fig.  9  assume  that  additional 
costs  for  equipment  would  reduce  final  demand  for  all  goods  and  services  (e.g.  food, 

EN 

33 

   EN 

 
 
textiles, furniture, restaurants,..) proportionally. GEM-E3 confirms the positive impacts 
for  the  metals  sectors  (Option  D  and  E)  and  shows  neutral  to  positive  effects  for  the 
consumer goods sectors (see Annex XIV). Given that the sales for new equipment might 
be overestimated (due to the negative impact of price increases on demand) the indirect 
reduction in demand for other goods might be somewhat smaller. 

– 

Total impact from both direct and indirect effects 

Overall,  the  total  effect  on  output  based  on  direct  and  indirect  effects  across  all 
sectors  is  very  small.  EmIO-F  Europe  predicts  a  slightly  positive  effect  at  0.006%, 
0.009%, and 0.003% for Options B, D and E, respectively (based on Fig. 8 and Fig. 9), 
while slightly negative (-0.006 for Option D to -0.003 for Option E) are obtained with 
GEM-E3 (see Table 10 below).    

For clarity and as a number of different industrial players may be affected by the F-Gas 
policy  options  as  outlined  above,  the  following  Table  7  gives  a  qualitative  overview 
over the most important actors and the impacts they may experience, summarizing the 
discussions above. For most players, impacts would be small and nobody is expected to 
lose  out  significantly,  as  demand  for  equipment  will  rise  and  not  decline.  However, 
actors will have to adjust to the new situation, e.g. retailers would see a shift towards 
selling  more  equipment  with  low  GWP  substances.  Most  market  players  have 
experienced a similar transition already under the Montreal ODS phase-out, which was 
achieved successfully and 10 years faster than required in the EU, so they are expected 
to adapt quickly also to a use reduction of F-Gases, as soon as a clear regulatory signal 
is  set.  It  is  clear  that  producers  of  alternative  equipment  would  be  the  big  winners, 
fostering the growth of green companies, many of which are SMEs similar to what has 
been observed in some Member States (e.g. DK, AU) where there is more stringent F-
Gas legislation already.  

Table 7: Overview of expected impacts of different market players: scales reach from very high 
positive impacts (+++) to very high negative impacts (---)  

Impact  due  to  policy 
options 

Types of company 

Estimated Impact 

Producers  of  F-Gases 
(chemical industry) 

Producers of equipment 
overall (manufacturers) 

Producers of alternative 
equipment 

direct 

direct 

7-10 large, globally 
acting companies 

0  (see  6.2.2,  Fig.  8, 
Table 6) 

large and small 
companies 

0/+  (see  6.2.2,  Fig.  8, 
Table 4) 

direct 

many SMEs 

+++ (see e.g. 6.2.9) 

Electricity production 

Service companies 

direct 

direct 

large companies 

- (see 6.2.2, Fig. 8) 

many SMEs 

0/-  (see  6.2.2,  Fig.  8, 
Table 5, 6.2.10, Annex 
III, Annex VI) 

EN 

34 

   EN 

 
 
Importers of equipment 

direct 

Exporters of equipment 

direct 

Users of equipment 

indirect 

large and small 
companies 

large and small 
companies 

0/- (see e.g. 6.2.6) 

0/-  (see  6.2.6,  Table 
12) 

large companies, SMEs, 
microenterprises, 
consumers 

0  (see  6.2.2,  6.2.6, 
6.2.10,  Fig.  9,  Table  
11) 

Retail sectors 

Input 
(Basic 
sectors 
metals, metal products) 

6.2.3.  Administrative costs 

indirect 

indirect 

large and small 
companies 

large and small 
companies 

0/-  (see 6.2.2, Fig. 9) 

0/+ (see 6.2.2, Fig. 9) 

The definition of administrative costs refers to the costs incurred by enterprises, public 
authorities  or  citizens  in  meeting  legal  obligations  to  provide  information  on  their 
actions or production. Information is used in a broad sense to cover labelling, reporting, 
registration,  monitoring  and  assessment  needed  to  provide  information  as  well  as  the 
transfer  of  information  to  public  authorities.  Administrative  costs  are  the  sum  of 
business-as-usual  costs  (costs  that  would  still  be  incurred  if  the  legislation  were  to  be 
removed)  and administrative  burden  (incurred due to the legislation). In the following 
the given costs are on top of costs currently resulting from the monitoring and reporting 
under the existing F-Gas Regulation, which remain  the  same  for  all  considered  policy 
options. Table 8 provides an overview of the total additional administrative costs for the 
policy options (details in Annex XII and XIII). It shows that administrative costs are 
small  in  general,  as  they  represent  only  a  small  percentage  of  the  direct  costs  to 
industry, ranging between <0.1% (Options C, D & E) and 2% (Option B).  

Table 8: Administrative costs of the policy options 

Option B  Option C  Option D  Option E 

Total administrative costs  
[million € / year] 

10.7 

0 

Total one-off administrative costs  
[million €] 

1.2 

0.2 

1.9 

– 

Option B 

EN 

35 

   EN 

 
 
 
 
 
 
 
 
 
Significantly higher administrative costs were determined for Option B compared to the 
other policy options. While this may seem surprising at first glance, it results from the 
fact that 

(i) only additional reporting costs are included in the calculations, i.e. on top of existing 
reporting under the F-Gas Regulation which addresses the bulk of reporting needs of the 
other options; 

(ii)  it  was  considered  that  voluntary  agreements  should  have  quantified  and  staged 
objectives  and  should  include  a  monitoring  and  reporting  system  for  achieving  the 
objectives, following the recommendations of a pertinent EC communication56; 

(iii)  the  number  of  participating  companies  to  experience  an  additional  administrative 
burden  would  be  large,  e.g.  the  number  of  individual  companies  in  the  commercial 
refrigeration sector would cover more than 1000 undertakings (see Annex XII); and 

(iv) approximately 75% of the estimated annual cost of 10.7 million €/year for Option B 
are  due  to  independent  verification  of  reported  HFC  use.  Without  the  independent 
verification of the reported information, the administrative burden for this option would 
amount to 2.9 million €/ year.  

– 

Option C 

No  additional  information  requirements  would  occur  and  hence  no  additional 
administrative burden was estimated. 

– 

 Option D 

The main additional costs for reporting and verification would be incurred by producers 
and importers of bulk HFCs, meaning ca. 80 companies. The administrative costs for all 
companies participating in a phasedown mechanism are estimated at €227,000 per year. 
In addition, one-off costs of 1.9 million Euros are estimated, 90% of which arise from 
the independent verification of baseline reports.  

– 

Option E  

For bans, the administration for companies is rather simple57 and not a lot of new and 
additional  information  is  needed.  It  would,  however,  require  additional  administrative 
costs  for  audits  or  inspections  by  competent  authorities  in  Member  States.  A  total 
amount  of  1.2  million  €/year  was  estimated  as  the  additional  administrative  burden, 
73%  of  which  arise  from  the  audits/inspections  conducted  on  companies  by  national 
administrations.  This  is  an  important  difference  to  Option  B  and  D,  where  additional 
costs would be borne mostly by companies. 

56 

57 

Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  Economic 
and  Social  Committee  and  the  Committee  of  the  Regions:  Environmental  Agreements  at 
Community  Level  -  Within  the  Framework  of  the  Action  Plan  on  the  Simplification  and 
Improvement of the Regulatory Environment. COM(2002) 412 final of 17.7.2002. 
In case exemptions to the bans should be foreseen in the implementation, this would probably 
involve extensive procedures to define and apply for such exemptions. However such procedures 
do not need to be accounted for in the assessment of administrative costs. 

EN 

36 

   EN 

 
                                                 
Stakeholders  in  the  on-line  consultation  saw  no  large  differences  between  options  as 
regards  the  administrative  burden,  but  regarded  Option  D  as  somewhat  less 
burdensome. Stakeholders also pointed out repeatedly that the additional burden would 
be small in sectors where reporting already exists (due to the F-Gas Regulation). 

6.2.4. 

Impacts on regions 

In the major (sub-)sectors that include domestic refrigeration, commercial refrigeration, 
transport refrigeration, mobile AC as well as aerosols, a large number of units would be 
affected by the policy options. As this type of equipment is distributed relatively evenly 
between  Member  States,  investments  in  replacement  technologies  in  these  sub-
therefore  also  be  distributed  evenly  without  a  regional 
sectors  would 
concentration. On the other hand, stationary AC units as well as AC systems in buses 
are  more  frequently  used  in  warmer  Mediterranean  climates  in  the  Southern  Member 
States than in the temperate climate in the North. For these subsectors, direct net costs 
will be 34% higher in Southern Europe than the EU average due to the higher number of 
installed equipment per inhabitant (Table 9). This cost effect is observed for Options 
D  and  E  and  would  be  about  1€  /  person,  hence  relatively  small.  Some  of  the 
remaining  sub-sectors  concern  only  a  few  installations  where  there  will  be  only  some 
limited effects as these sectors are very specialised.  

Table  9:  Direct  net  cost  effects  for  AC  systems  per  1000  persons  and  sector  (€  /  1000 

inhabitants)  

New Split AC  New Bus AC  Other sectors  TOTAL  % of EU average 

EU 27 average 

940 

Southern EU58 

Northern EU 

1893 

494 

206 

239 

191 

1737 

1737 

1737 

2883 

3868 

2422 

100 

134 

84 

GDP effects were calculated with the macro-economic GEM-E3 model (see Annex XIV 
for details). The scenario modelled with GEM-E3 focuses on the phasedown (Option D) 
and  bans  (Option  E)  only  as  these  options  include  the  highest  number  of  sectors, 
implying  that  all  other  policy  options  would  show  smaller  effects.  Table  10  indicates 
that in 2030 the net GDP effects are very small for the EU27 (for Option D and E) 
but somewhat higher for Southern European countries (all countries bordering the 
Mediterranean  Sea)  assuming  an  allocation  of  rights  to  place  on  the  market  through 
grandfathering (scenario 1 in Table 10). If costs are fully passed on into higher prices 
for the consumer, the difference between EU and the EU South in terms of GDP losses 
could  be  slightly  higher  (scenario  2,  Table  10).  The  impacts  might  even  be  more 
positive both in the EU27 and the EU South since the GEM-E3 model does not include 

58 

Southern EU: Bulgaria, Cyprus, Greece, Italy, Malta, Portugal, Romania, Spain 
Northern EU: Rest of EU 27 

EN 

37 

   EN 

 
 
 
                                                 
 
the importers of F-Gases in the analysis and hence the small negative impacts on GDP 
are  overestimated.  Hence,  the  impact  on  GDP  is  generally  very  small  and  differences 
between the EU and the EU-South are small as well (see Annex XIV for details.) Thus, 
in  summary,  even  if  some  regional  effects  are  inherent  in  the  proposed  policy 
options,  the  economic  impacts  are  very  small  and  will  not  have  significant  large 
effects on certain regions in the EU. 

Table 10: GDP effects for the EU27 as a whole and Southern Europe in 2030 (% change) for 

Options D and E (% change) 

Option D 

Option E 

EU27 

EU South 

EU27 

EU South 

1. free allocation  
(grandfathering) 

-0.006 

-0.008 

-0.003 

-0.003 

2. costs pass-on 

-0.012 

-0.016 

-0.007 

-0.009 

Source: GEM-E3 (see Annex XIV for details) 

6.2.5. 

Impacts on the functioning of the internal market and competition 

For all policy options, the rules will be applicable in the same way to all undertakings in 
the  EU  so  that  a  distortion  of  the  internal  market  is  not  given.  Given  that  for  most 
appliances  several  alternatives  can  be  used,  a  limitation  on  the  use  of  F-Gases  is  in 
general  not  expected  to  limit  competition  in  any  significant  way.  In  the  case  of  the 
phasedown  (Option  D),  market  players  are  assigned  rights  to  place  on  the  market 
(POM) based on past outputs. For new entrants to the market a reserve of rights to POM 
is implemented, so that competition is similarly safeguarded. 

6.2.6. 

Impacts on competitiveness, trade and investment flows 

As regards competitiveness, direct impacts on costs across all F-Gas application sectors 
are  expected  to  be  small  for  all  policy  options  compared  to  total  output  since  costs 
increases  are  small  compared  to  business-as-usual  Moreover,  Option  B,  D  and  E  are 
designed in a way where domestic producers and importers of appliances will face the 
same conditions for placing products on the market and hence EU producers of F-Gases 
and F-Gas equipment will, even though costs may increase, not be put at a disadvantage 
which  could  harm  their  international  competitiveness.  Furthermore,  the  activity  of 
servicing/maintenance is not subject to international competition.  

However,  if  Option  D  did  not  include  measures  to  target  imported  substances  in  pre-
charged equipment, only domestically produced products would be affected by the cap 
which  would  represent  a  competitive  disadvantage  for  equipment  producers.  Such  a 
concern  was  expressed  by  companies  and  industry  associations  in  the  stakeholder 

EN 

38 

   EN 

 
 
  
survey.  Sectors  of  concern  would  predominantly  be  stationary  AC  systems59  and  to  a 
lesser  degree  AC  systems  of  imported  vehicles.  The  numbers  of  producers,  importers 
and  exporters  of  pre-charged  equipment  can  be  estimated  as  shown  in  Annex  X.  The 
measures on pre-charged equipment, namely the requirement to fill on site, would treat 
domestically  produced  and  imported  equipment  in  the  same  way.  Claims  that  such  a 
requirement  would  lead  to  higher  production  costs  for  foreign  manufacturers  are 
unfounded.  According  to  expert  estimates  additional  costs  would  be  in  the  order  of 
€0.50 per unit produced in the worst case.60  

Exports of products and equipment containing HFCs are only relevant in a few (sub)-
sectors: mobile  ACs  (motor  vehicles),  MDIs (Metered Dose Inhalers: 50% of demand 
exported)  as  well  as  XPS  foam  insulation  boards  (20%  of  demand  exported;  compare 
Table A_X-3/4 in Annex X). HFCs used in this equipment are put on the market in the 
EU and would therefore fall under the phasedown, which may lead to higher costs. In 
the  automotive  sector  a  shift  to  low  GWP  substances  is  already  on-going  due  to  the 
MAC Directive and extra costs compared to the product (vehicle) price are small.  

Whether  trade  flows  will  change  depends,  in  general,  on  the  different  abilities  to 
produce products relying on alternative technologies. Option D, E and B will create an 
EU demand that spurs development of alternative technologies to a varying extent, with 
the  phasedown  having  the  highest  potential  to  enhance  the  demand-driven  capacity  to 
innovate.  Many  stakeholders  in  the  on-line  consultation  and  stakeholder  conference 
pointed  out  that  an  EU  pioneering  role  for  alternatives  could  result  in  a  competitive 
"first  mover"-advantage  for  European  companies  at  the  international  level,  if  a  global 
agreement to phase out F-Gases is reached. Many of those industrial stakeholders who 
expressed  concerns  on  competitiveness  due  to  unilateral  EU  action  preferred  a 
phasedown measure (Option D) over bans (Option E) due to its flexibility (Annex II).  

However,  since  it  is  not  a  priori  clear  that  costs  can  be  passed  on  to  the  user,  it  is 
appropriate  to  also  look  at  the  possible  effects  of  costs  on  the  expected  increase  in 
demand  (and  sales)  from  the  affected  products.  The  increase  in  (annualised)  costs  for 
the  operators  investing  in  new  equipment  based  on  alternative  technologies  has  been 
compared with the annualised costs (of using the specific technology) under the baseline 
for  those  eight  subsectors  that  are  faced  with  the  highest  absolute  costs  or  have  a  big 
share in the investments (See Annex VI for details). Table 11 shows the increase in total 
annual  costs.  Differences  between  the  policy  options61  are  apparently  small.  The 
expected  annualised  increase  in  investment  and  operation  costs  of  new  equipment  is 
highest  for  centralised  systems  of  commercial  refrigeration  and  lowest  for  industrial 
refrigeration (with expected decreases). For all the other sectors overall costs and total 
costs are small. These increases in costs may have some effect on the expected increase 
in  demand  (sales)  for  the  affected  products  (see  Annex  VI,  Table  A_VI-2).  Evidence 

59 
60 
61 

Ca. 3.5 million units sold in the EU in 2008, projected to be 10.4 million units in 2030 
Personal communication from Oeko-Recherche 
Option C affects only one sector. 

EN 

39 

   EN 

 
                                                 
shows that the elasticity of demand (for AC and refrigeration) is rather small (-0.37)62; 
e.g. an increase in expected cost of multi-split AC of 1.6% may therefore lead only to a 
direct reduction in demand of -0.6%. Hence, this indirect impact of costs increase on the 
expected  increase  in  demand  for  equipment  will  also  be  rather  small.  By  way  of 
example,  under  Option  D  sales  of  centralised  commercial  refrigeration  systems  would 
increase by 774 million per year (see Annex XVII). As a result of the annual cost (and 
price)  increase,  demand  might  drop  and  the  increase  sales  might  not  increase  by  774 
million, but only by 760 million for that sector (See Annex XVII). In the worst case the 
expected increase in sales (and investments) for all sectors addressed could be up to 1% 
smaller than the increase in output expected because some consumers will refrain from 
buying the new equipment. 

A second issue is the impact of the additional costs for those sectors that are buying the 
new equipment. The sectors that use commercial refrigeration see their costs increase by 
up to 4.8% in the case of centralised systems. The refrigeration costs are however only 
part of the total costs for these companies and can be distributed over a large range of 
products (e.g. in the case of supermarkets), so the costs increase will be very small. The 
sectors that use industrial refrigeration experience a decrease in the costs (up to 1.4%) 
which  will  decrease  their  total  costs  to  some  degree  with  positive  impacts  on  output. 
Stakeholders in this area, e.g. FoodDrinkEurope, only wanted to be reassured that there 
will  be  no  forced  replacement  of  existing  equipment.  Replacement  of  end-of-life 
equipment by alternative equipment was not considered a problem. None of the policy 
options entail bans on the use of existing HFC appliances and hence will not force users 
to scrap equipment before its end of life. Large supermarket chains are already making 
voluntary  efforts  to  introduce  alternatives  at  large  scales.34  For  the  other  selected 
subsectors, the additional costs linked to new investments are between -1.4 and 2% of 
the costs associated with the baseline F-Gas equipment. It is apparent that even for those 
sectors with additional costs at the high end, the additional costs per unit compared to 
baseline unit costs remain low and impacts on end-users are therefore expected to be 
rather small.  

(2004).  Appendix  10  A.  Relative  price  elasticity  of  demand 

62  DOE 
for  appliances. 
(http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/home_appliances_tsd/appen
dix_10a.pdf.).  Department  of  Energy,  Washington.  Based  on:  Golder,O  and  G.  Tellis  (1998)  Beyond 
diffusion: an affordability model of the growth of new consumer durables, Journal of Forecasting, 17, pp 
259-280  and    D.  Revelt  and  K.  Train  (1997)  Mixed  logit  with  repeated  choices:  household  choices  of 
appliances efficiency level, Review of economics and statistics (July). 

EN 

40 

   EN 

 
                                                 
 
Table 11: Average change in annualized costs for operators investing in new equipment 

compared to the baseline scenario (Option A: % change) 

Condensing units commercial refrigeration 

Centralized Systems 
commercial refrigeration 

Bus AC 

Trucks and trailers AC 

Single-split Room AC 

Multi-split AC 

Industrial refrigeration large 

Chillers 

B 

0.9 

4.7 

n/a 

n/a 

n/a 

0.0 

0.0 

0.0 

C 

n/a 

n/a 

n/a 

1.2* 

n/a 

0.0 

0.0 

0.0 

D 

0.9 

4.8 

2.1 

0.1 

1.6 

0.8 

E 

0.9 

4.7 

n/a 

0.0 

1.6 

0.0 

-1.4 

-1.4 

0.4 

0.4 

Source: Annex VI and Schwarz et al. 2011 (p. 243-272)9. Costs include capital costs, interest costs as well 

as all other costs (* costs linked to containment and recovery provisions only) 

The  impacts  on  competitiveness  (i.e.  on  output  and  trade  (imports  and  exports))  have 
also  been  analysed  with  the  GEM-E3  model  for  Options  D  and  E,  which  entail  the 
highest  costs.  Table  12  summarises  the  results  per  economic  sector.63  Impacts  are 
generally very small, with highest effects in the range of -0.13 and -0.16 for production 
and exports in the chemical sector under Option D. Effects on imports are even smaller 
(see Annex XIV for details). Based on the model, the impacts on output and trade are 
therefore expected to be small, with negative or positive effects depending on the 
sector. 

63 

The modelled scenario assumes that costs of the right to use F-gases are allocated for free and 
their (opportunity) costs are not passed on to the final price.  Other scenarios were also modelled 
(see Annex XIV). 

EN 

41 

   EN 

 
 
 
                                                 
Table  12:  Impacts  on  production  and  exports  per  sector  for  Options  D  and  E  in  2030  (% 

change compared to baseline) 

OPTION  

Agriculture 

Chemical 

Coal 

Construction 

Consumer goods 

Electric Goods 

Production 

Exports 

D 

E 

D 

  0.01 

-0.13 

-0.01 

  0.01 

  0.01 

  0.04 

0.01 

-0.06 

-0.01 

0.00 

0.00 

0.02 

Electricity 

-0.01 

-0.01 

Energy Intensive 

Gas 

Market services 

Metals 

  0.00 

  0.01 

  0.00 

  0.02 

Non-market services 

  0.00 

Oil 

Other equipment 

Transport 

  0.00 

  0.02 

  0.00 

Transport Equipment 

  0.02 

Source: GEM-E3  

0.00 

0.00 

0.00 

0.01 

0.00 

0.00 

0.02 

0.00 

0.01 

E 

0.03 

-0.07 

0.08 

0.01 

0.01 

0.01 

0.01 

0.01 

0.02 

0.01 

0.01 

0.01 

0.01 

0.01 

0.00 

0.01 

0.03 

-0.16 

0.07 

0.01 

0.02 

0.03 

0.01 

0.01 

0.05 

0.02 

0.02 

0.03 

0.02 

0.03 

0.01 

0.02 

6.2.7.  Third countries and international relations 

At international level measures on the reduction of F-Gas emissions, in particular HFCs 
are being considered. The initiative to control HFCs under the Montreal Protocol has so 
far  not  been  successful,  even  though  already  in  2010  more  than  108  Parties  to  the 
Montreal Protocol expressed support for this approach.64 

All options for the reduction of HFC emissions would demonstrate the determination of 
the  EU  to  tackle  increasing  F-Gas  emissions.  The  underlying  analysis,  which 
demonstrates that the use of HFC alternatives is technically feasible and cost-efficient, 
will strengthen the EU position in further negotiations on an international agreement on 

64 

EN 

Annex III to the Report of the Twenty-Second Meeting of the Parties to the Montreal Protocol 
on  Substances 
2010. 
ozone.unep.org/Meeting_Documents/mop/22mop/MOP-22-9E.pdf 

the  Ozone  Layer,  Bangkok,  November 

that  Deplete 

42 

   EN 

 
 
 
 
 
                                                 
HFCs. The adoption of a phasedown (Option D) and of bans (Option E) would create a 
substantial market for low-GWP technologies and thus incentivise the development of 
such technologies also in exporting third countries. It can be expected that these market 
opportunities will also result in higher penetration rates of such technologies in non-EU 
countries,  even  if  these  countries  do  not  support  binding  commitments  through  an 
international agreement at the present stage.  

Bans  on  certain  new  applications  (Option  E)  apply  equally  to  domestically  produced 
and imported products and equipment. Nevertheless, some third country producers have 
voiced  that  they  would  consider  bans  to  be  de  facto  discriminatory  vis-à-vis  imports 
because those producers would not set-up a new production line to serve the EU Market 
only. The complementary measures on certain equipment pre-charged with HFC (part of 
Option  D)  addresses  imports  as  well.  The  proposed  measures  have,  therefore,  to  be 
notified under the TBT (Agreement on Technical Barriers to Trade). 

6.2.8. 

Impacts on consumer prices 

Effects on consumer prices depend on the extent that producers or retailers pass through 
any  additional  costs  they  may  experience.  Potential  effects  on  consumer  prices  can 
easily  be  categorised  based  on  abatement  costs.  Those  measures  that  exhibit  negative 
abatement  costs  (see  Annex  VI)  can  be  assumed  to  impose  no  or  positive  (through 
reduced prices) effects on consumers. Table 11 shows the increase in annualized costs 
for  the  consumer  for  the  most  affected  products  in  case  costs  would  be  fully  passed 
through.  Higher  costs  of  equipment  are  to  a  large  degree  compensated  by  decreased 
operating  costs.  Costs  of  domestic  refrigeration  are  hardly  affected  (€0.004/year  for 
option D) and annual costs of AC (single-split, multi-split or chillers) might increase by 
0.4  to  1.6%.  It  can  therefore  be  expected  that  the  effect  on  specific  as  well  as 
general consumer prices will remain small for all policy options. This is confirmed 
by the GEM-E3 results which suggest a macroeconomic price effect between -0.01% to 
+0.00% for Options D and E depending on cost pass-through. 

6.2.9. 

Impacts on innovation and research 

Legislation  could  drive  innovation,  economic  development  and  green  jobs  in  Europe. 
By  way  of  example,  Denmark  has  successfully  supported  alternatives  backed  up  by 
strict national F-Gas legislation and has seen important increases in the use of natural 
refrigerants in RAC equipment. While market shares of e.g. commercial and industrial 
refrigeration equipment using natural alternatives are still low today in Europe, market 
prospects in Europe as seen by industry are very good in the field.65  

Options  B,  D  and  E  promote  the  use  of  alternative  substances  and  technologies. 
Therefore, these policy options would stimulate research and development and facilitate 
the  development  and  dissemination  of  new  production  methods,  technologies  and 
products. These effects would be largest for Option D, followed by Options E and B. 
Option  E  provides  binding  legal  requirements  driving  the  innovation  process  just  like 
Option  D  but  would  affect  a  smaller  number  of  sectors.  In  Option  B  the  driver  for 

65 

Shecco  (2012).  "GUIDE  2012:  Natural  Refrigerants  –  Market  Growth  for  Europe". 
guide.shecco.com  

EN 

43 

   EN 

 
                                                 
innovation is based only on voluntary commitments and less sectors would be covered, 
so a smaller effect than for D and E is expected. Option C, the improvement of the F-
Gas  Regulation  does  not  require  new  technologies  and  innovations  to  the  extent  that 
Options  B,  D  and  E  do  and  would  therefore  have  only  minor  positive  impacts  on 
innovation and research. 

6.2.10.  Impacts on small and medium enterprises (SMEs: see also Annex III) 

The companies currently placing F-Gases on the EU market and reporting under the F-
Gas  regulation  were  classified  based  on  the  number  of  employees  and  the  annual 
turnover. As a result, 36% of the affected companies are large, 15% medium, and 26% 
small enterprises (for 23% data found was not sufficient to fully categorize their status). 
Producers  of  F-Gases  are  almost  exclusively  large  companies,  while  wholesalers, 
distributors,  import/export  companies  and  service  companies  are  often  SMEs.  SMEs 
and microenterprises are also found as operators/end-users of relevant equipment, e.g. in 
the food and drink industry. 

Many  SMEs  in  the  F-Gas  sector  are  wholesalers  who  would  be  less  affected  by 
additional  substantive  costs  because  policy  Options  B,  C,  D  and  E  do  not  require 
adaption  of  their  service  delivery  processes  in  a  substantial  way.  In  addition,  SMEs 
placing on the market only small quantities of HFCs benefit from the foreseen minimum 
thresholds  for  the  application  of  the  phasedown  mechanism  under  Option  D.  On  the 
other hand, Option E would affect importers of foreign equipment relying strongly on F-
Gases, as pointed out at the stakeholder meeting and the on-line consultation. Option D 
would provide more flexibility to allow foreign producers to adapt, and thus would be 
preferable to Option E for SME importers.  

As  for  producers  of  equipment  it  should  be  emphasised  that  a  strengthened  policy 
approach  (in  particular  Options  D  and  E)  would  provide  opportunities  for  small 
innovative  companies.  Denmark  has  successfully  supported  alternatives  by  national 
legislative measures and support to R&D and thus stimulated market growth of Danish 
SMEs in the sector.7, 66 

As for companies servicing F-Gas equipment, the effects explained above (6.2.2) will 
also  affect  small  enterprises  as  demand  for  the  enhanced  maintenance  requirements 
under the F-Gas regulation should decline in the long run when less F-Gases would be 
used in equipment. However, at least in the medium term this should not be noticeable 
to service companies as the containment obligations stemming from the existing F-Gas 
Regulation are only slowly being fully understood and implemented on the ground by 
affected companies, leaving a lot of growth potential for the service sector in this field. 
Furthermore,  the  inclusion  of  additional  sectors  in  existing  maintenance  requirements 
should create additional demand for servicing companies just as novel equipment using 
alternatives will create new service and maintenance needs, in particular for substances 

66 

Founded  at  the  same  time  as  the  entry  into  force  of  the  Danish  ban  on  certain  HFC  uses,  a 
Danish start-up, founded by 2 persons in 2006, succeeded in becoming a leading brand for CO2 
refrigeration technology. 

EN 

44 

   EN 

 
                                                 
that are flammable and/or used at high pressures. Making best use of such opportunities 
will however require initial investments in particular with regard to training.67 Finally, 
service  companies  which  have  limited  their  business  activities  to  leak  checking  and 
recovery usually are also involved in the installation of new equipment and its on-site 
construction (and would profit from the latter activities under a strengthened approach, 
in particular if on-site filling is prescribed). In summary, even though F-Gas servicing 
needs due to the existing Regulation would decline in particular for the most effective 
policy options, SMEs in the service sector will experience new business  opportunities 
under a strengthened approach (i.e. in particular D and E), so that they are not expected 
to suffer any significant negative consequences.  

As  for  SMEs  in  sectors  that  might  be  indirectly  affected  (as  suppliers  or  sellers  of 
products/services to end-users, e.g. foodstuff, clothing, gastronomy,..), the discussion in 
6.2.2  (and  Fig.  9)  showed  that  such  effects  are  very  small  overall,  with  some  sectors 
providing input to the machinery and equipment sector affected positively, while very 
small  negative  effects  on  the  products-for-endusers  sectors  could  occur.  All  policy 
options aim at reducing the use of F-Gases with high GWP in new equipment and do 
not  force  the  replacement  of  old  equipment.  Hence,  SMEs  would  not  be  burdened 
with any new costs for replacing existing equipment. This is particularly relevant for the 
competitiveness of SMEs and microenterprises in the food-and-drink industry.68  

Options  B  and  D  would  impose  a  (small)  additional  administrative  burden  on 
companies for the verification of the reported information (see 6.2.3). It is the intention 
to introduce quantitative thresholds similar as is the case for reporting requirements to 
protect small companies, especially microenterprises. 

6.3. 

Social impacts 

In the following  impacts on  employment and safety,  occupational and health risks are 
presented.  All  other  types  of  social  impacts,  including  rights  related  to  job  quality, 
social inclusion of particular groups, gender issues, governance issues, access to justice 
of media, crime and security, culture or social protection are not affected by any of the 
proposed policy options. 

6.3.1.  Employment impacts and labour market 

Net employment effects of the policy options were analysed in detail including: 

(1)  Direct employment effects at the level of regulator or regulated entities;  

67 

68 

AREA, the European organisation of refrigeration, AC and heatpump contractors, who represent 
ca. 9000 servicing companies that are mostly SMEs and micro-enterprises, is already working on 
guidance documents and qualification requirements related to the use of low GWP refrigerants.  
www.area-eur.be/_Rainbow/Documents/AREA%20-
%20PP%20Low%20GWP%20refrigerants%20(110629).pdf  
There are 274,000 food and drink companies in Europe, 99.1% of which are SMEs. SMEs also 
accounted for 48.7% of turnover and 63% of employment in the food and drink industry in 2010.  

EN 

45 

   EN 

 
                                                 
 
(2) 

Indirect employment effects that occur further up the production chain as 
a  result  of  the  increased  investment  activity  in  specific  sectors  or 
economic areas; 

(3)  Employment  effects  induced  through  demand  shifts  that  i)  occur  to 
finance  the  investments  (demand  reduction)  or  ii)  result  from  revenue 
recycling, e.g. increased government expenditure (demand increase). 

In  the  following,  employment  effects  of  Options  B  (voluntary  agreements),  D 
(phasedown) and E (bans) are compared. Option C was not analysed in detail because 
its  limited  scope  means  that  costs  are  very  small  and  employment  effects  therefore 
negligible. Based on the EmIO-F Europe Input-Output model (see Annex IX) and EU27 
employment data for 2007, the effect of additional investments, reduced running costs 
and  consumer  reaction  on  employment  was  estimated.  Fig.  10  shows  employment 
effects  for  those  activity  areas  directly  impacted  by  the  change  in  F-Gas  policy.  The 
effects  are  in  line  with  the output  effects  discussed  previously  (6.2.2).  As  most  of  the 
change in activity is related to additional investment in machinery and equipment, the 
(positive) effect is most pronounced in this area. On the other hand, the model predicts 
negative effects for services and maintenance. The overall effect on service companies 
is, however, likely to be more balanced (see discussion in 6.2.2). Electricity demand is 
lower  for  new  equipment,  hence  a  negative  effect  on  employment  in  this  area  is 
observed.  The  same  is  true  for  the  chemicals  sector  which  shows  positive  but  rather 
small  effects.  For  Option  D,  the  effects  are  more  pronounced  (both  positive  and 
negative)  than  for  the  other  two  options,  as  more  sectors  are  involved,  with  a  small 
overall positive benefit on employment. As discussed before the impacts on sales (and 
investments) might be somewhat smaller (1%) if costs are passed through in prices and 
lower  sales  of  equipment,  e.g.  the  total  effect  for  machinery  (option  D)  would  not  be 
0.3%, but only 0.297%.  

Phase-Down

Ban

VA

Services/
maintenance

Electricity

Machinery/

equipment

Chemicals

0.40%

0.30%

0.20%

0.10%

0.00%

-0.10%

-0.20%

-0.30%

-0.40%

Fig.  10:  Employment  effects  for  activity  areas  in  directly  impacted  sectors  (%  of  2007  sector 

employment) based on EmIO-F Europe 

EN 

46 

   EN 

 
 
 
Fig.  11  details  employment  effects  based  on  EmIO-F  Europe  for  selected,  indirectly 
affected sectors. Positive effects occur for those sectors providing inputs for production 
to  the  machinery/equipment  sector  (basic  metals  and  metal  products),  while  small 
negative  effects  occur  in  the  retail  and  consumer  goods  sectors  due  to  the  reduced 
demand by consumers.  

Phase-Down

Ban

VA

0.06% 

0.05% 

0.04% 

0.03% 

0.02% 

0.01% 

0.00% 

-0.01% 

-0.02% 

Retail

trade

Hotel and 

Tobacco

Clothing

restaurant 

Basic 
metals 

Metal 
products 

Fig.  11:  Employment  effects  on  selected,  indirectly  impacted  sectors  (as  %  of  2007  sector 

employment), based on EmIO-F Europe 

Fig. 12 summarises direct and indirect employment effects for policy Options B, D and 
E in terms of number of jobs created, based on EmIO-F Europe. All sectors related to 
investment  expenditures  will  experience  a  stimulus,  while  ongoing  expenditure  would 
be reduced and thus affect employment negatively, and consumer reaction might lead to 
less sales due to higher prices. In total, Option D would have a net total positive effect 
on  employment  of  around  7180  jobs,  Option  E  would  have  a  net  effect  of  3740  and 
Option  B  would  create  around  630  net  jobs.  The  net  effect  on  employment  are  small 
positive effects in case of Option D and to a lesser degree, for Option E, while almost 
no effect is observed for Option B. 

EN 

47 

   EN 

 
 
 
Phase-Down

Ban

VA

Ongoing 
expenditure

Consumer
reaction 

Investment
expenditure

Total

60,000

50,000

40,000

30,000

20,000

10,000

0

-10,000

-20,000

-30,000

-40,000

Fig. 12: Effect on employment (number of employees), EmIO-F Europe model 

For comparison, employment impacts for Option D and E have also been estimated with 
the  macro-economic  GEM-E3  model  (Annex  XIV)  for  Option  D  and  E.  The  results 
differ somewhat from EmIO-F: 1600 jobs could be lost by Option D; in case costs are 
passed on to consumers the net employment would decrease further to -15,800 jobs (In 
case  rights  to  use  F-gases  would  be  auctioned  and  revenues  used  to  cut  labour  costs 
impacts  would  be  positive:  +5400  jobs)  Option  E  would  have  similar,  but  smaller 
impacts of -1,000 to -11,600 in case of costs pass-on (and +4000 in case of auctioning) 
Since  GEM-E3  does  not  account  for  the  fact  that  F-Gas  imports  are  addressed  by 
measures, the impacts shown are likely to be overestimated. Overall, both models agree 
on the magnitude of effects, which are in the order of several thousand jobs created or 
lost. By comparison, these numbers are small compared to the total number of jobs in 
2030 (some 231 million jobs in the EU as a whole), representing a maximum effect of -
0.007% in the worst case.  

In  conclusion,  both  models  predict  small  effects  in  the  order  of  up  to  several 
thousand jobs in case of a strengthened F-Gas Regulation, an effect that is highest 
for the phasedown mechanism (Option D). 

6.3.2. 

Safety, occupational and health risks 

Many substances used in abatement technologies are flammable and therefore constitute 
a  potential  occupational  hazard.  Hydrocarbon  (HC)  refrigerants  such  as  already 
commonly  used  in  private  fridges  are  classified  as  highly  flammable  and  unsaturated 
HFC refrigerants which are also likely to be used as substitutes for HFCs have recently 
been  classified  as  “mildly  flammable”  69.  This  classification  also  applies  to  ammonia 

69 

The unsaturated HFC-1234ze, which is considered not only a possible alternative refrigerant (for 
centrifugal chillers) and aerosol propellant but also an alternative blowing agent for XPS foam, 
is  not  flammable  at  room  temperature  (<30°C).  However,  the  process  temperature  on  foam 
blowing is significantly higher than 30°C so that adequate safety measures must be taken in the 
factory, comparable to those when hydrocarbons/organic solvents are used. 

EN 

48 

   EN 

 
 
 
                                                 
(NH3)  and  e.g.  HFC-32.  Some  substances  are  toxic  (NH3),  and  some  are  operated  at 
high pressures (CO2). 

The  feasibility  analysis  of  replacement  substances  for  the  different  application  sectors 
carried  out  by  Schwarz  et  al.  (2011)9  which  forms  the  basis  for  the  effectiveness  and 
efficiency  assessment  of  the  policy  options  is  based  on  the  precondition  that  only 
proven and safe (and energy-efficient) alternative technologies should be deployed. For 
this  reason  health  and  occupational  risks  for  alternatives  as  a  result  of  the  policy 
options  are  not  expected  to  be  high,  as  long  as  safety  standards  and  procedures  are 
followed. Even though no comprehensive data to quantify the increased health risks due 
to the use of flammable HCs or highly pressurised CO2 and NH3 systems at larger scale 
seems  to  be  available,  the  use  in  some  sectors  such  as  commercial  and  industrial 
refrigeration  is  already  widespread  in  Europe  without  giving  rise  to  a  high  number  of 
accidents.  

Halogen-free  alternatives  such  as  propane,  butane  (HCs),  CO2  received  a  more 
favourable  toxicological  rating  than  F-Gases  and  pose  no  health  risks  to  employees  if 
regulations are observed. Given proper handling, NH3 is also an acceptable alternative 
substance  for  refrigeration  purposes.4  Product  design  must  take  the  flammability  or 
pressure  needs  into  account,  e.g.  combustible  substances  are  contained  in  enclosed  or 
encapsulated explosion-proof systems only. Health risks from flammable substances for 
non-professionals are met by technical safety standards and safety installations (charge 
limits  in  occupied  spaces,  operation  in  indirect  mode  for  higher  charges,  etc.).  Health 
risks  for  professionals  as  a  result  of  improper  handling  or  installation  cannot  be  fully 
ruled  out  but  can  be  minimised  by  appropriate  training  and  education,  which  is 
obligatory  for  persons  who  come  into  contact  with  dangerous  substances,  and  is 
prescribed by existing legislation (F-Gas Regulation). It is considered to include in the 
legal  proposal  the  need  for  training  requirements  for  certified  personnel  handling 
alternatives  in  order  to  further  minimise  any  safety  risks.  The  costs  for  training  and 
education are already included in the investment costs of equipment, which is based on 
alternative technologies such as HCs, ammonia or CO2. Stakeholders pointed out during 
the consultation that different safety standards and regulations in Member States should 
be  harmonised  in  order  to  minimise  risks  but  also  to  avoid  that  different  standards 
remain a barrier to innovative solutions and internal trade. 

7. 

COMPARING THE OPTIONS  

Table 13 compares the most important impact parameters for all policy options vs. the 
baseline (Option A). 

Option D, the HFC phasedown mechanism complemented by measures on pre-charged 
equipment  achieves  the  highest  environmental  effectiveness,  i.e.  the  fastest  and 
largest  replacement  of  HFCs  with  high  GWP.  Options  E  also  achieves  considerable 
emission  savings  albeit  significantly  lower  than  Option  D,  while  Option  B  and  C 
achieve much less emission reductions altogether.   

EN 

49 

   EN 

 
 
Table 13: Summary table of environmental, economic and social impacts of the policy options 

IMPACTS 

Option B 

Option C 

Option D 

Option E 

Vas 

Enlarged Scope 

Phasedown 

Bans 

ENVIRONMENTAL 

Emission Reductions 

SUM [Mt CO2eq] 

22.2 

1.4 

70.7 

53.3 

Ecotoxicological Relevance 

low risk 

negligible 

low risk 

low risk 

ECONOMIC 

Average abatement costs 

[€/t CO2eq] 
Total 
[(M€/year] 

direct 

Administrative 
[M€/year] 

costs 

costs 

Direct  effects  on  sector 
output  

[ % of 2007, I/O model] 

- machinery/ equipment 

- services/ maintenance 

- chemicals 

- electricity 

GDP  impacts  (%  change, 
GEM-E3 model) 

Impacts Regions 

Impacts SMEs 

17 

527 

10.7 

46 

66 

0 

16 

1,499 

0.2 

(+ 1.9 one-off) 

0.006 

negligible 

0.009 

0.38 

-0.09 

-0,19 

-0.19 

negligible 

negligible 

negligible 

negligible 

0.52 

-0.38 

0.17 

-0.59 

17 

1,286 

1.2 

0.003 

0.23 

-0.37 

0.03 

-0.26 

smaller than D 

negligible 

-0.006 

-0.003 

negligible 

negligible 

no significant 
effects 

negligible 

small effects on 
EU South 

smaller than D 

no significant 
effects 

no significant 
effects 

Internal market 

none 

none 

Competiveness,  trade  & 
investment 

small 

negligible 

Third countries 

negligible 

negligible 

none 

small 

positive for 
alternatives 

incentivises 
alternatives 
globally 

None 

Small 

positive for 
alternatives 

incentivises 
alternatives 
globally 

Consumer prices 

negligible 

negligible 

negligible 

negligible 

Innovation & research  

facilitates to 
low degree 
new 
technologies 

negligible 

facilitates new 
technologies 
and products 

facilitates new 
technologies 
and products 

SOCIAL 

Employment: 
2030 [No. of jobs] 

impact 

in 

+600 

negligible 

Safety & health risks 

negligible 

negligible 

-16,000 to  
+7,000 

negligible 

-12,000 to 
+4,000 

negligible 

EN 

50 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
All policy  options achieve their respective emission reductions cost-efficiently, i.e. 
at abatement costs below 50€ / t CO2eq. 

Economic impacts on GDP, employment, industry sectors, regions, etc. are low in 
general.  Due  to  the  higher  use  of  replacement  substances  in  Option  D  the  total  direct 
costs are highest, but lead to stronger positive sectoral effects in some areas (machinery 
and equipment) but small negative effects in others (services and energy). SMEs are not 
expected to face considerable negative effects, but for Options D and E there is a small 
effect  on  Southern  European  countries.  Options  D  and  E  are  the  only  options  that 
will strongly stimulate innovation and market uptake of green technologies. 

Additionally,  administrative  costs  are  relatively  low  for  all  options,  but  highest  for 
Option B mostly due to the need for additional verified reporting by a high number of 
companies affected. 

The qualitative ranking in Table 14 below further summarises environmental, economic 
and social effects, using 0 for neutral effects, +/++/+++ for positive impacts and –/--/--- 
for costs and negative impacts. For the economic impacts mainly the abatement costs, 
the  administrative  costs  and  effects  on  output  were  considered  for  the  ranking.  This 
table  clearly  indicates  the  most  positive  total  impact  of  policy  option  D,  the  HFC 
phasedown mechanism complemented with measures on pre-charged equipment.  

Only  Option  D  is  fully  effective  as  regards  the  objectives,  as  only  this  option  would 
make  a  sufficiently  large  contribution  in  emissions  reductions  to  the  low  carbon 
roadmap at the levels needed to take overall cost-efficient mitigative action (see Table 
14). This is achieved at levels that are considered cost-efficient (at < €50 / tonne CO2) 
according to the Roadmap. Option D also stimulates innovation and comes at a low cost 
to  the  economy  and  society  as  a  whole  while  giving  flexibility  to  industry.  It  is 
therefore the only policy option that is coherent with the objectives.  

Table 14: Ranking of policy options 

IMPACTS 

Option B 

Option C 

Option D 

Option E 

VA's 

Enlarged scope 

Phasedown  

Bans 

ENVIRONMENTAL 

ECONOMIC 

SOCIAL 

Cost-Effective  Contribution 
to Roadmap 

+ 

0 

0 
No (emission 
reductions 
only capture 
30% of cost-
effective 
actions) 

0 

0  

0 

+++ 

0 

0 

++ 

0 

0 

No (emission 
reductions 
negligible) 

Yes (all 
emission 
reductions up to 
cost-efficient 
level captured) 

No (emission 
reductions only 
capture 75% of  
cost-effective 
actions 

EN 

51 

   EN 

 
 
 
 
As  set  out  in  section  5.6,  all  policy  options  are  not  mutually  exclusive.  By  way  of 
example, Option C is complementary to all the other policy options and could therefore 
be  implemented  alongside  e.g.  Option  D.  Some  bans  in  Option  E  are  also 
complementary to Option D, e.g. if they concern F-Gases not covered by the phasedown 
(SF6 in magnesium die casting) and the mandatory destruction of HFC-23, or could be 
implemented  alongside  to  address  low-hanging  fruits  in  sectors  where  the  use  of 
alternatives is already commonplace, i.e. domestic and commercial refrigeration. 

In this way, Option D implemented together with Option C, as well as complementary 
bans  on  emissive  uses  of  SF6,  mandatory  destruction  of  HFC-23  by-production, 
together  with  action  on  domestic  and  commercial  refrigeration  would  achieve  an 
emission reduction of ca. 72 Mt CO2eq. All economic and social effects would for all 
practical  purposes  be  identical  to  Option  D,  as  this  option  alone  addresses  the  vast 
majority of sectors and applications of such a package. 

Stakeholders  including  many  industrial  umbrella  groups  have  also  to  a  large  degree 
expressed  their  preference  for  a  package  of  measures  at  the  stakeholder  conference 
meeting  and  as  a  main  element  would  prefer  a  phasedown,  as  opposed  to  use  bans 
(Annex II).  

8. 

MONITORING AND EVALUATION  

The main objective is to reduce emissions and deliver a fair, cost-efficient contribution 
from the F-Gas sector to mitigative action, e.g. the Low Carbon Roadmap. Effectiveness 
of the chosen policy option as regards emissions can be closely followed in the future 
through the reporting of GHG emissions by Member States to the UNFCCC70 and the 
EU Monitoring Mechnism71, which includes emission data on F-Gases. 

Furthermore,  the  baseline  (Option  A)  allows  the  annual  collection  of  data  on  bulk  F-
Gases  in  the  EU  due  to  existing  reporting  requirements  in  the  current  F-Gas 
Regulation2. These obligations apply to companies producing, importing or exporting F-
Gas quantities and preparations >1 tonne and reports are to be submitted annually to the 
EC  and  the  competent  authorities  of  the  Member  State  concerned.  Data  is  currently 
available for the years 2007-2010. 

This  existing  reporting  scheme  under  the  F-Gas  Regulation  is  generally  suitable  for 
retrospectively  verifying  the  bulk  F-Gas  quantities  placed  on  the  EU  market  and  also 
provides important data for an effective monitoring and evaluation of the policy options 
discussed.  Additional  monitoring  and  reporting  needs  arise  in  the  following  areas  to 
ensure the evaluation of the effectiveness of the implemented F-Gas policies as well as 
coherence with possible international obligations: 

70 
71 

EN 

unfccc.int/ghg_data/ghg_data_unfccc/items/4146.php 
Decision  280/2004/EC  of  the  European  Parliament  and  of  the  Council  of  11 February 2004 
concerning a mechanism for monitoring Community  greenhouse  gas 
for 
implementing the Kyoto Protocol. 

emissions 

and 

52 

   EN 

 
                                                 
 
 
– 

– 

– 

– 

– 

– 

– 

Extend  coverage  of  substances  (to  meet  international  developments  and 
include unsaturated HFCs) 

Extend  the  company  reporting  requirements  to  quantities  contained  in 
imported  or  exported  pre-charged  products  and  equipment  (needed  for 
implementing Option D or E) 

Complement  the  one  tonne  threshold  for  company  reporting  with  a 
GWP-based  de  minimis  rule  (for  implementing  Option  D)  of  1,000  t 
CO2eq  per  year  (on  average  similar  in  magnitude  to  the  one  tonne 
threshold which already applies under the current regulation72) 

Introduce  reporting  obligations  for  reclamation  and  destruction  of  F-
Gases by specialised facilities to fully monitor recovered HFC quantities 
from reuse/recycling or reclamation  

Additional  reporting  for  exporters  in  an  EU  phasedown  mechanism 
(Option D) 

Improve  reporting  systems  which  Member  States  need  to  calculate 
emission data under Art. 6(4) of the F-Gas Regulation  

Independent verification of company reports on POM to assure accuracy 
(Option D) 

Based  on  the  reporting  data  alongside  the  UNFCCC  emissions  data,  progress  on 
emission  reductions,  the  use  of  individual  substances  and  the  introduction  of 
alternatives,  the  performance  of  policies  and  their  environmental  impact  can  be 
calculated in the future. A review clause would be appropriate to take account of new 
technical  developments,  while  at  the  same  time  safeguarding  planning  certainty  for 
industry.73 

72 

73 

The abolition of the threshold had been considered but was discarded in Schwarz et al. 2011 as 
the  impact  on  the  accuracy  of  reporting  was  found  to  be  negligible  and  would  not  justify  the 
additional administrative burden. 
F-Gas  producers  indicated  that  lead  times  of  10  years  are  needed  for  an  adequate  planning 
process. 

EN 

53 

   EN 

 
 
                                                 
AC 

AnaFgas  

CFCs   

COP 

CO2eq  

COM   

CN  

CRF 

EC 

EEA 

ANNEX I: Glossary of Terms  

Air conditioning 

Analysis of Fluorinated GHGs in EU-27 (bottom-up stock model 
to derive demand and emission scenarios for F-Gases in relevant 
sectors and sub-sectors for the EU-27) (see Annex IV) 

Chlorofluorocarbons (belong to ODS) 

Conference of parties 

CO2 equivalents 

European Commission 

Combined Nomenclature 

Common reporting format (UNFCCC) 

European Commission  

European Environment Agency 

EmIO-F (Europe) 

Employment  Input-Output  Model  for  Analysis  of  Policies  and 
Measures for the European Union (see Annex IX and XV) 

ETS 

FAR  

F-Gases 

GEM-E3 

GHG 

GWP 

HCs 

HCFCs 

HF 

HFCs   

HFC-23 

Emission Trading System 

Fourth IPCC Assessment Report  

Fluorinated Gases: HFCs, PFCs and SF6 

macro-economic general equilibrium model (see Annex XIV and 
XV) 

Greenhouse gases 

Global warming potential 

Hydrocarbons, e.g. propane, butane 

Hydrochlorofluorocarbons (belong to ODS) 

Hydrofluoric acid 

Hydrofluorocarbons (belong to F-Gases) 

Trifluoromethane 

EN 

54 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HS code  

Harmonized System code 

IPCC 

International Panel on Climate Change 

LULUCF 

Land Use/Land Use Change/Forestry 

MAC Directive 

Directive 2006/40/EC relating to emissions from air-conditioning 
systems  in  motor  vehicles  and  amending  Council  Directive 
70/156/EEC 

MDI 

Mg 

MS 

NF3 

NH3 

OCF 

ODS 

ORC 

PFCs 

POM 

PU 

RAC 

SAR  

SF6 

SME 

SO2F2 

TAR 

TBT 

TFA 

Metered Dose Inhaler 

Magnesium 

Member State(s) 

Nitrogentrifluoride 

Ammonia 

One-component foams 

Ozone-depleting substances: e.g. CFCs, HCFCs, Halons 

Organic Rankine Cycle 

Perfluorocarbons (belong to F-Gases) 

Placing on the market 

Polyurethane 

refrigeration and AC equipment (includes heatpumps) 

Second IPCC Assessment Report 

Sulphurhexafluoride (belongs to F-Gases) 

Small and medium enterprise 

Sulfurylfluoride 

Third IPCC Assessment Report 

Agreement on Technical Barriers to Trade  

Trifluoric Acetic Acid 

UNFCCC 

United Nations Framework Convention on Climate Change  

EN 

55 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
(M)t CO2eq 

(million) tonnes CO2 equivalents 

VA(s)   

WAM   

WM 

WOM   

WTO   

XPS 

Voluntary agreement(s) 

Emission scenario for EU if F-Gas legislation is  
strengthened 

Emission scenario for EU if current F-Gas legislation is  
maintained unchanged (= baseline Option A) 

(Hypothetical) emission scenario for EU in the case that no EU F-
Gas legislation existed 

World Trade Organisation 

Extruded Polystyrene 

EN 

56 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX II: Stakeholder Consultations 

1. 

 CONFERENCE  REPORT  ON  STAKEHOLDER  MEETING  IN  BRUSSELS,  13 
FEBRUARY 2012  

1.1. 

Conference Objectives 

The  meeting  aimed  at  informing  stakeholders  about  first  results  of  the  online 
stakeholder consultation, as well as options for future action. A second objective was to 
provide  a  platform  for  an  open  exchange  of  views  with  stakeholders  to  conclude  the 
consultation process. 

1.2. 

Summary of Presentations and Interventions 

– 

Presentations 

Consultants from Öko-Recherche presented their preparatory study for the review of the 
Regulation on certain fluorinated gases (F-Gas Regulation), focusing in particular on the 
feasibility  and  cost-effectiveness  of  alternatives  in  different  sectors,  and  calculating 
future  penetration  rates  for  these  alternatives.  They  also  screened  the  most  promising 
policy options in terms of effectiveness of emission reductions, cost efficiency, energy 
efficiency, technical constraints and other criteria such as coherence with other policies. 
The highest emission reduction potential was achievable by limiting the amounts of F-
Gases  placed  on  the  market  ("phasedown"),  followed  by  bans  and  by  voluntary 
agreements.  

Subsequently,  DG  CLIMA  presented  the  Commission's  review  report  (COM  (2011) 
581) of 26 September 2011, which assessed the current state of implementation of the 
F-Gas  Regulation,  its  impacts  and  long-term  adequacy  of  reducing  the  climate  effects 
due  to  F-Gas  emissions.  Some  shortcomings  in  the  implementation  of  the  Regulation 
were highlighted. A full implementation could enable a stabilisation of F-Gas emissions 
at today's levels. In view of the climate goals and a growing feasibility of replacing F-
Gases in many sectors with alternatives, further cost-effective reductions of greenhouse 
gas  emissions  were  justified.  Potentially,  up  to  2/3  of  today's  emissions  could  be 
eliminated in the EU by 2030. 

DG CLIMA presented initial results from the online stakeholder consultation that took 
place from September to December 2011. 261 stakeholders replied to this questionnaire 
of  which  77%  came  from  the  industrial  sectors.  Almost  all  stakeholders  agreed  there 
was a need for further action on F-Gases compared to the status quo and over 40% of 
respondents also considered further legislative action to be necessary. Many suggestions 
for improving containment were also made. On the question of the most adequate policy 
approaches there were quite divergent views and sectoral differences. In addition, some 
industry  respondents  expressed  concerns  as  regards  their  competitiveness,  while 
manufacturers  of  equipment  using  alternatives,  administrations,  NGOs  and  many 
individuals  saw  concrete  benefits  in  a  shift  away  from  F-Gases,  especially  for  fast 
movers. 

EN 

57 

   EN 

 
DG  CLIMA  then  presented  the  current  state  of  play  regarding  the  reflections  on 
potential EU action in the field of F-Gases in order to reach the EU climate goals in a 
cost-effective way. The Commission was currently assessing further the environmental, 
economic  and  social  impacts  of  major  policy  options  such  as  voluntary  agreements, 
improving  containment,  progressively  limiting  the  supply  of  F-Gases  ("phasedown"), 
and  possible  bans  on  the  use  of  F-Gases  in  certain  applications.  These  options  were 
being considered on top of a full application of the existing F-Gas Regulation. Given the 
need to address different F-Gases, different uses and varying availability of alternatives 
as  well  as  old  and  new  equipment  and  products,  a  mix  of  policy  measures  appeared 
necessary. The Commission planed to adopt a legislative proposal in the second half of 
2012.  

– 

Discussion and Comments 

Stakeholders were invited to provide feedback, in particular, on what package of F-Gas 
measures could best meet the objective of contributing consistently and cost-effectively 
to the EU 2050 greenhouse gas emission reduction target.  

Almost all stakeholders took the floor.  

• 

A large majority of industry acknowledged the need for further EU action 
and preferred or could live with a phasedown option as it was considered 
to  be  more  flexible  than  bans  and  would  allow  industry  to  adapt  and 
continue  using  F-Gases  in  applications  where  this  was  considered  to  be 
the  optimal  solution.  NGOs  and  a  few  industrial  participants  favoured 
bans  where  alternatives  to  F-Gases  would  lead  to  lower  overall 
greenhouse  gas  emissions  and  NGOs  saw  a  phasedown  rather  as  a 
complementary measure to bans. Others, such as importers of equipment, 
pointed  out  that  bans  would  be  detrimental  to  their  business.  A  few 
participants wanted to focus on containment only. Member States had no 
official positions yet, but indicated support for a phasedown measure. 

•  Many would also like to see action at the global level and encouraged the 
Commission  to  endeavour  to  get  an  agreement  through  the  Montreal 
Protocol 
to  avoid  unfair  competition  and  a  need  for  product 
differentiation between the EU market and markets elsewhere.  

• 

A need for a mix of policies was confirmed by many stakeholders. 

Other comments mentioned by some stakeholders included: 

• 

Full implementation and application of the current legislation should be 
ensured. 

•  Measures related to containment of F-Gases should be strengthened and 
the scope should be extended. Also, requirements regarding "end of life" 
treatment should be enhanced. 

EN 

58 

   EN 

 
• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

The  experiences  with  voluntary  agreements  were  very  mixed.  Such 
agreements  were  favoured  by  some,  whereas  others  did  not  consider 
them to be adequate and enforceable.  

A level playing field should be ensured. Consequently, the chosen mix of 
policies should affect imported products containing F-Gases to the same 
extent as products produced and used in the EU and it should not hamper 
export. It could be considered to tax gases in  pre-charged equipment or 
require the installation of the gas to be done by certified personnel in the 
EU.  

It  would  be  unfair  to  introduce  bans  on  the  use  of  F-Gases  in  products 
that could be substituted by products not subject to bans, e.g. banning F-
Gases in certain foams while leaving other foams unregulated. 

Existing equipment should not be made redundant; therefore, it would be 
crucial  that  potential  bans  target  only  the  use  of  F-Gases  in  new 
equipment. 

Product  liability  issues  should  be  taken  into  account  for  alternative 
technologies that were e.g. flammable. 

Different safety and building codes across the EU represented barriers to 
the use of alternatives and EU harmonisation should be considered.  

Availability of F-Gases should be safeguarded for certain necessary uses 
in e.g. in fire protection and medical aerosols.  

Training  and  certification  rules  for  personnel  dealing  with  alternative 
technologies  should  be  harmonised  to  ensure  sufficiently  trained 
contractors in order to enable uptake of alternatives and to limit distortion 
of competition. 

Alignment with other policies, e.g. requirements related to environmental 
performance  of  energy  related  products  (ecodesign)  and  waste  was 
essential.  Impacts  on  energy  efficiency  should  be  further  assessed,  in 
particular for heat pumps. 

Sufficient time for transition and clear dates would be needed to enable 
industry to plan ahead. 

Effects on SMEs should be considered. 

Policy  should  promote  a  direct  shift  to  natural  refrigerants,  while 
intermediate  steps  involving  first  a  shift  to  F-Gases  with  a  lower  GWP 
and  subsequently  to  natural  refrigerants  would  be  costly  and  should  be 
avoided. 

EN 

59 

   EN 

 
• 

To  avoid  use  of  SF6  in  switchgear,  the  EU  should  ban  the  use  in  the 
future  and  at  the  same  time  jointly  finance  with  industry  R&D  on 
alternative uses to SF6 in large switchgear since currently alternatives do 
not exist. 

• 

HFC23 destruction should be made mandatory 

The following questions were raised by stakeholders: 

• 

The  findings  of  the  Öko-Recherche  study  show  a  high  feasibility  to 
replace  F-Gases  with  natural  refrigerants.  Why  are  F-Gases  with  low 
GWP not included as alternatives to a higher extend in the model? 

Öko-Recherche  response:  The  EU  objective  is  to  reduce  emissions  cost  effectively 
hence,  where  technically  feasible  and  cost  effective  (costs  lower  than  50  €  per  CO2 
equivalent  in  2030)  gases  with  no  recorded  GWP  have  been  favoured,  regardless  of 
whether a shift to relatively low GWP F-Gases would be less costly. A study conducted 
by ERIE/Armines confirms the Öko-Recherche results and gives similar metric tonnes 
by 2030 for the main application sectors, but is more limited in its scope. Alternatives 
were only taken into account if they could at least meet the energy efficiency related to 
technologies using conventional F-Gases. 

• 

Are other studies also considered in the impact assessment? 

DG CLIMA response: The Öko-Recherche study is a comprehensive study covering all 
sectors and F-Gases and it provides a good basis to develop policies. In addition, studies 
made by ERIE/Armines in 2011 and the German Umweltbundesamt in 2010 as well as 
an  upcoming  study  on  "banks"  by  SKM/ENVIROS  are  taken  into  consideration.  DG 
CLIMA  would  also  welcome  further  input  from  projects  announced  by  EPEE  on  a 
phasedown mechanism and by AREA on training requirements. 

• 

Have inadvertent emissions during production processes been considered 
in the study? 

Öko-Recherche response: No. 

• 

How would the trend for F-Gas projections be iF-Gases covered by the 
F-Gas Regulation alone and disregarding the MAC Directive? 

DG  CLIMA  response:  The  projected  F-Gas  emissions that are regulated by  the  F-Gas 
Regulation alone would increase in the future if no further action is taken. 

• 

Does the Commission have good experiences with voluntary agreements? 

DG  CLIMA  response:  The  voluntary  agreements  in  this  context  are  non-regulatory 
voluntary  agreements  between  industry  players.  The  experiences  with  that  type  of 
voluntary  agreements  appear  to  be  mixed.  The  semiconductor  industry's  agreement  to 
reduce perfluorocarbons has lead to a reduction in greenhouse gas emissions.   

EN 

60 

   EN 

 
•  Will  there  be  set-asides  for  necessary  uses  in  e.g.  fire  protection  and 

medical aerosols? 

DG CLIMA response: Needs for F-Gases where no cost efficient alternative exists are 
taken carefully into consideration.   

• 

Are taxes considered at EU level? 

DG  CLIMA  response:  EU-harmonised  taxes  requiring  unanimity  in  the  Council  and 
covering so many different sectors are difficult to establish at an optimal level and it is 
difficult  to  foresee  the  resulting  emission  reductions.  By  introducing  e.g.  cap  under  a 
"phasedown" the outcome is assured. Hence, at this stage an EU harmonised tax is not 
considered  as  a  relevant  option,  however,  Member  States  could  introduce  taxes  on  F-
Gases. 

•  Will training measures be included into the Regulation? 

DG  CLIMA  response:  The  Commission  is  considering  all  options  including  possible 
measures related to training.  

• 

How will pre-charged equipment be handled? 

DG  CLIMA  response:  We  are  looking  into  this  with  a  view  to  ensure  a  consistent 
approach to reduce emissions and a level playing field for producers inside and outside 
the EU. 

•  Will the impact assessment be made public? 

DG CLIMA response: Yes, when the Commission adopts a legislative proposal it will 
be accompanied by an impact assessment in the form of a staff working paper. 

1.3. 

Concluding remarks 

DG CLIMA thanked participants for the comments made at the meeting and during the 
online stakeholder consultation and underlined that the comments were very useful for 
the further work on the impact assessment and the legislative proposal.  

DG  CLIMA  noted  that  proper  implementation  of  existing  legislation  was  crucial  and 
that Member States had been asked to step up their efforts. The meeting had revealed a 
large  consensus  on  the  need  for  further  EU  legislative  action  and  a  preference  for  a 
"phasedown" mechanism as a key driver while noting that a phasedown can be designed 
in many ways. Also, given the complexity of the subject a mix of measures would be 
appropriate. Moreover, many had flagged the need to work towards a global phasedown 
under  the  Montreal  Protocol.  Finally,  many  called  for  more  harmonisation  of,  in 
particular, safety requirements. 

DG  CLIMA  mentioned  that  this  conference  was  seen  as  the  last  step  in  a  long 
consultation process with stakeholders which started in 2010 with an expert stakeholder 

EN 

61 

   EN 

 
group following the preparatory study by Öko-Recherche, included the 3-month online 
stakeholder consultation as well as this open stakeholder conference. DG CLIMA would 
further  analyse  all  the  contributions  obtained  and  thoroughly  examine  the  impacts  of 
different policy options and work on the legislative proposal foreseen later in 2012. 

**** 

EN 

62 

   EN 

 
1.4. 

Agenda of meeting 

STAKEHOLDER MEETING  

On a Review of 

REGULATION (EC) NO 842/2006 OF THE EUROPEAN PARLIAMENT AND 
OF THE COUNCIL “ON CERTAIN FLUORINATED GREENHOUSE GASS” 

Monday 13 February 2012 – 10:00 / 17:00 HOURS 

Room 0A, Centre de Conference Albert Borschette, Rue Froissart 36, B-1049 
BRUSSELS 

1. 

Opening  

2. 

Presentation by Öko-Recherche GmbH of the Preparatory study for a 
Review  of  the  Regulation  on  certain  fluorinated  greenhouse  gass 
(Regulation (EC) No 842/2006)  

- Questions and clarifications 

3. 

Presentation  by  DG  CLIMA  of  the  Commission  Report  on  the 
application,  effects  and  adequacy  of  the  Regulation  on  certain  fluorinated 
greenhouse gass (Regulation (EC) No 842/2006)); COM(2011) 581 final  

- Questions and clarifications 

4. 

Presentation  by  DG  CLIMA  of  the  results  of  the  online  stakeholder 

consultation on reducing fluorinated greenhouse gas emissions 

- Questions and clarifications 

5. 

Introduction by DG CLIMA of policy options to achieve cost-effective 

reductions of fluorinated greenhouse gas emissions  

- Exchange of views and statements 

6. 

Closing 

EN 

63 

   EN 

 
 
 
 
 
 
 
1.5. 

Registered Participants 

Surname 

First name  

BECKER 

Malte 

Electrolux Home Products Corporation N.V. 

TARABBIA 

Christian  Whirlpool EMEA 

D'HAESE 

Alain  

European Aerosol Federation (FEA) 

FOURNEAU 

Virginie  

Dehon Group 

Mr 

Mr 

Mr 

Ms 

Mr 

LELIÉVRE-DAMIT 

Alain  

Climalife - dehon group 

Ms 

MARTIN 

Delphine  

Climalife - dehon group 

Mr 

Mr 

Mr 

Mr 

Mr 

KUNZE  

Peter  

ACEA - European Automobile Manufacturers 
Association  

ELDER 

Alan 

EUROFEU 

CAMERON 

Alasdair 

Environmental Investigation Agency  

LARSSON 

Tove 

FoodDrinkEurope 

REESON 

Stephen 

FoodDrinkEurope 

Ms 

PAPAZAHARIOU 

Christiana 

LG Electronics France 

Mr 

Mr 

Mr 

Mr 

HWANG 

Herman 

LG Electronics France 

SCUMPIERU 

Mihai 

Mitsubishi Electric AC Systems Europe Ltd 

LOWRIE 

Richard 

Mitsubishi Electric AC Systems Europe Ltd 

NICOLLE 

Darcy 

AmCham EU 

Mr 

COWPERTHWAITE 

Stephen 

UK - DEFRA 

Mr 

Mr 

Mr 

Mr 

ANDERSEN 

Jacob 

UK - DEFRA 

WÖHRL 

Stefan 

German Association of the Automotive Industry 

MESSNER 

Kevin 

Association of home appliance Manufacturers 
(AHAM) 

HOOGKAMER 

Joop 

EUROVENT 

EN 

64 

   EN 

 
 
 
 
Ms 

Mr  

Ms 

Mr 

DHONT 

Hilde 

Daikin Europe N.V. 

DIERYCKX 

Martin 

Daikin Europe N.V. 

FLRTCHER 

Rory 

ASSURE Secretariat 

THIE 

Stefan 

JBCE  

Mr  

BAUMBACH 

Frank 

MAC Partners Europe 

Mr 

Mr 

Mr 

DIERYCKX 

Martin 

AGORIA 

GREALY 

Joe 

Transfrigoroute International 

STUMPF 

André 

Transfrigoroute International 

Mr  

McCARTHY 

Adam 

Johnson Controls 

Mr 

Mr 

Ms 

Mr 

Mr 

Ms 

Ms 

Mr 

Mr 

Mr 

Mr 

Mr 

Mr 

Mr 

Mr  

Mr 

BLACK 

Jon 

European Industrial Gases Association AISBL 
(EIGA) 

DEVIN 

Eric  

CEMAFROID SNC - France 

PIGACHE 

Claire 

EADS 

CAMPBELL 

Nick 

ARKEMA SA 

GOELLER 

Juergen 

Carrier EMEA and Carrier Transicold EMEA  

O'NEILL 

Michelle 

Ingersoll Rand International Ltd. 

WEIKER 

Christine 

European Cold Storage and Logistics Association - 
ECSLA 

BAUMEISTER 

Frank 

European Cold Storage and Logistics Association - 
ECSLA 

KENICHI 

Ichihara 

Fujitsu General  

LORENZO VOLPI 

Ilja 

CER 

JANIN 

Olivier 

AREA 

LINDLEY 

Andy 

Mexichem Fluor Ltd 

Nigel 

GRANT  

BEAMA Ltd 

CORDIOLI 

Giacomo 

ANIE-Energia (Italy) 

AMBROSI 

Robert 

Sub-Zero, Inc  

OETJEN 

Jan 

Sub-Zero, Inc  

EN 

65 

   EN 

 
Mr 

Ms 

ENGELHARDT 

Rolf 

DE - Federal Ministry for the Environment  

MUNZERT 

Elisabeth 

DE - Federal Ministry for the Environment  

Mr 

SATHIAMOORTHY 

Muhunthan  BP 

Ms 

ROBINSON 

Andrea 

BP 

Mr 

Mr 

Mr 

Mr 

MOSEMANN 

Dieter 

Eurammon 

BIASSE 

Jean-Marc 

T&D Europe 

PORTE 

Wim 

EATON 

DE HAAN 

Ton 

EATON 

Mr  

OTEGUI 

Enrique 

AFBEL 

Ms 

Ms 

Mr 

Ms 

Ms 

Ms 

Mr 

Mr 

Mr 

Ms 

Ms 

Mr 

Mr 

Ms 

VOIGT 

Andrea 

EPEE 

van der LOO 

Fanny 

EPEE 

SLEDSENS 

Ton 

Natuur & Milieu  

BECKEN 

Katja 

DE - German Federal Environment Agency 

ANGELOSANTE 

Antonella 

IT - Ministry for the Environment, Land and Sea 

SPINETTI 

Roberta 

IT - Ministry for the Environment, Land and Sea 

KATAOKA 

Osami 

JRAIA/JROAME 

MARATOU 

Alexandra 

Shecco 

RICHTERS 

Arne 

Shecco 

FINEL 

NURMI 

Nufar 

FI - Finish Environmental Institute 

Eeva 

FI - Ministry of Environment 

Nankivell 

Mike 

ACRIB 

RAUSCHER 

Nadine  

EXIBA 

CLARKE  

Jean 

IE - Department of Environment, Community and 
Local Government 

Ms  

COLLINS 

Caitriona 

EPA 

Mr 

GARNACHO 

Laura 
Gallego  

CAMBIO CLIMÁTICO – DEPARTAMENTO DE 
ECONOMÍA 

EN 

66 

   EN 

 
Mr 

Mr 

Mr 

Mr 

Mr 

Ms 

Ms 

Mr 

BEIGHTON 

Samuel 

Wragge & Co LLP. 

J. LEVINE 

Lewis 

Wragge & Co LLP. 

WALTHAUS 

Herman 

NL - Ministry of Infrastructure and Environment 

COCCIONI 

Renzo 

ZVEI - German Electrical and Electronic 
Manufacturers' Association 

BASSI 

Marino 

EMBRACO 

KÖPPEN 

Andrea 

EHI 

POPP 

Dana 

EHI 

KYLMALIIKKEIDEN 
LIITTO 

Suomen 

Finnish Refrigeration Enterprises Association 

Mr 

 KYLMAYHDISTYS 

Suomen 

The Finnish Society of Refrigeration 

Mr 

Ms 

Mr 

Mr 

Mr 

Mr 

Mr 

Mr 

Ms 

JONES 

Arthur 

Tyco International 

BORSKA 

Jana 

CZ - Ministry of Environment of the Czech Republic 

JUST 

Samuel 

FR - Ministère de l'Ecologie, du Développement 
Durable des Transports et du Logement 

CACCIATORI 

Federico 

ANIMA 

PAUWELS 

Marleen 

EFCTC (European Fluorocarbon Technical 
Committee) 

BONASO 

Carlo 

Frigo 2000 srl 

LINKE 

Wilfried  

BDH 

SCHMITT 

Peter Boris   Henkel AG & Co. KGaA 

RABAZAUSKAITE-
SURVILE 

Jurga 

LT – Ministry of Environment of the Republic of 
Lithuania  

Mr  

LAURINAVICIUS 

Vladislavas  Board of National Association of Refrigeration 

Mr  MARTINEZ-SCHÜTT 

Diego 

CDM Watch 

Mr 

Mr 

Ms 

Mr 

FRACCAROLI 

Nicola 

CDM Watch 

SZYMANSKI 

Rafal  

PL - Ministry of the Environment 

MATHIS 

Pamela 

ICF International 

AARNIO 

Ulriikka 

Climate Action Network Europe 

EN 

67 

   EN 

 
Mr 

Dr. 

Mr 

Mr 

Mr  

Ms 

Ms 

Mr 

Van GERWEN 

Rene 

Refrigerants Naturally  

THEWISSEN 

Harry 

EECA ESIA 

GOEMAN 

Bart 

3M Belgium 

BUREAU 

Maxime 

3M Belgium 

KRENZ 

Thorsten  

Deutsche Bahn 

LANDER 

Annika 

MAN SE 

CONRAD 

Silke 

Daimler AG 

LEE 

Nicholas 

PSA Peugeot Citroën 

Ms  MERCEDES VÁZQUEZ   MIRANDA  RED ELÉCTRICA DE ESPAÑA 

Dr. 

Mr 

Ms 

Ms 

Mr 

Mr  

Mr 

Mr  

Dr. 

Mr 

Ms 

Mr 

Ms 

Mr 

RAINER 

Jakobs 

IZW e.V. Information Centre of Heat Pumps and 
Refrigeration  

LENDERS 

Jan Willem 

The German Association of Energy and Water 
Industries  

SAAR 

Dorothee 

Deutsche Umwelthilfe e.V. 

NOURIGAT 

Cécile 

Burson-Marsteller 

SÉNÉJEAN 

Benoit 

ADHAC  

GROZDEK 

Marino 

HR - Ministry of Environment and Nature Protection 

LEMOINE 

Sébastien 

Carrier Transicold Europe 

ZBYSZEWSKI 

Sandamali  Acumen public affairs 

WYATT 

David 

IPAC 

HOFTJIZER 

Joris 

Westye Group Europe, Inc 

ÚJFALUSI 

Maria 

SE - Environmental Protection Agency 

AHMADZAI 

Husamuddin  SE -  Environmental Protection Agency 

SCACANOVA 

Klara 

R744.com 

DIEGUEZ 

Jorge 

Dupont 

Mr 

VANDERSTRAETEN  

Stefaan 

AGORIA 

Ms 

PERRY 

Clare 

EIA 

EN 

68 

   EN 

 
Ms 

Mr  

Mr 

Mr 

Mr 

JACOBI 

BASSO 

Reeli 

Ministry of the Environment 

Paolo 

European Photovoltaic Industry Association (EPIA) 

WILMART 

Alain  

BE - Ministry of Environment 

LEES 

Jeannine 

BE - Ministry of Mobility 

DAUWE 

Tom 

VITO 

Mr  

MOORKENS 

BONNE 

Ils 

Jan 

VITO 

MAYEKAWA 

Mr 

Dr 

Ms 

Mr 

Ms 

Mr 

Mr 

Ms 

Mr 

Ms 

SCHWARZ 

Winfried 

Öko-Recherche GmbH 

GSCHREY 

Barbara 

Öko-Recherche GmbH 

KIMMEL 

Thomas 

Öko-Recherche GmbH 

TRANHOLM -
SCHWARZ 

Bente (chair)  European Commission 

KASCHL 

Arno 

European Commission 

KLAASSEN 

Gerardus 

European Commission 

PLIMON 

Isabella 

European Commission 

KESTNER 

Matthew 

European Commission 

BASIN 

Bérangère 

European Parliament 

EN 

69 

   EN 

 
 
 
2. 

EXECUTIVE  SUMMARY  OF  THE  ANALYSIS  OF  THE  ON-LINE  STAKEHOLDER 
CONSULTATION 

2.1. 

Participation 

259 stakeholders participated in the online consultation, 95 identified themselves as individuals 
(37%) and 164 as organised stakeholders (63%). 77% of the organised stakeholders represented 
companies,  professional  associations  or  trade  unions;  the  remaining  organised  stakeholders 
included non-governmental organisations (NGOs) or associations of NGOs (7%), relatively few 
public authorities (3%) and some other organisations.   

62  stakeholders  were  active  at  EU  or  the  international  level,  e.g.  including  umbrella  groups, 
NGOs, and international companies. All major application sectors were covered. The stationary 
refrigeration sector accounted for 24% of stakeholders, stationary AC sectors for 21% and the 
heat pump sector for 24%.  

2.2.  Methodology 

As  regards  the  evaluation  of  the  results  a  quantitative  focus  based  only  on  the  number  of 
responses given to a particular option in this multiple-choice questionnaire is not appropriate for 
several reasons.  

1.  Industrial  stakeholders  clearly  outnumber  other  organisations  such  as  NGOs  and 

administrations.  

2.  Certain industries participated very actively whereas other application sectors replied at 
comparably  low  numbers;  hence  the  opinion  of  particular  sectors  is  overrepresented 
relative to the size of the sector.  

3.  Submissions  by  umbrella  organisations  and  associations  of  NGOs  would  in  a  purely 
quantitative approach be counted only once (just as the position of a single company) 
although they already represent concerted (and thus very valuable) positions of multiple 
members or even sectors.  

4.  Some companies replied more than once since national branches, different departments 
or daughter companies sent their responses separately, largely using the same text as the 
mother companies or headquarters.  

As a result a more differentiated approach to deriving results was taken by relating answers to 
the  type  of  respondents  giving  them.  Further,  qualitative  aspects  of  the  contributions  (e.g. 
textual  contributions)  were  integrated  into  the  analysis  and  particular  weight  was  placed  on 
concerted positions of umbrella organisations rather than single opinions.   

EN 

70 

   EN 

 
 
 
2.3. 

Policy action addressing F-gas emissions 

84%  of  respondents  found  that  the  current  status  quo  of  implementing  the  existing  regulation 
was not sufficient. While some stakeholders believed that better implementation would suffice, 
others wanted to see further legal action. Different opinions as regards the latter were linked to 
stakeholder types as well as sector particularities.   

As for obstacles preventing the switch to alternative technologies, the results indicated that the 
barriers differ between sectors. This reflects that safe and cost-effective alternatives are not yet 
available to the same degree in all application sectors. Overall, higher initial investments were 
the main barrier identified.  

In  the  absence  of  a  global  HFC  phasedown,  the  preferred  policy  actions  for  organised 
stakeholders  were  strengthening  containment  and  recovery,  voluntary  agreements  for  specific 
sectors, and limits to the placing of HFCs on the EU market, in this order. The options preferred 
by  individuals  were  additional  prohibitions,  strengthening  containment  and  recovery,  and 
voluntary agreements.  

Stakeholders provided numerous suggestions to improve containment and recovery pointing out 
the importance of control and enforcement of the existing legislation and harmonisation of the 
situation  within  the  EU  as  well  as  the  need  to  broaden  the  scope  of  the  existing  legislation. 
Further  propositions  included  measures  improving  awareness  and  information  exchange,  the 
introduction of financial incentives and taxes as well as some technical measures.   

2.4. 

Impacts of policy options 

When  asked  who  would  be  most  negatively  affected,  organised  stakeholders  and  individuals 
selected  most  often  the  commercial  or  industrial  end-users  of  relevant  products/  equipment  as 
well as producers of products/ equipment normally relying on F-gases. Individuals also assumed 
that F-gas producers would experience negative impacts, a concern not shared by the producers 
themselves.   

A  majority  of  industry  stated  concerns  on  a  strengthened  approach  with  regard  to  the 
competitiveness  of  European  businesses  in  general.  However,  impacts  were  likely  to  differ 
between  product  groups.  Also,  industry  associations  expressed  concerns  that  non-EU 
competitors  and  companies  not  covered  by  a  strengthened  approach  might  benefit.  It  was 
suggested that respecting industrial planning timescales would help minimize negative impacts. 
Also, it was important to avoid equipment redundancy before their end of life. 

Benefits of a strengthened approach would occur for manufacturers of products and equipment 
relying  on  alternatives  as  well  as  for  servicing  companies  and  users  of  relevant  products  and 
equipment.  Improved  containment  and  higher  energy  efficiency  due  to  regular  maintenance 
would result in advantages for end users. NGOs and public authorities highlighted competitive 
advantages in the alternative refrigeration and AC market.  

EN 

71 

   EN 

 
In  additional  comments,  environmental  NGOs  underlined  the  economic  and  environmental 
benefits for Member States and consumers that could be achieved through an HFC phase out. 
Measures  affecting  the  industry,  considered  to  be  responsible  for  HFC  use  in  the  first  place, 
were fairer than measures impacting users and service companies. Public authorities highlighted 
“marketing opportunities for fast movers”. 

Stakeholders saw no large differences for the different options in relation to the administrative 
burden. In sectors where certain reporting requirements already exist, it was suggested that the 
additional  administrative  burden  could  be  rather  small.  Established  monitoring,  consistent 
enforcement, control and sanctioning were considered crucial for the implementation of further 
measures.  Environmental  NGOs  pointed  out  that  sectoral  bans  on  use  and  marketing  would 
bring about the smallest administrative burden.  

2.5. 

General Conclusions 

•  Only a tiny minority of all respondents (2%) thought that no further action would be an 
appropriate response for the EU in the absence of progress at the global level. Similarly, 
only  10%  of  respondents  thought  the  current  status  quo  (i.e.  existing  legal  rules  and 
level of implementation) is sufficient. 

•  A great number of suggestions for improvement on implementation and containment of 
leakages  were  made.  In  addition,  over  40%  of  respondents  including  some  industrial 
players clearly indicated a need for further legal action. 

•  Stakeholders  were  divided  on  the  most  appropriate  policy  options.  This  was  linked  to 
stakeholder  type  (e.g.  industry,  NGO,  national  administration,..)  but  also  to  sectoral 
differences between industrial players. The preferred type of action largely depends on 
the  application  sectors  and  whether  requirements  already  exist  or  not.  This  seems  to 
indicate  that  there  is  no  magic  solution  in  the  form  of  a  single  policy  option  that  can 
address the complexities of the different sectors and applications. Over 500 suggested 
measures  collected  as  part  of  the  consultation  indicate  that  an  appropriate  mix  of 
policies may be the best way forward. 

•  The  expected  impacts  similarly  varied  according  to  interest  groups  and  application 
sectors. Many, but not all, industrial players expressed some concerns on the grounds of 
competitiveness. Other stakeholders including administrations, companies in the field of 
alternatives, NGOs and many individuals saw concrete opportunities and benefits in a 
shift away from F-Gases, especially for "fast movers" and "green technologies". 

•  Such  benefits  are  expected  in  particular  if  a  global  agreement  to  phase  down/out  F-

Gases can be achieved. 

EN 

72 

   EN 

 
 
ANNEX III: Consultations of SMEs  

Table A_III-1:  

The SME test 

(1) Consultation 
with SMEs 
representatives 

(2) Preliminary 
assessment of 
businesses likely to 
be affected 

See section 2.3, Annex II as well as the list of organisations given 
below 

See  sections  3.4,  6.2  (in  particular  6.2.2,  6.2.10)  as  well  as 
Annex II & information below 

Companies  currently  placing  HFCs  on  the  EU  market  and 
reporting under the F-Gas regulation were analysed: 36% of the 
affected  companies  are 
large,  15%  medium,  26%  small 
enterprises and for 23% no data was found to fully categorize the 
status.  

Small  companies  are  mostly  wholesalers,  distributors  and 
producers  of  equipment,  while  manufacturers  and  producers  of 
HFCs  in  Europe  are  almost  exclusively  large  companies.  In 
addition  SMEs  also  provide  service  and  maintenance  for  the  F-
Gas  sector  (e.g.  Art  3,  Art  4  existing  F-Gas  Regulation).  SMEs 
and  microenterprises  are  also  found  as  operators/end-users  of 
relevant equipment, e.g. in the food and drink industry. 

(3) Measurement of 
the impact on SMEs 

See  sections  6.2  (in  particular  6.2.2,  6.2.10)  &  7  as  well  as 
Annex II & information below 

The effects on SMEs have been analysed via  

(i) an assessment of direct abatement costs in different sectors, 

(ii) an Input-Output model (see Annex IX, XV), 

(iii) a general equilibrium model (Annex XIV, XV), and  

(iv)  a  qualitative  analysis  based  on  the  experience  with  the 
existing F-Gas regulation.   

Many  SMEs  are  wholesalers/distributors  which  will  be  less 
affected because the policy options B, C, D and E do not require 
adapting  the  nature  of  their  service  delivery  process  in  a 
substantial  way.  In  addition,  SMEs  placing  on  the  market  only 
small  quantities  of  HFCs  benefit  from  the  foreseen  minimum 

EN 

73 

   EN 

 
 
 
thresholds  for  the  application  of  the  phasedown  mechanism 
under  Option  D.  On  the  other  hand,  option  E  would  affect 
importers of foreign equipment relying strongly on F-Gases, as 
the  on-line 
pointed  out  at 
consultation.  Option  D  would  provide  more  flexibility  to  allow 
foreign  producers  to  adapt,  and  thus  would  be  preferable  to 
option E for SME importers.  

the  stakeholder  meeting  and 

As for producers of equipment it should be emphasised that a 
strengthened  policy  approach  (in  particular  Options  D  and  E) 
would  provide  opportunities  for  small  innovative  companies. 
Denmark  has  successfully  supported  alternatives  by  national 
legislative  measures  and  support  to  R&D  and  thus  stimulated 
market growth of Danish SMEs in the sector.6, 74 

As  for  companies  servicing  F-Gas  equipment,  the  effects 
explained  above  (6.2.2)  will  also  affect  small  enterprises  as 
demand for the enhanced maintenance requirements under the F-
Gas regulation should decline in the long run when less F-Gases 
would  be  used  in  equipment.  However,  at  least  in  the  medium 
term  this  should  not  be  noticeable  to  service  companies  as  the 
containment  obligations  stemming  from  the  existing  F-Gas 
Regulation  are  only  slowly  being  fully  understood  and 
implemented on the ground by affected companies, leaving a lot 
of  growth  potential  for  the  service  sector  in  this  field. 
Furthermore,  the  inclusion  of  additional  sectors  in  existing 
maintenance  requirements  should  create  additional  demand  for 
servicing  companies  and  companies  working  with  alternative 
technologies. Novel equipment using alternatives will also create 
new service and maintenance needs, in particular for substances 
that  are  flammable  and/or  used  at  high  pressures.  Making  best 
use of such opportunities will however require initial investments 
in particular with regard to training.75 Finally, service companies 
which have limited their business activities to leak checking and 
recovery  usually  are  also  involved  in  the  installation  of  new 
equipment and its on-site construction (and would profit from the 
latter activities under a strengthened approach, in particular if on-
site  filling  is  prescribed).  In  summary,  even  though  F-Gas 
servicing needs due to the existing Regulation would decline in 

74 

75 

Coincidentally with the entry into force of the Danish ban on certain HFC uses, a Danish start-
up, founded by 2 persons in 2006, succeeded in becoming a leading brand for CO2 refrigeration 
technology. 
AREA, the European organisation of refrigeration, AC and heat pump contractors, who represent 
ca. 9000 servicing companies that are mostly SMEs and micro-enterprises, is already working on 
guidance documents and qualification requirements related to the use of low GWP refrigerants.  
http://www.area-eur.be/_Rainbow/Documents/AREA%20-
%20PP%20Low%20GWP%20refrigerants%20(110629).pdf  

EN 

74 

   EN 

 
                                                 
 
particular  for  the  most  effective  policy  options,  SMEs  in  the 
service sector will experience new business opportunities under a 
strengthened approach (i.e. in particular D and E) so that they are 
not expected to suffer any significant negative consequences.  

As  for  SMEs  in  sectors  that  might  be  indirectly  affected  (as 
suppliers  or  sellers  of  products/services  to  end-users,  e.g. 
foodstuff,  clothing,  gastronomy,..),  the  discussion  in  6.2.2  (and 
Fig.  9)  showed  that  such  effects  are  very  small  overall,  with 
some  sectors  providing  input  to  the  machinery  and  equipment 
sector  affected  positively,  while  very  small  negative  effects  on 
the products-for-endusers sectors could occur. All policy options 
aim  at  reducing  the  use  of  F-Gases  with  high  GWP  in  new 
equipment and do not force the replacement of old equipment. 
Hence,  SMEs  would  not  be  burdened  with  any  new  costs  for 
replacing existing equipment. This is particularly relevant for the 
competitiveness  of  SMEs  and  microenterprises  in  the  food-and-
drink industry.76 

impose  a 

Options  B  and  D  would 
(small)  additional 
administrative burden on companies for the verification of the 
reported information (see 6.2.3). It is the intention to introduce a 
threshold  similar  as  is  the  case  for  reporting  requirements  to 
protect small companies. 

SMEs  expressed  the  view  during  the  consultations  that  the 
Commission  should  ambitiously  pursue  an  agreement  at  the 
global level, as producing for markets governed by different rules 
would  be  difficult  for  SMEs  that  target  global  markets.  Further 
information  on  the  consultation  process  with  SMEs  is  given  in 
Annex II.  

(4) Assess alternative 
options and 
mitigating measures 

Considering that policy option A (no policy change) will not lead 
to  a  reduction  in  F-Gases  in  line  with  the  low  carbon  roadmap, 
policy  options  B,C,D  and  E  have  to  be  considered.  The  content 
and  structure  of  these  policy  options  should  ensure  that  any 
plausible negative impacts on SMEs are minimized or averted. In 
addition to the general policy design, this is done via e.g. the use 
of thresholds:  

-  option  B  and  D  would 
impose  a  (small)  additional 
administrative  burden  on  companies  for  the  verification  of  the 

76 

There are 274,000 food and drink companies in Europe, 99.1% of which are SMEs. SMEs also 
accounted for 48.7% of turnover and 63% of employment in the food and drink industry in 2010.  

EN 

75 

   EN 

 
 
                                                                                                                                               
reported  information  (see  6.2.3).  It  is  the  intention  to  use  a 
threshold  (e.g.  10,000t  CO2eq.)  for  this  requirement  in  order  to 
protect 
disproportionate 
administrative  costs.  A  threshold  of  1000  tonnes  CO2eq  or  1 
metric  tonne  of  HFC  applies  to  the  reporting  requirements  (in 
average corresponding to the currently applicable threshold). 

enterprises 

small 

from 

any 

-  under  option  D  companies  need  quotas  to  place  HFCs  on  the 
market.  A  threshold  of  1000  tonnes  CO2eq  will  be  used  to 
exclude very small HFC market players. (see Annex X) 

The following organisations which include SMEs among their members were consulted 
during the on-line stakeholder consultation and/or the open stakeholder conference: 

European-level umbrella organisations 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

Alliance Froid Climatisation Environnement (AFCE) 

Eurofins 

Euroheat & Power 

European Aerosol Federation 

European Association of Refrigeration, AC, and Heat Pump Contractors 
(AREA) 

European Cold Storage and Logistics Association (ECSLA) 

European Committee of Domestic Equipment Manufacturers (CECED) 

European Committee of Air Handling and Refrigeration (Eurovent)  

European Garage Equipment Association (EGEA) 

European Heat Pump Association (EHPA) 

European Partnership for Energy and the Environment (EPEE) 

FoodDrinkEurope 

PU Europe 

T&D Europe 

EN 

76 

   EN 

 
 
 
– 

Transfrigoroute International (TI) 

National-level organisations 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

Agoria (BE) 

AC and Refrigeration Industry Board (ACRIB, UK) 

Asociación  de  Empresas  Gestoras  de  Residuos  y  Recursos  Especiales 
(ASEGRE, ES) 

Asociación de Fabricantes de Equipos de Climatización (AFEC, ES) 

Associazione Italiana Costruttori Antincendio (UMAN, IT) 

Associazione dei Tecnici del Freddo (ATF, IT) 

British Refrigeration Association (BRA, UK) 

Bundesverband  der  Deutschen  Energie  und  Wasserwirtschaft  (BDEW, 
DE) 

Bundesverband der Deutschen Giesserei-Industrie (BDG, DE) 

CLIMAFORT (FR) 

Conferederation of Employers and Industries of Spain (CEOE, ES) 

Fachverband der Elektro- und Elektronikindustrie (FEEI, DE) 

Fachverband der Gas- und Wärmeversorgungsunternehmen (AU) 

Fédération des services énergie environnement (FEDENE) 

Federation of Environmental Trade Associations (FETA, UK) 

Finnish Refrigeration Enterprices Association (FI) 

Fire Industry Association (FIA, UK) 

Heating, Ventilating and AC Manufacturers Association (HEVAC, UK) 

Österreichischer Kälte- und Klimatechnischer Verein (ÖKKV, AU) 

Polish Refrigeration and AC employers association (KFCh, PO) 

Turkish AC & Refrigeration Manufacturers` Association (ISKID, TU) 

Unie der belgischen frigoristen (BE) 

EN 

77 

   EN 

 
– 

– 

VKE – Norwegian Refrigeration and HVAC Association (NO) 

Zentralverband Elektrotechnik- und Elektronikindustrie e.V. (ZVEI) 

In addition single SMEs provided feedback incl.:  

– 

– 

– 

– 

– 

– 

– 

– 

Ambient control 

Calorex Heatpumps 

Clima-D 

Elektrotechnische Werke Fritz Diescher & Söhne 

Konvekta 

Lucas Rupp Weider Wärmepumpen 

Stratox 

Sub Zero 

EN 

78 

   EN 

 
ANNEX IV: Background Information on the Business as Usual 
Scenario (No Further Action – Option A)  

1. 

F-GAS EMISSIONS 

F-Gas emissions and the differences between the scenarios WM (= option A, no further 
legislative  action)  and  WOM  (=  without  existing  F-Gas  legislation)  are  presented  in 
Table A_IV-1 for selected years. The data in this table is calculated with GWP values 
from the 4th IPCC Assessment Report. 

Table A_IV-1:  

F-Gas emissions in EU-27 in the WOM and WM scenarios in 2000-2050 (kt 
CO2eq) and differences between the scenarios (kt CO2eq; %) 

2000 

2005 

2008 

2010 

2015 

2020 

2030 

2050 

WOM 

84,929 

90,335 104,013 116,114 144,580 164,561 183,928  204,162 

WM 

84,929 

90,335 103,104 113,253 113,666 118,489 103,657  110,824 

Diff in kt CO2 

Diff. In % 

0 

0 

0

0

909

2,861

30,914

46,072

80,271 

93,338 

0.9%

2.5% 21.4% 28.0% 43.6% 

45.7% 

F-Gas emissions as presented in Table A_IV-1 are derived from the model AnaFgas.77 
The modelled emissions are only partly based on emission data reported by the Member 
States  to  the  UNFCCC  in  form  of  CRF  (common  reporting  format)  tables,  although 
CRF data represent the best available empiric information source on F-Gas activity data 
and  emissions  in  Member  States.  Sectors  largely  relying  on  CRF  data  include  fire 
protection,  solvents,  semiconductor  manufacture,  primary  aluminium  production, 
production  of  halocarbons,  and  XPS  foam.  In  other  sectors  CRF  data  are  too  general, 
often  incomplete,  not  sufficiently  transparent  and  of  varying  quality.  For  this  reason, 
additional efforts were made to improve the emission data for fluorinated gases in these 
sectors. 

Numbers for current and historic emissions differ due to the use of different GWPs in 
the  calculations.  The  emissions  in  CO2eq  presented  herein,  such  as  Table  A_IV-1 
above, are calculated with GWPs from the IPCC 4th Assessment Report. These GWPs 
were  agreed  at  COP 17  as  the  future  metric  for  the  reporting  of  greenhouse  gas 
inventories after the 1st commitment period under the Kyoto Protocol. Previously, until 
the inventory reports for the reporting year 2012, GWPs from the Second Assessment 
Report of the IPCC were used. 

77 

A detailed description of the assumptions in model AnaFgas is provided in Annex III of Schwarz 
et al. 2011. 

EN 

79 

   EN 

 
  
 
                                                 
A comparison of the F-Gas emissions reported by CRF and F-Gas emissions calculated 
by  the  model  AnaFgas  has  been  undertaken  for  validation.  Table  A_IV-2  summarizes 
the total EU F-Gas emissions for the years 2000-2009. In the first line emissions from 
the recent CRF submission (EU CRF table 10s4.2) in 2011 are listed. The second line 
contains  total  F-Gas  emissions  from  the  model  AnaFgas.  For  this  validation  exercise, 
the  GWP  values  are  in  both  time  series  from  the  2nd  IPCC  AR  so  that  only 
methodological  differences  between  the  model  AnaFgas  and  the  greenhouse  gas 
inventories are reflected.  

Table A_IV-2:   Comparison  of  emission  estimates  between  AnaFgas  and  Member  States’ 

greenhouse gas inventories 

kt CO2eq  2000 

2001 

2002 

2003 

2004 

2005 

2006 

2007 

2008 

2009 

CRF 

66,205 63,833  66,949 69,303 70,113 73,485 74,657 78,551  80,950  81,352 

Model  

74,023 69,197  70,722 71,701 74,285 77,694 79,887 83,077  89,210  92,707 

Diff in % 

12%

8% 

6%

3%

6%

6%

7%

6% 

10% 

14% 

From the comparison it can be seen that: 

(1)  CRF reports and model output feature the same upward trend from 2001 

to 2009. 

(2)  The deviation between the annual emission data ranges between 3% and 

14%. 

(3)  The model emissions are always higher than the national greenhouse gas 

inventories. 

The  third  point  is  not  surprising  because  the  model  sets  completeness  standards 
equivalent  to  the  requirements  of  2006  IPCC  Guidelines  for  all  Member  States.  The 
2006 IPCC Guidelines are not yet legally binding for the inventory reporting and will 
only  be  binding  starting  with  the  inventory  submission  for  the  year  2013.  2006  IPCC 
Guidelines are considerably refined with regard to methodologies for fluorinated gases 
and  provide  methodologies  in  areas  in  which  current  IPCC  guidelines  lack  such 
methodologies.  Only  some  MS  already  report  these  additional  sources  of  F-Gases 
already  now  in  their  greenhouse  gas  inventories.  This  is  considered  to  be  the  main 
reason  for  the  deviation  between  the  modelled  emissions  and  the  reported  greenhouse 
gas inventories.  

EN 

80 

   EN 

 
 
2. 

THE MODEL ANAFGAS 

The model AnaFgas (Analysis of Fluorinated greenhouse gass in EU-27) is a bottom-up 
stock  model  to  derive  demand  and  emission  scenarios  for  F-Gases  in  relevant  sectors 
and sub-sectors for the EU-27 Member States (see Fig. A_IV-1). It models demand for 
and emissions of HFCs, PFCs and SF6 as well as HCFC-22 for the period 1995 to 2050 
based on market data and estimates of the quantity of equipment or products sold each 
year  containing  these  substances,  and  the  amount  of  substances  required  in  the  EU  to 
manufacture  and/or  maintain  equipment  and  products  over  time.  All  emission  and 
demand  estimates  are  derived  from  bottom-up  approaches,  i.e.  by  estimating  demand 
and  emissions  per  sector  through  the  use  of  underlying  driving  factors.  These  include 
annual changes in equipment stock, composition and charge of the equipment, leakage 
during equipment lifetime and during disposal.  

The lag between use of a chemical and actual emission of this chemical is reproduced. 
Aggregating emission and use over the different end-uses, the model produces estimates 
of total year-specific annual demand for and emissions of each substance expressed in 
metric tonnes or GWP-weighted (kt CO2eq). 

Seven sectors with a total of 29 sub sectors are separately represented in the model (see 
Figure  A_IV-1).  In  total  21  different  fluorinated  gases  (excluding  ozone-depleting 
gases)  are  included  in  the  model  (11  HFCs,  5  PFCs,  2  unsaturated  HFCs,  1 
fluoroketone, SF6, NF3) and calculations can either be based on metric tonnes or GWP 
(GWP). 

Figure A_IV-1:  Sectors and sub-sectors represented by the model AnaFgas 

EN 

81 

   EN 

 
 
3. 

HFC DEMAND AND EMISSIONS IN EU-27 UNTIL 2050 FOR DIFFERENT SECTORS 

In the following the projected emissions per sectors are presented. 

Total F-Gas emissions in the EU-27 are projected to remain at stable levels from about 
2010 onwards (Table A_IV-3). In spite of the containment measures of the existing F-
gas Regulation, emissions from stationary AC strongly increase by 25 Mt CO2eq until 
2050, due to increased use. In addition, emissions from the refrigeration sector increase 
by 5 Mt CO2eq from 2015 to 2050. As a result, the reduction in emissions from AC of 
motor vehicles by almost 30 Mt CO2 eq. is offset by 2050.  

Table A_IV-3: 

F-Gas emissions by sectors in EU-27 as projected in the baseline scenario 
(AnaFgas)  

F-gas emissions 

(kt CO2eq) 

2010 

2015 

2020 

2030 

2050 

Refrigeration 

39,347 

32,093 

34,363 

35,556 

37,277 

Stationary AC 

15,058 

20,641 

28,206 

36,992 

40,971 

Mobile AC motor vehicles 

32,526 

34,819 

28,293 

6,604 

6,889 

Mobile AC ships + rail 

1,999 

1,789 

1,812 

1,822 

1,846 

Foam 

Other 

3,299 

3,631 

3,974 

4,634 

5,746 

9,155 

9,503 

9,893 

10,143 

10,576 

- thereof MDI 

2,921 

3,065 

3,202 

3,453 

3,886 

Total HFC  

101,384 

102,476 

106,541 

95,750 

103,306 

Total  HFCs  w/o  mobile  AC 
motor vehicles 

68,858 

67,657 

78,248 

89,146 

101,460 

SF6  

5,452 

5,583 

6,966 

2,921 

2,533 

PFCs and haloproduction 

6,417 

5,607 

4,982 

4,986 

4,985 

Total 

113,253 

113,666 

118,489 

103,657 

110,824 

EN 

82 

   EN 

 
 
The  effect  of  containment  and  recovery  measures  set  out  by  the  F-gas  Regulation  is 
expected to occur in the period until 2015 if the provisions will be fully implemented 
and  applied.  The  sector  where  the  effects  of  containment  and  recovery  measures  are 
most  significant  in  absolute  terms  is  commercial  refrigeration  (Figure  A_IV-2).  After 
reductions  in  the  period  2010-2015  due  to  the  F-gas  Regulation,  constant  long-term 
levels for emissions and demand are projected. 

EU Commercial Refrigeration

q
e
2
O
C
t
k

40,000

35,000

30,000

25,000

20,000

15,000

10,000

5,000

0

2010

2015

2020

2025

2030

2035

2040

2045

2050

Emissions

Demand

Figure A_IV-2:  HFC  emissions  and  demand  (kt  CO2eq)  in  commercial  refrigeration  (2010-

2050), for EU-27 under baseline scenario.  

EN 

83 

   EN 

 
 
In  the  stationary  AC  and  heat  pump  sector  containment  provisions  apply  to  certain 
equipment with charges >3 kg. Effects of these measures will be offset by the growth in 
subsectors  with  equipment  of  charges  <3  kg  (Figure  A_IV-3).  Before  the  market 
becomes  saturated  in  2035,  considerable  growth  is  expected,  which  makes  stationary 
AC  the  largest  individual  HFC  sector  in  Europe.  In  this  graph,  demand  includes 
imported HFCs in pre-filled systems. 

EU Stationary AC +Heat Pumps

q
e
2

O
C
t
k

80,000

70,000

60,000

50,000

40,000

30,000

20,000

10,000

0

2010

2015

2020

2025

2030

2035

2040

2045

2050

Emissions

Demand

Figure A_IV-3:   HFC  emissions  and  demand  (kt  CO2eq)  for  stationary  AC  and  heat  pumps 

(2010-2050), for EU-27 under baseline scenario.  

EN 

84 

   EN 

 
 
4. 

F-GAS SOURCES CURRENTLY NOT ADDRESSED BY EU LEGISLATION 

At the moment, certain sources of F-Gas emissions in EU-27 are addressed neither by 
the F-Gas Regulation nor the MAC Directive. These sources include: 

– 

– 

– 

– 

– 

– 

– 

– 

HFC emissions from mobile AC systems contained in vehicles other than 
motor vehicles (ship AC and rail AC); 

HFC  emissions  from  mobile  refrigeration  systems  such  as  refrigerated 
trucks, refrigerated containers or fishing vessels; 

HFC emissions from foams other than OCF; 

HFC emissions from halocarbon production;  

HFC-23 by-product emissions; 

PFC  emissions  (e.g.  from  primary  aluminium  production  or  from  the 
semiconductor industry); 

SF6  emissions 
manufacture, particle accelerators, air-borne military radar systems, etc.; 

from  certain  applications  such  as  photovoltaic 

F-Gas emissions from Organic Rankine Cycles (ORC; i.e. generation of 
power from heat recovery). 

Emissions of other F-Gases not currently included in the scope of the F-Gas Regulation: 
NF3 emissions, SO2F2 emissions and emissions of unsaturated HFCs. 

EN 

85 

   EN 

 
ANNEX V: Technical Assessment of Environmental Impacts  

1. 

EMISSIONS FOR POLICY OPTIONS B, C, D, E VS. BASELINE (OPTION A) 

This Annex presents the F-Gas emission trends in the WM scenario (= no further policy 
action: option A) and the WAM scenario ("with additional measures")) for the different 
policy options. 

Option Voluntary Agreements F-gas Emission Reduction 
Reduction in emissions 2015-2050 (WAM vs. WM)

140,000

120,000

100,000

q
e
2

O
C

t
k

80,000

60,000

40,000

20,000

0

WM F-gas emissions
WAM F-gas emissions

2015

2020

2025

2030

2035

2040

2045

2050

Fig. A_V-1:   Maximum  F-Gas  emission  reduction  potential  (WAM)  of  the  option  B 
“voluntary  agreements”,  compared  to  F-Gas  emissions  in  the  WM  (baseline)  scenario  in  the 
period 2015-2050. Source: AnaFgas 

EN 

86 

   EN 

 
 
 
 
 
 
 
Option Application of Art3+4 to Refrigerated Trucks  
Reduction of F-gas emissions 2015-2050 (WAM vs. WM)

WM F-gas emissions
WAM F-gas emissions

q
e
2

O
C

t
k

130,000

120,000

110,000

100,000

90,000

2015

2020

2025

2030

2035

2040

2045

2050

Fig. A_V-2:  

F-Gas emission reduction potential (WAM) of the option C “Inclusion in the 
scope of Articles 3 and 4: Refrigerated road transport – trucks and trailers” 
compared to total F-Gas emissions  in the WM (baseline) scenario in 2015-
2050. Source: AnaFgas 

N.B.: The Y-axis does not start from 0 but from 90,000 ktCO2eq in order to better illustrate the difference 

between WM and WAM scenario. 

EN 

87 

   EN 

 
 
 
 
Option Limits  of Placing on the Market (POM)
Reduction in F-gas emissions 2015-2050 (WAM  vs. WM)

WM Emissions 

WAM Emissions

140.000

120.000

100.000

q
e
2

O
C
t
k

80.000

60.000

40.000

20.000

0

2015

2020

2025

2030

2035

2040

2045

2050

Fig. A_V-3:  

F-Gas  emission  reduction  potential  (WAM)  of  the  option  D  “Limits  of 
Placing  on  the  Market  of  HFCs”  compared  to  total  F-Gas  emissions  in  all 
sectors in the WM (baseline) scenario. Source: AnaFgas 

The emission reduction potential in 2030 amounts to 71.7 Mt CO2 eq, which is almost 
70% of the total F-Gas emissions of 103.7 Mt CO2 eq in 2030. 

EN 

88 

   EN 

 
 
 
Option Ban on open HFC applications: Reduction in F-gas 
em issions 2015-2050 (WAM vs. WM)

q
e
2

O
C

t
k

140,000

120,000

100,000

80,000

60,000

40,000

20,000

0

WM emissions
WAM emissions

2015

2020

2025

2030

2035

2040

2045

2050

Fig. A_V-4:  

Emission reduction potential (WAM) of the option “ban of use of HFCs for 
open applications” compared to total F-Gas emissions of the WM (baseline) 
scenario in the period 2015-2050. Source: AnaFgas 

N.B.:  "Open  applications"  include  (i)  non-medical  technical  aerosols  and  (ii)  HFC-134a  in  XPS  foam 

blowing, and form part of option E 

EN 

89 

   EN 

 
 
 
 
Option Ban of placing on the m arket of certain closed F-gas 
applications: Reduction in F-gas em issions 2015-2050 (WAM vs. WM)

140,000

120,000

100,000

q
e
2

O
C

t
k

80,000

60,000

40,000

20,000

0

WM emissions
WAM emissions

2015

2020

2025

2030

2035

2040

2045

2050

Fig. A_V-5:  

Emission  reduction  potential  (WAM)  of  the  option  “ban  of  the  POM  of 
certain  closed  applications  containing  HFCs”  compared  to  total  F-Gas 
emissions  of  the  WM  (baseline)  scenario  in  the  period  2015-2050.  Source: 
AnaFgas 

N.B.:  "Closed  applications"  include  commercial  refrigeration,  industrial  refrigeration,  transport 
refrigeration,  stationary  AC,  HFC-23  in  fire  protection,  SF6  in  Mg  die  casting,  and  mandatory 
destruction of HFC-23 

Bans  on  open  and  closed  applications  (Fig.  A_V-4  and  A_V-5)  together  make  up 
policy option E (refer to chapter 5.5 of main part). The emission reduction potential 
for  banning  both  open  and  closed  applications  in  2030  amounts  to  52.7  Mt  CO2eq, 
which is 50.4% of the total F-Gas emissions of 103.7 Mt CO2 eq in 2030. 

EN 

90 

   EN 

 
 
 
 
2. 

REPLACED UNITS IN EACH SECTOR AS A RESULT OF POLICY OPTIONS B, C, D 
AND E IN 2030 

Table A_V-1:  

Number of replaced HFC based stock units by policy options B, D and E in 
2030 for each sector 

Option 

Domestic Refrigeration
Commercial Refrigeration 
Hermetic Commercial 
Condensing units 
Centralized systems 
Industrial Refrigeration 
Industrial Ref small 
Industrial Ref large 
Transport refrigeration 
Refrigerated Vans 
Refrigerated Trucks 
Refrigerated Ships 
Mobile AC 
Ship AC 
Bus AC 
Truck AC 
Stationary AC 
Moveable AC systems 
Split AC systems 
Multi split AC systems
Rooftop AC systems 
Chillers 
Centrifugal chillers 
Fire protection 
Fire protection 227ea 
Fire protection 23 
Foam blowing 
XPS-152a 

Option B 
Voluntary 
agreements 

[stock units] 

Option E:  
Option Bans of use 
in certain open and 
closed applications 

Option D:  
Quantitative limits for 
placing on the market 
of HFCs 

[stock units] 

[stock units] 

not affected

not affected

5,737,300 
3,020,000 
144,900 

not affected 
not affected 

not affected 
not affected 
not affected 

not affected 
not affected 
not affected 

not affected 
not affected 
not affected 
not affected 
not affected 
not affected 

not affected 
24,500 

5,307,000 
2,421,300 
134,000 

500 
200 

not affected 
63,200 
not affected 

not affected 
not affected 
not affected 

34,283,800 
96,697,500 
1,376,200 
522,500 
714,600 
not affected 

not affected 
24,500 

2,783,400 

5,737,300 
3,020,000 
144,900 

6,000 
2,900 

601,800 
532,300 
400 

4,200 
609,400 
19,520,300 

3,428,380 
96,697,500 
1,570,583 
522,500 
771,866 
3,800 

48,600 
24,500 

not affected 

not affected 

13 (prod. lines) 

XPS-134a 

13 (prod. lines) 

13 (prod. lines) 

13 (prod. lines) 

PU other 
Other 
Aerosols 

Manufacture  of  HCFC-22 
and HFC-32 

Source: AnaFgas 

not affected 

not affected 

77 (prod. lines) 

not affected 

9,000,000 cans 

9,000,000 cans 

not affected 

not affected 

not affected 

EN 

91 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table A_V-2:  

Number of replaced HFC based stock units by policy options C in 2030 for 
each sector 

Option 

Domestic Refrigeration
Commercial Refrigeration
Industrial Refrigeration
Transport refrigeration
Refrigerated Vans 
Refrigerated Trucks 
Refrigerated Ships 
Mobile AC 
Stationary AC 
Fire protection 
Foam blowing 
Other
Aerosols 
Manufacture  of  HCFC-22  and  HFC-
32 

Option C: 
Extended Scope 

[stock units] 

not affected 
already covered 
already covered 

not affected 
631,000 
not affected 

already covered 
already covered 
not applicable 

not applicable 

not affected 

As  a  result  of  a  lower  number  of  affected  sectors  and  sub-sectors,  the  number  of 
replaced  units  is  the  lowest  under  the  option  “extended  scope”  (option  C:  only  one 
sector), followed by “voluntary agreements” (option B), “bans of the use of F-Gases in 
certain  applications”  (option  E)  and  is  highest  for  the  option  “limits  to  placing  on  the 
market” combined with measures on pre-charged equipment (option D).  

However, within the relevant sectors the number of replaced units also differs between 
policy  options.  In  sectors  which  could  theoretically  be  covered  by  any  of  the  three 
policy options, the number of replaced units in 2030 is often lower for “bans of the use 
of F-Gases in certain applications” (option E), compared to the other two options. This 
is due to the fact that the introduction of replacement solutions follows the penetration 
rates of these technologies in the options “voluntary agreements” (option B) and “limits 
to  placing  on  the  market”  (option  D),  i.e.  that  every  year  all  available  replacement 
solutions for new equipment are installed according to the penetration mix. In the option 
“regulatory bans of the use of F-Gases in certain applications” (option E) on the other 
hand, a ban can be established only when the penetration mix in the sector has already 
reached 100% (unless specific exemptions can be clearly defined). This leads to a delay 
in  the  replacement  of  HFC-based  systems,  and  consequently  to  a  lower  number  of 
replaced units in 2030 for option E. 

EN 

92 

   EN 

 
 
 
 
 
ANNEX VI: Assessment of cost impacts on sectors (Competitiveness proofing)  

1. 

ABATEMENT AND DIRECT COSTS 

Table A_VI-1:   Overview of cost impacts for the policy options at sub-sectoral level 

Subsectors affected 

Option B: Voluntary agreements 

Average emission 
abatement cost 

Direct net costs to 
sector* 

Direct cost per 
operator  

€/tCO2eq 

M€/year 

€ /year 

Commercial hermetics 

Condensing units 

Centralized systems 

Fire protection HFC-23 

XPS-134a78 

HFC-23 by-product emissions 

-0.8 

1.2 

23.7 

3.1 

1.0 

< 2 

-0.12 

105.0 

416.8 

3.18 

1.2 

0.55 

Total voluntary agreements 

16.8b 

526.6a 

Option C: Extended scope 

-0.02 

34.7 

2,876 

130 

98,000 
(production line) 

0.55 

- 

Trucks and trailers 

46 

66.4 

105.2 

Option D: HFC phasedown mechanism 

Domestic Refrigeration 

Commercial hermetics 

Condensing units 

Centralized systems 

Industrial Ref small 

Industrial Ref large 

Refrigerated Vans 

Refrigerated Trucks 

1.0 

-0.8 

1,2 

23.7 

-0.9 

-21.6 

45.1 

2.6 

0.01 

-0.12 

105.0 

416.8 

-0.92 

-65.9 

20.9 

16.8 

0.004 

-0.02 

34.7 

2,876 

-153 

-22,642 

34.7 

31.6 

78  

Considering  an  annual  output  of  a  typical  production  line  of  ca.  75,000  cubic  metres  of  foam, 
and a wholesale price of € 300 per cubic metre foam board, the annual production is worth over 
20 M€. Compared to this total value, the additional costs of € 98,000 account for only 0.5% of 
the annual output value of products and thus still represents only a small financial load 

to the operators. 

EN 

93 

   EN 

 
                                                 
 
Subsectors affected 

Fishing vessels 

Cargo ship AC 

Passenger ship AC 

Bus AC 

Truck AC 

Moveable AC systems 

Split AC systems 

Multi split AC systems 

Rooftop AC systems 

Chillers 

Centrifugal chillers 

Fire protection 227ea 

Fire protection 23 

Aerosols 

XPS-152a 

XPS-134a 

PU other 

Total limits placing on market 

Option E: Bans for POM 

Average emission 
abatement cost 

Direct net costs to 
sector* 

Direct cost per 
operator  

€/tCO2eq 

M€/year 

€ /year 

3.4 

16.7 

35.0 

48.5 

43.1 

8.9 

19,0 

13.1 

8.2 

5.9 

11.1 

22,3 

3.1 

10.0 

-1.6 

1.0 

3.5 

16.2 

1.96 

5.60 

2.90 

107.1 

243.9 

1.9 

488.7 

53.5 

11.8 

36.3 

1.49 

10.9 

3.18 

36.3 

5,368 

1,507 

6,190 

175.1 

12.5 

0.55 

5.1 

34.1 

22.5 

47.0 

381 

225 

130 

4.0 

-56,400 

-0.7 

(production line) 

1.2 

0.32 

98,000 
(production line) 

4,130 

1,499.00 

- 

36.3 

1.2 

37.5 

-4.64 

276.1 

n. e. 

98,000 
(production line) 

3.2 

-0.9 

34.0 

   EN 

Ban the POM of certain open applications containing F-Gases 

Aerosols 

XPS-134a 

Total ban open appl. 

10 

1 

7 

Ban the POM of certain closed applications containing F-Gases 

Commercial hermetics 

Condensing units 

EN 

-0.8 

1.2 

94 

 
Subsectors affected 

Centralized systems 

Industrial Ref small 

Industrial Ref large 

Refrigerated Trucks 

Moveable AC systems 

Split AC systems 

Multi split AC systems 

Rooftop AC systems 

Chillers 

Fire protection 23 

Total ban closed applications 

Average emission 
abatement cost 

Direct net costs to 
sector* 

Direct cost per 
operator  

€/tCO2eq 

M€/year 

€ /year 

23.7 

-0.9 

-21.6 

2.6 

8.9 

19.0 

13.1 

8.2 

5.9 

3.1 

16.9 

380.1 

-0.07 

-5.10 

0.96 

18.76 

488.72 

45.74 

11.78 

33.05 

3.18 

1,248.6 

2,835 

-153 

-22,642 

15.3 

0.5 

5.1 

33.2 

22.6 

46.3 

130.1 

- 

Mandatory destruction of HFC-23 emissions from halocarbon production 

Destruction of HFC-23 emissions 
to the extent possible 

n.e. = not estimated; n.a. = not applicable 

<2 

0.55 

n.a. 

*  In  option  E,  the  additional  direct  net  costs  to  the  sectors  include  the  additional  cost  for  equipment 
arising  to  the  operators  in  the  sectors,  not  only  the  sales  of  domestic  equipment  suppliers  to  the 
operators. 

Source: Schwarz et al.9: Table 8.24 with additional corrections  

EN 

95 

   EN 

 
 
2. 

ABATEMENT COST CURVE 

Fig. A_VI-1 shows that F-Gas emission reductions of ca 72 Mt CO2eq can be abated at 
a  price  of  <50€  per  tonne  CO2eq.  This  would  eliminate  almost  70%  of  today`s 
emissions due to F-Gases despite a growing use of the relevant equipment..  

EU-27 M ACC emission reduction vs. WM  scenario 2030

150

100

50

q
e
2

O
C

t

/

0

0

-50

20,000

40,000

60,000

80,000

ktCO2eq

Fig. A_VI-1: Marginal emission abatement costs vs. achievable emission reductions by 2030. 

Source: Schwarz et al. (2011)9 (MACC: Marginal Abatement Cost Curve) 

3. 

INVESTMENT AND SERVICE COSTS, EMPLOYMENT EFFECTS 

Table A_VI-2:   Overview  of  investment  costs,  loss  and  gains  from  service  and  qualitative 

assessment of employment effects 

Subsectors affected 

Equipment investment 
cost / Sales of 
equipment suppliers* 

Loss (-) / Gains (+) from 
service Art 3+4 or new 
service for NH3+CO2 M€/y 

Employment (domestic 
equipment manufacture 
+ service) 

Option B: Voluntary agreements 

M€/year 

M€/year 

Commercial hermetics 

Condensing units 

Centralized systems 

Fire protection HFC-23 

81.3 

752.7 

773.9 

0.0 

-14.3 

-204.7 

-81.4 

-2.2 

++ 

+++ 

+++ 

0 

EN 

96 

   EN 

 
€
 
 
 
 
 
Subsectors affected 

Equipment investment 
cost / Sales of 
equipment suppliers* 

Loss (-) / Gains (+) from 
service Art 3+4 or new 
service for NH3+CO2 M€/y 

Employment (domestic 
equipment manufacture 
+ service) 

M€/year 

M€/year 

XPS-134a 

HFC-23 by-product 
emissions 

Total voluntary 
agreements 

Option C: Extended scope 

2.5 

0.3 

+ 

+ 

1,610.7 

-302.7 

+++ 

Trucks and trailers 

n.a. 

+71.3 

++ 

Option D: Quantitative limits for the placing on the market of HFCs 

Domestic Refrigeration 

Commercial hermetics 

Condensing units 

Centralized systems 

Industrial Ref small 

Industrial Ref large 

Refrigerated Vans 

Refrigerated Trucks 

Fishing vessels 

Cargo ship AC 

Passenger ship AC 

Bus AC 

Truck AC 

Moveable AC systems 

Split AC systems 

Multi split AC systems 

Rooftop AC systems 

Chillers 

Centrifugal chillers 

Fire protection 227ea 

2.0 

81.3 

752.7 

773.9 

67.3 

498.7 

17.8 

141.7 

6.3 

2.8 

0.4 

34.7 

2.3 

7.4 

157.6 

69.6 

66.5 

339.2 

3.0 

5.4 

-0.3 

-14.3 

-204.7 

-81.4 

-0.6 

+2.2 

+2.5 

+7.0 

+0.7 

+3.2 

+0.0 

+4.6 

-0.9 

-483.5 

-268.7 

-83.6 

-139.3 

-3.0 

-4.4 

+ 

++ 

+++ 

+++ 

++ 

+++ 

+ 

++ 

+ 

+ 

0 

+ 

+ 

- 

+ 

0 

0 

+± 

0 

0 

EN 

97 

   EN 

 
 
 
 
 
Subsectors affected 

Equipment investment 
cost / Sales of 
equipment suppliers* 

Loss (-) / Gains (+) from 
service Art 3+4 or new 
service for NH3+CO2 M€/y 

Employment (domestic 
equipment manufacture 
+ service) 

M€/year 

M€/year 

Fire protection 23 

Aerosols 

XPS-152a 

XPS-134a 

PU other 

Total limits placing 
on market 

Option E: Bans for POM 

0.0 

0 

2.5 

2.5 

3.3 

-2.2 

0 

0 

+ 

+ 

+ 

3,039 

1,275 

+++ 

Ban the POM of certain open applications containing F-Gases 

Aerosols 

XPS-134a 

Total ban open appl. 

0 

2.5 

2.5 

Ban the POM of certain closed applications containing F-Gases 

Commercial hermetics 

Condensing units 

Centralized systems 

Industrial Ref small 

Industrial Ref large 

Refrigerated Trucks 

Moveable AC systems 

Split AC systems 

Multi split AC systems 

Rooftop AC systems 

Chillers 

Fire protection 23 

70.7 

602.2 

714.1 

5.2 

38.6 

16.5 

7.4 

157.6 

61.2 

66.5 

314.0 

0 

n.a. 

n.a. 

n.a. 

-13.3 

-163.4 

-75.6.0 

+0.1 

+0.2 

+0.6 

-85.7 

-483.5 

-235.7 

-83.7 

-128.9 

-2.2 

Total ban closed appl. 

2,054.0 

-1,271.3 

Mandatory destruction of HFC-23 emissions from halocarbon production 

0 

+ 

+ 

++ 

+++ 

+++ 

+ 

+++ 

+ 

0 

+++ 

++ 

+ 

+++ 

0 

+++ 

EN 

98 

   EN 

 
 
 
 
 
 
Subsectors affected 

Equipment investment 
cost / Sales of 
equipment suppliers* 

Loss (-) / Gains (+) from 
service Art 3+4 or new 
service for NH3+CO2 M€/y 

Employment (domestic 
equipment manufacture 
+ service) 

M€/year 

M€/year 

Destruction of HFC-23 
emissions to the extent 
possible 

n.e. = not estimated; n.a. = not applicable 

0.3 

n.a. 

0 

* In option E, only the additional sales of domestic equipment suppliers/manufacturers are included. In 
the  sectors  of  stationary  AC,  the  cost  for  equipment  arising  to  operators  are  higher  than  the  sales  of 
domestic equipment manufacturers. 

Source: Schwarz et al.20119, with additional corrections  

EN 

99 

   EN 

 
 
4. 

IMPACTS ON SERVICE COMPANIES 

After  replacement  of  HFCs  in  systems  of  refrigeration,  stationary  AC,  and  fire 
protection  equipment  >3  kg,  enhanced  servicing  activities  according  to  Articles  3  and 
4(1) of the F-Gas Regulation are no longer required. In the sectors with charges <3 kg, 
i.e.  domestic  refrigeration,  commercial  hermetics,  moveable  air  conditioners,  single-
split  air  conditioners,  and,  partly,  condensing  units,  application  of  Article  4(1)  will 
discontinue.  Discontinuation  of  Articles  3  and  4(1)  leads  to  a  net  loss  in  service 
activities and in turnover for service companies in the long run. These effects on service 
companies have been quantified in the following way:  
1st step: The service costs of the HFC reference unit resulting from application of Art 3 
and/or  Art  4(1)  of  the  F-Gas  Regulation,  have  been  determined  (see  Schwarz  et  al., 
20119, Annex V, EU sector sheets).  
2ndstep:  The  service  costs  of  the  HFC  reference  unit  (1st  step)  and  the  number  of 
replaced  HFC  units  by  2030  (AnaFgas)  were  multiplied,  which  results  in  the  loss  in 
turnover of service companies by 2030. 
3rd step: In the case of HFC replacement by CO2 (high pressure equipment) and NH3 
(toxicity) new service costs occur (Schwarz et al., 20119, Annex V, EU sector sheets), 
which were estimated in this step.  

In  option  B,  servicing  activities  according  to  Articles  3  and  4(1)  of  the  F-Gas 
Regulation  are  not  required  anymore  in  some  sectors.  This  leads  to  a  loss  in  service 
turnover of 345 M€/year. New servicing needs arise for CO2 systems and cause gains of 
57  M€/year.  Net  loss  for  service  companies  would  be  289  M€/year.  Losses  are 
particularly high for condensing units (-186 M€/year) and rather low for service of fire 
protection equipment (-2.2 M€/year).   

In option D, after the replacement of HFCs in systems of refrigeration, stationary AC, 
and  fire  protection,  servicing  activities  according  to  Articles  3  and  4(1)  of  the  F-Gas 
Regulation are no longer required in these sectors. In the sectors with charges <3 kg, i.e. 
domestic  refrigeration,  commercial  hermetics,  moveable  air  conditioners,  single-split 
AC,  and,  partly,  condensing  units,  application  of  Article  4(1)  is  no  longer  required. 
Discontinuation  of  Articles  3  and  4(1)  leads  to  a  net  loss  in  service  activities  and 
turnover of -1,356 M€/year in Option D. This sum already includes earnings from new 
service  and  maintenance  for  ammonia  and  CO2  systems  of  +114  M€/year.  Losses  are 
particularly high in four sectors, namely single split and multi-split AC units, chillers, 
and  condensing  units  (-1,070  M€/year;  79%).  In  transport  refrigeration  (vans,  trucks, 
fishing vessels) earnings can be expected, which are, however, comparably small.   

The  same  effect  would  occur  for  bans  in  closed  applications  in  option  E,  a 
discontinuation of Articles 3 and 4(1) would lead to a total loss in service turnover of -
1,270 M€/year. This sum already includes earnings from new service and maintenance 
for ammonia and CO2 systems of +78 M€/year. Service losses are particularly high for 
single  split  and  multi-split  AC  units  (-711  M€/year;  56%).  The  numbers  differ  from 
option D as the emission reduction effects are also lower due to a later introduction of 
the replacement substances.  

EN 

100 

   EN 

 
As discussed in chapter 6.2.10, these "theoretical" losses for service companies are not 
expected to materialise in the short and medium term, since 

(i) containment obligations stemming from the existing F-Gas Regulation are only 
slowly being fully understood and implemented on the ground by affected companies, 
leaving a lot of growth potential for the service sector in this field compared to the 
current situation; 

(ii) service companies which have limited their business activities to leak checking and 
recovery usually are also involved in the installation of new equipment and its on-site 
construction (and stand to profit from the latter activities under a strengthened approach, 
in particular if on-site filling is prescribed).  

EN 

101 

   EN 

 
 
 
ANNEX VII: Detailed results of Screening of Policy Options  

1. 

DISCARDED POLICY OPTIONS 

In  the  following  more  detailed  information  related  to  other  considered  but  eventually 
discarded policy options is presented: 

– 

Suspension of current provisions of F-Gas Regulation 

A  general  suspension  of  existing  provisions  would  disadvantage  Member  States  and 
industry  compliant  with  current  legislation.  Such  a  measure  would  also  not  be  in  line 
with the climate and energy package and the 2050 roadmap, that require contributions 
from all sectors to the EU emission reduction targets in 2020 and beyond until 2050. 

– 

Inclusion of additional activities under the EU-ETS 

The scope for inclusion of F-Gases under the EU-ETS Directive is rather limited. The 
Directive applies either to industrial installations that directly emit greenhouse gass or to 
aircraft  operators,  but  not  to  household  or  industrial  appliances  and  equipment  that 
mostly contribute to emissions via leakages, at the end of the lifetime or through the use 
of a product, i.e. with a timelag of several years to decades after production. It would 
e.g. be impractical to require all individuals buying domestic fridges to acquire licenses 
for the F-Gases contained therein. 

There  are  only  few  remaining  sources  of  F-Gases  that  are  directly  emitted  from 
industrial installations. PFCs from aluminium production are already covered under the 
F-Gas Directive.  One potential application would be the use of  SF6 in magnesium die 
casting. However, most installations already phased out SF6 due to the ban included in 
the  F-Gas  Regulation  for  quantities  above  850kg  per  year  and  the  remaining 
installations are addressed by policy option E. 

– 

EU harmonized tax schemes 

Experiences  from  Denmark  and  Norway  with  the  implementation  of  tax  schemes  for 
fluorinated gases showed that  

– 

The effect of taxes will strongly depend on the tax level chosen and on 
the  development  of  prices  for  HFCs  and  other  F-Gases.  It  is  rather 
difficult to assess price elasticity for F-Gases in the context of the future 
development  of  global  markets  with  significant  growth  projections  of 
production  levels  in  Asian  countries.  In  this  situation,  it  is  rather 
uncertain,  which  would  be  the  appropriate  tax  level.  The  uncertainties 
around  the  future  development  of  prices  for  F-Gases  with  an  uncertain 
level of production growth in emerging countries are a feature which is 
clearly  distinct  from  other  environmental  taxes  on  products  with  more 
stable prices.  

EN 

102 

   EN 

 
– 

– 

– 

The  level  of  taxes  needs  to  be  determined  nationally  and  should  allow 
regular adjustments to the economic situation.  

Exemptions from tax should be chosen carefully and depend on national 
circumstances in Member States.   

Furthermore,  substantial  administrative  effort  to  establish,  operate  and 
control  such  tax  scheme  for  fluorinated  gases  at  EU  level  would  be 
needed  over  several  years,  in  particular  for  a  tax  that  is  imposed  on  F-
Gases in manufactured products due to the wide range of such products 
on the market charged with different F-Gases.  

As  other  policy  options  are  available  to  reach  the  environmental  objectives,  fiscal 
measures  at  EU  level  have  been  discarded  at  this  stage,  also  considering  the 
predominant Member State competence for those provisions. 

– 

Deposit and refund schemes 

Deposit  and  refund  schemes  provide  financial  incentives  that  can  efficiently  reduce 
demand and supply and foster responsible use of F-Gases, enhance recovery, recycling 
and  reclamation,  and  support  the  use  of  low  or  zero  GWP  substances  if  linked  to  the 
GWP of specific substances. However, the level of the financial incentives should take 
into account the following aspects:  

– 

– 

– 

– 

– 

Reclamation costs of recovered refrigerants (including costs for transport 
to reclamation facilities); 

Initial  costs  for  set-up  of  the  scheme  (including  infrastructure)  and 
current costs of administration and control; 

Costs for refunds or rebates; 

Flexibility to allow regular adjustments to the economic situation;   

Deposit and refund schemes need to reflect the structure of supply of F-
Gases, which are likely to vary substantially from one use to another and 
from one Member State to another.  

Therefore, no generic scheme seems to be universally applicable in EU-27 and deposit 
and refund schemes seem to be a policy option that is preferably to be implemented at 
MS level and not at EU level.  

2. 

DISCARDED SUB-OPTIONS OF POLICY OPTIONS B, C, D AND E 

In  addition  to  the  general  options  discarded  described  under  (1),  some  additional 
subsectors  or  specific  applications  were  excluded  from  policy  options  B,  C,  D  and  E 
because  of  a  more  detailed  screening  exercise  related  to  effectiveness,  efficiency  and 
other technical constraints which are presented in Table A_VII-1.  

EN 

103 

   EN 

 
The screening criteria were the following: 

– 

– 

– 

– 

Effectiveness in terms of level of emission reductions (> 1Mt CO2eq);  

Efficiency in terms of abatement costs (<50€ per t of CO2eq abated); 

Technical constraints like safety or loss of energy efficiency; 

Other constraints such as consistency with other EU policies. 

This  screening  analysis  was  performed  in  the  same  way  as  for  the  considered  (sub)-
options under policy options B to E (see next section (3)). 

Table A_VII-1: Sub-options discarded based on detailed screening for effectiveness, efficiency 

and other criteria as specified 

Application 

Discarded because of 

Option B: New VA for domestic 
refrigeration 

Effectiveness criterion not fulfilled, very low emission reduction 
potential of 12 kt CO2eq. by 2030 due to small number of units 
containing F-Gases remaining on the EU market 

Option C: Inclusion in the scope 
of Articles 4 (1): Refrigerated 
road transport – vans 

Efficiency criterion not fulfilled, abatement costs about 290 €/t 
CO2eq., effectiveness criterion not fulfilled, very low emission 
reduction potential of 11 kt CO2eq. by 2030, implementation and 
verification is considered difficult due to high number of ‘van 
operators’ 

Option C: Inclusion in the scope 
of Articles 3 and 4: Rail transport 

Efficiency criterion not fulfilled, abatement costs about 340 €/t 
CO2eq.very low emission reduction potential of 16 kt CO2eq. by 
2030 because 80% of operator already fulfil service requirements 

Option C: Lowering the 
applicable charge threshold of 
certain equipment containing F-
Gases already covered by Article 
4(1) 

Efficiency criterion not fulfilled, abatement costs > 1,750 € / t 
CO2eq.for all sub-options 

Option E: Ban of HFC-152a in 
XPS foam blowing 

Effectiveness criterion not fulfilled, low emission reduction potential 
of 460 kt CO2eq.  

Option E: Ban of HFC in PU 
spray foam blowing 

Efficiency criterion not fulfilled, abatement costs about 60 €/t 
CO2eq., relevant mainly in Spain and Portugal 

Option E: Ban of HFC in other 
PU foam blowing 

Effectiveness criterion not fulfilled, low emission reduction potential 
of 590 kt CO2eq. by 2030 

Option E: Ban of HFC 
indomestic refrigeration 

Effectiveness criterion not fulfilled, very low emission reduction 
potential of 12 kt CO2eq. by 2030 

Option E: Ban of HFC in 
centrifugal chillers 

Effectiveness criterion not fulfilled, very low emission reduction 
potential of 9 kt CO2eq. by 2030 

EN 

104 

   EN 

 
Application 

Discarded because of 

Option E: Ban of HFC in 
refrigerated vans 

Effectiveness criterion not fulfilled, low emission reduction potential 
of 420 kt CO2eq. by 2030 

Option E: Ban of HFC in heat 
pumps 

Efficiency criterion not fulfilled, abatement costs about 130 
€/t CO2eq.. 

Option E: Ban of HFC in fishing 
vessels and ship AC  

F-Gas Regulation not the most appropriate instrument to address this 
sector: The Commission is currently considering options to reduce 
greenhouse gas emissions from the maritime sector, taking into 
account its international nature and unique characteristics. It would 
be appropriate to also consider addressing F-Gases in such coherent 
approach.   

Option E: Ban of HFC in rail 
vehicle AC 

Effectiveness criterion and efficiency criterion not fulfilled, very low 
emission reduction potential of 16 kt CO2eq. by 2030 and abatement 
costs about 560 €/t CO2eq., penetration rate < 100% until 2030 

Option E: Ban of HFC-227ea in 
fire protection 

Effectiveness criterion not fulfilled, low emission reduction potential 
of 170 kt CO2eq. by 2030, penetration rate < 100% until 2030 

Option E: Ban of SF6 in medium 
voltage secondary switchgear 

Effectiveness criterion and efficiency criterion not fulfilled, very low 
emission reduction potential of 60 kt CO2eq. by 2030 and abatement 
costs about 350 €/t CO2eq., penetration rate < 100% until 2030 

N.B.: Effectiveness criterion was considered not to be fulfilled if emission reduction potential at EU-27 
level was below 1 Mt CO2eq. until 2030. Efficiency criterion was considered not to be fulfilled if 
abatement costs were higher than 50 €/tCO 2eq. 

EN 

105 

   EN 

 
3. 

SCREENING OF SUB-OPTIONS FOR POLICY OPTIONS B, C, D & E  

Table A_VII-2: Options to address F-Gas emissions in EU-27 through voluntary agreements 

Additional 
emission 
reductions  
2030 

Abatement 
costs  

2030 

Effectiveness Efficiency

Technical 
feasibility / 
penetration rates

Other qualitative 
criteria 

Final 
evaluation 

Self-regulation or co-regulation 

Threshold:  

Threshold: 

kt CO2eq 

€/ t CO2eq 

1,000 kt CO2eq

50€/tCO2eq

VA with industry to phase-out/down HFCs in 
centralized systems, commercial hermetics, 
condensing units 

18,818 

-0.8 to 23.7 

++ 

++ 

New VA with photovoltaic industry to replace 
SF6 and NF3 

100 

n.a. 

-  

+ 

alternatives 
available, 
penetration rate 
100% in 2020 

alternatives 
available, 
penetration rate 
100% in 2015 

Photovoltaics industry 
likely to be willing to 
engage 

Update international VA with semiconductor 
industry for PFCs, NF3, HFC-23 and SF6 

reduction 
potential n.e. 

n.a. 

-  

+ 

VA expired in 2010 

I
n
c
l
u
d
e

I
n
c
l
u
d
e

I
n
c
l
u
d
e

EN 

106 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
 
Additional 
emission 
reductions  
2030 

Abatement 
costs  

2030 

Effectiveness Efficiency

Technical 
feasibility / 
penetration rates

Other qualitative 
criteria 

Final 
evaluation 

Self-regulation or co-regulation 

Threshold:  

Threshold: 

kt CO2eq 

€/ t CO2eq 

1,000 kt CO2eq

50€/tCO2eq

New VA for XPS foams  

(HFC-134a) 

1,553 

1.0 

New VA for domestic refrigeration 

12 

1.0 

+ 

-  

New VA for HFC-23 in fire protection 

961 

3.1 

+/- 

New VA for HFC-23 by-product emissions  

370 

<2 

-  

+ 

+ 

+ 

+ 

penetration rate 
100% in 2015 

penetration rate 
100% 

Very small number of units 
containing F-Gases 
remaining  

penetration rate 
100% 

Very high GWP. No use in 
>20 MS, alternatives 
available 

destruction 
technology is 
available  

HFC-23 destruction 
technology installed by 
most producers, only 1 
production facility without 

I
n
c
l
u
d
e

e
x
c
l
u
d
e

I
n
c
l
u
d
e

I
n
c
l
u
d
e

Total 

21,702* 

* without semiconductor and photovoltaic industry, and domestic refrigeration; n.a.: not applicable; n.e.: not estimated. 

EN 

107 

EN 

 
  
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
Table A_VII-3: Options to address F-Gas emissions through extending the scope of the F-Gas Regulation 

Improve containment and recovery in certain sectors 

Abatement 
costs 2030 

Additional 
emission 
reductions  
2030 

Effectiveness Efficiency

Other qualitative criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold: 

1,000 kt CO2eq

50€/tCO2eq

Improve containment and recovery 

Inclusion in the scope of Articles 4 (1): Refrigerated road 
transport - vans 

11 

291 

Inclusion  in  the  scope  of  Articles  3  and  4:  Refrigerated 
road transport – trucks and trailers 

1,430 

46 

Inclusion in the scope of Articles 3 and 4: Rail transport 

16 

340 

- 

+ 

- 

-- 

+ 

-- 

Difficult implementation and 
verification due to high number 
of operators  

80% of operators already fulfil 
service requirements  

e
x
c
l
u
d
e

i
n
c
l
u
d
e

e
x
c
l
u
d
e

EN 

108 

EN 

 
  
 
 
 
 
 
 
 
 
 
Improve containment and recovery in certain sectors 

Abatement 
costs 2030 

Additional 
emission 
reductions  
2030 

Effectiveness Efficiency

Other qualitative criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold: 

1,000 kt CO2eq

50€/tCO2eq

Inclusion  in  the  scope  of  Articles  3  and  4:  Refrigerated 
maritime transport – cargo ships 

273 

10.5 

Inclusion  in  the  scope  of  Articles  3  and  4:  Refrigerated 
maritime transport – passenger ships 

405 

8.5 

Inclusion  in  the  scope  of  Articles  3  and  4:  Refrigerated 
maritime transport – fishing vessels 

360 

0.5 

- 

- 

- 

+ 

+ 

+ 

F-Gas Regulation not the most 
appropriate instrument to address 
this sector: The Commission is 
currently considering options to 
reduce greenhouse gas emissions 
from the maritime sector, taking 
into account its international 
nature and unique characteristics. 
It would be appropriate to also 
consider addressing F-Gases in 
such coherent approach.   

e
x
c
l
u
d
e

Lowering the applicable charge threshold of certain equipment containing F-Gases already covered by Article 4(1) 

Domestic refrigeration 

1 

324,722 

- 

--- 

u
de

c
l

e
x

EN 

109 

EN 

 
  
 
 
 
 
 
Improve containment and recovery in certain sectors 

Abatement 
costs 2030 

Additional 
emission 
reductions  
2030 

Effectiveness Efficiency

Other qualitative criteria 

Final 
evaluation 

Commercial hermetics 

Moveable air conditioners 

Split air conditioners  

Heat pumps 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold: 

1,000 kt CO2eq

50€/tCO2eq

13 

29,575 

644 

3,707 

6,057 

2,204 

740 

1,756 

- 

- 

+ 

- 

--- 

--- 

--- 

--- 

Extending the training and certification requirements to personnel undertaking activities currently not covered under Article 5 

Not  

Not  

quantifiable 

quantifiable 

Effectiveness likely to be very 
low. 

Introducing maximum leakage rates for certain systems and equipment containing F-Gases 

Not available  Not available

Does not include accidents; 
problems related to measurability 
of leakage rates; effectiveness 
likely to be low 

e
x
c
l
u
d
e

e
x
c
l
u
d
e

Introducing obligation for producers and suppliers of F-Gases to take back recovered F-Gases for reclamation and destruction 

EN 

110 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Improve containment and recovery in certain sectors 

Abatement 
costs 2030 

Additional 
emission 
reductions  
2030 

Effectiveness Efficiency

Other qualitative criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold: 

1,000 kt CO2eq

50€/tCO2eq

Not available  Not available

Include as an area for 
coordination and exchange of 
best practice as specific measures 
may vary across Member States. 

e
x
c
l
u
d
e

EN 

111 

EN 

 
  
 
 
 
 
 
 
 
Table A_VII-4: Options to address SF6and HFC emissions from open applications in EU-27 through use bans 

Ban the use of  

SF6 in open applications  

Additional 
emission 
reductions  
2030 

Abatement 
costs 2030 

Effectiveness Efficiency

technical 
feasibility / 
penetration 
rates 

Other qualitative criteria 

Final 
evaluation 

kt CO2eq 

€/ t CO2eq 

Threshold:  

Threshold: 

1,000 kt CO2eq

50€/tCO2eq

Inclusion of magnesium die casting <850 kg/ y and recycling of die casting alloys in the scope of Article 8 

250 

0.4 

- 

+ 

100% in 2015 

Operators have started replacing SF6, are 
ready to phase-out. Costs are low, smaller 
installations could be treated in the same 
way as larger ones (consistency).  

Inclusion of HFCs from open applications of technical aerosols and XPS and PU foam in the scope of Article 9 

Ban of HFCs in technical 
aerosols 

3,637 

10 

+ 

+ 

95% in 2020  

Exemptions need to be defined 

i
n
c
l
u
d
e

i
n
c
l
u
d
e

EN 

112 

EN 

 
  
 
 
 
 
 
 
 
 
Ban the use of  

SF6 in open applications  

Additional 
emission 
reductions  
2030 

Abatement 
costs 2030 

Effectiveness Efficiency

technical 
feasibility / 
penetration 
rates 

Other qualitative criteria 

Final 
evaluation 

kt CO2eq 

€/ t CO2eq 

Threshold:  

Threshold: 

1,000 kt CO2eq

50€/tCO2eq

Ban of HFC-152a in XPS 
foam blowing in 2015 

460 

-1.60 

- 

++ 

100% in 2015 

GWP of 152a is much lower (124) 
than GWP of 134a (1,430). Could 
possibly be considered combined with 
HFC-134a.  

Ban of HFC-134a in XPS 
foam blowing in 2015 

1,553 

1.0 

+ 

++ 

100% in 2015 

Very few companies in EU 

Ban of HFC in PU spray 
foam blowing 

1,369 

61.6 

+ 

+/- 

100% in 2015 

Relevant mainly in Spain and 
Portugal 

e
x
c
l
u
d
e

i
n
c
l
u
d
e

e
x
c
l
u
d
e

EN 

113 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
Ban the use of  

SF6 in open applications  

Additional 
emission 
reductions  
2030 

Abatement 
costs 2030 

Effectiveness Efficiency

technical 
feasibility / 
penetration 
rates 

Other qualitative criteria 

Final 
evaluation 

kt CO2eq 

€/ t CO2eq 

Threshold:  

Threshold: 

1,000 kt CO2eq

50€/tCO2eq

Ban of HFC in other PU foam 
blowing 

587 

3.5 

- 

+ 

up to 95% in 
2015 

Exemptions need to be defined. 

e
x
c
l
u
d
e

Total 

5,190* 

* only the sub-options included for further analysis 

EN 

114 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
Table A_VII-5: Options to address F-Gas emissions from closed applications in EU-27 by placing on the market bans 

Ban the placing on the market of 
certain closed F-Gas applications 

Additional emission 
reduction 2030 

Abatement costs 
2030 

Effectiveness 

Efficiency 

technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

Domestic refrigeration 

12 

1.0 

Commercial hermetic systems 

147 

-0.8 

Condensing units  

2,849 

1.2 

- 

-- 

+ 

Centralised systems 

12,055 

23.7 

++ 

+ 

2015 

++ 

2020 

+ 

+ 

2020 

2020 

e
x
c
l
u
d
e

i
n
c
l
u
d
e

i
n
c
l
u
d
e

i
n
c
l
u
d
e

EN 

115 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
Ban the placing on the market of 
certain closed F-Gas applications 

Additional emission 
reduction 2030 

Abatement costs 
2030 

Effectiveness 

Efficiency 

technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

Small industrial refrigeration 

67 

-0.9 

+/- 

++ 

Large industrial refrigeration 

202 

-21.6 

+ 

++ 

95% in 
2030 

95% in 
2030 

Exemptions 
need to be 
defined for 
small 
systems, e.g. 
<50 kg  

(similar to 
Sweden).  

Exemptions 
need to be 
defined. 
Combination 
of small + 
large ref. 
possible 
(threshold 50 
kg) 

Moveable AC  

2,781 

8.9 

+ 

+ 

2020 

i
n
c
l
u
d
e

i
n
c
l
u
d
e

i
n
c
l
u
d
e

EN 

116 

EN 

 
  
 
 
 
 
 
 
 
Ban the placing on the market of 
certain closed F-Gas applications 

Additional emission 
reduction 2030 

Abatement costs 
2030 

Effectiveness 

Efficiency 

technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

Single split AC 

22,970 

19.0 

++ 

+ 

2020 

Multi split AC 

2,172 

13.1 

Rooftop AC systems 

Displacement chillers 

Centrifugal chillers 

EN 

573 

1,989 

9 

8.2 

5.9 

7.5 

117 

+ 

- 

+ 

- 

++ 

2020 

++ 

2020 

++ 

2020 

++ 

2030 

i
n
c
l
u
d
e

i
n
c
l
u
d
e

i
n
c
l
u
d
e

i
n
c
l
u
d
e

e
x
c
l
u
d
e

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Ban the placing on the market of 
certain closed F-Gas applications 

Additional emission 
reduction 2030 

Abatement costs 
2030 

Effectiveness 

Efficiency 

technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

Refrigerated vans 

421 

45.1 

- 

+/- 

2020 

Heat pumps 

1,356 

130.2 

- 

2020 

Fishing vessels 

27 

3.4 

- 

+ 

penetration 
rate not 
100% 

F-Gas Reg. is 
not the most 
appropriate 
instrument to 
address this 
sector: The 
Commission 
is currently 
considering 
options to 
reduce 
greenhouse 
gas emissions 
from the 
maritime 
sector, taking 
into account 
its 
international

e
x
c
l
u
d
e

e
x
c
l
u
d
e

D
e
p
e
n
d
s
o
n

c
h
o
i
c
e
o
f
p
o
l
i
c
y

i
n
s
t
r
u
m
e
n
t

EN 

118 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ban the placing on the market of 
certain closed F-Gas applications 

Additional emission 
reduction 2030 

Abatement costs 
2030 

Effectiveness 

Efficiency 

technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

Cargo ship AC 

232 

16.7 

- 

+ 

2020 

EN 

119 

EN 

 
  
 
 
 
Ban the placing on the market of 
certain closed F-Gas applications 

Additional emission 
reduction 2030 

Abatement costs 
2030 

Effectiveness 

Efficiency 

technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

Passenger ship AC 

97 

35,0 

- 

+ 

Refrigerated trucks and trailers 

322 

2.6 

Rail vehicle AC 

16 

555.6 

- 

-- 

HFC-23 in fire protection 

961 

3.1 

+/- 

+ 

- 

+ 

penetration 
rate not 
100% 

2030 

penetration 
rate not 
100% 

2015 

i
n
c
l
u
d
e

e
x
c
l
u
d
e

i
n
c
l
u
d
e

Very high 
GWP. No use 
in 21 MS, 
alternatives 
available  

EN 

120 

EN 

 
  
 
 
 
 
 
 
 
 
Ban the placing on the market of 
certain closed F-Gas applications 

Additional emission 
reduction 2030 

Abatement costs 
2030 

Effectiveness 

Efficiency 

technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

HFC-227ea in fire protection 

167 

22.3 

Medium Voltage secondary switchgear 

61 

347.7 

- 

- 

+ 

- 

penetration 
rate not 
100% 

penetration 
rate not 
100% 

Destruction of HFC-23 emissions from 
halocarbon production  

370 

<2 

+ 

+++ 

100% 

e
x
c
l
u
d
e

e
x
c
l
u
d
e

i
n
c
l
u
d
e

Industrial 
process 
emiss.; 

very high 
GWP; 
international 
commitments 

Total  

47,459* 

18.9* 

*: only sub-options included for further analysis 

EN 

121 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
Table A VII-6:   Option to address F-Gas supply in EU-27 through quantitative limits for the placing on the market of F-Gases. Reference year 2030 

Set quantitative limits for the 
placing on the market of HFCs 

Add. emission reduction 
2030 

Average emission 
abatement costs 2030

Effectiveness 

Efficiency

Maximum supply reductions in all 
sectors relying on HFCs :  

136,500 kt CO2eq 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2 eq. 

50€/tCO2eq 

69,239 

16.5 

+++ 

++ 

Technical 
feasibility / 
penetration 
rates 

Other 
qualitative 
criteria 

Final 
evaluation 

No need for 
100% due to 
nature of 
measure 

High 
flexibility 

i
n
c
l
u
d
e

Table A VII-7: Options to address inadvertent HFC-23 emissions in EU-27 through the obligation for destruction of these emissions 

HFC.23 emissions from 
halocarbon production 

Add. emission reduction  
2030 

Abatement costs 
2030 

Effectiveness  Efficiency

Technical 
feasibility / 
penetration 
rates 

Other 

Qualitative 

criteria 

Final 
evaluati
on 

kt CO2eq 

€/t CO2eq 

Threshold:  

Threshold:  

1,000 kt CO2eq 

50€/tCO2eq 

EN 

122 

EN 

 
  
 
 
 
 
 
 
 
 
Destruction of HFC-23 emissions 
from halocarbon production to the 
extent technically feasible 

370 

<2 

+ 

+++ 

100% 

Industrial 
process 
emissions; 

very high 
GWP; 
international 
commitments 

i
n
c
l
u
d
e

EN 

123 

EN 

 
  
 
ANNEX VIII: Sensitivity Analysis of Cost Estimation 

1. 

GENERAL 

The  economic  impacts  largely  rely  on  cost  data.  This  applies  not  only  to  economic 
impacts  in  a  strict  sense  such  as  effects  on  specific  abatement  costs,  on  costs  to  the 
industry sectors and to individual end-users but also to social impacts such as effects on 
prices for equipment or employment.  

It is evident that all monetary variables which are included in Annex V of Schwarz et al. 
(2011)9 influence the economic and social situation of the actors in the relevant sectors. 
In  this  section,  a  sensitivity  analysis  is  conducted  for  those  cost  parameters  which 
significantly affect the abatement costs (€/t CO2eq) and thus the cost efficiency of the 
potential emission reductions. The most important parameters are considered to be the 
following: 

– 

The assumed purchase prices of unsaturated HFCs such as HFC-1234yf 
(€60/kg), HFC-1234ze (€40/kg as a refrigerant, €12/kg as foam blowing 
agent or aerosol propellant) and the blend DR-11 (€30/kg) influence the 
abatement  costs  of  the  alternative  technical  options  which  rely  on  these 
substances. It is anticipated that the cost will considerably decrease up to 
2030  because  large-scale  production  of  the  chemicals  would  be 
established  by  then.  In  the  sensitivity  analysis  the  effect  of  a  price 
reduction  of  50%  (“half  price”)  is  assumed,  compared  to  the  prices 
mentioned above (“base case”). 

Table A_VIII-1: Assumptions for purchase prices of alternative substances 

“base case” scenario 

“half price” scenario 

HFC-1234yf 

€60 /kg 

€30/ kg 

HFC-1234ze 

€40 /kg as a refrigerant;  

€20 /kg as a refrigerant; 

€12 /kg as foam blowing agent or 
aerosol propellant 

€6 /kg as foam blowing agent or 
aerosol propellant 

DR-11 

€30 /kg 

€15/ kg 

– 

The  discount  rate  for  the  annualisation  of  investment  costs  strongly 
influences the total annual costs to operators in each individual sector, for 
application of conventional HFCs as well as of low-GWP alternatives. A 
discount  rate  of  4%  was  used  in  Schwarz  et  al.  (2011)9  as  a  general 
assumption and might be appropriate from the perspective of the national 

EN 

124 

   EN 

 
 
 
economy (long-term capital market interest). However, a discount rate of 
4%  is  too  low  compared  to  the  return  rate  from  the  perspective  of 
individual operators. An alternative discount rate of 8% will be used for 
cost  estimates  and  results  will  be  compared  to  those  based  on  a  4% 
discount rate (“base case”). 

The impact of a doubled discount rate and halved cost of unsaturated HFCs on emission 
reduction  in  2030  was  analysed  separately  for  the  three  policy  options:  Option  B 
“Voluntary agreements”, option D “Quantitative limits for the placing on the market of 
certain F-Gases”, and option E “Ban of placing on the market of certain open and closed 
applications”.  

2. 

OPTION B "VOLUNTARY AGREEMENTS IN CERTAIN HFC APPLICATIONS" 

After  screening,  the  option  B  “Voluntary  agreements”  includes  only  five  application 
sectors  of  F-Gases:  Commercial  hermetics,  commercial  condensing  units,  commercial 
centralised systems, fire protection with HFC-23, and XPS manufacture with HFC-134a 
as  blowing  agent.  Despite  the  small  number,  the  emission  reduction  potential  is 
comparably  high  because  the  reduction  potential  of  alternative  low-GWP  solutions  is 
assumed to follow the penetration rates of the relevant technologies without delay, as it 
is the assumption in the option “Quantitative limits for the placing on the market”. 

2.1. 

Effects of prices for unsaturated HFCs 

The specific emission abatement costs in the five sectors are below the threshold of €50 
/t CO2eq. This efficiency criterion is met not only in the base case where the value is 
16.8 € /t CO2 eq. but also if the prices of unsaturated HFCs are halved: 16.6 € t CO2 eq. 
(see Table A_VIII-2, col. 2). This very small difference results from the assumption that 
there  is  only  one  sector  for  which  unsaturated  HFCs  (HFC-1234ze)  are  considered  a 
realistic technical alternative to HFCs. This sector is XPS manufacture, where the price 
reduction  for  HFC-1234ze  leads  to  a  reduction  in  the  sector  specific  abatement  cost 
from 1.0 € /t CO2eq to -1.5 € /t CO2eq.  

EN 

125 

   EN 

 
Table A_VIII-2:   Option B Voluntary agreements: Impact of doubled discount rate and halved 

cost of unsaturated HFCs on emission reduction 2030 

 Discount rate 

4% 

4% 

8% 

Unsaturated HFCs 

High cost 

Half cost 

High cost 

Maximum reduction potential  

Abated at< €50/tCO2eq 

Abatement cost (€/tCO2eq) 

Sectors > 50€/tCO2eq 

Not abated emissions 
(>€50/tCO2eq) 

21,332 

21,332 

16.8 

0 

0 

21,332 

21,332 

16.6 

0 

0 

21,332 

21,183 

30.4 

1 

149 

Table A_VIII-3: Option B: Sector excluded by screening as efficiency too low 

 Discount rate 

4% 

4% 

8% 

 Unsaturated HFCs 

High cost 

Half cost 

High cost 

Commercial 
hermetics 

2.2. 

Effects of discount rate 

Under  a  doubled  discount  rate  of  8 %  instead  of  4 %  the  average  abatement  cost 
increase  from  €  16.8  to  30.4€/t  CO2eq.  (see  Table  A_VIII-2,  column  3).  The 
comparably  high  growth  results  from  the  fact  that  all  five  sectors  are  affected  if  the 
investment costs are annualised with the higher discount rate. In one sector (commercial 
hermetic (refrigeration systems)) the abatement costs rise over the threshold of 50 € /t 
CO2eq,  so  that  the  cost  effective  overall  emission  reduction  potential  of  the  policy 
option is reduced. It decreases only by 0.15 Mt CO2eq, from 21.33 to 21.18 Mt CO2eq 
because the affected sector is very small.  

EN 

126 

   EN 

 
 
 
 
2.3. 

Conclusions 

Option Voluntary agreements
Im pact of doubled discount rate / halved prices of unsaturated HFCs on 
em ission reduction potential 2030 (MACC)

150

100

50

q
e
2

O
C

t

/

0

0

-50

5,000

10,000

15,000

20,000

25,000

ktCO2eq

Fig. A_VIII-1:   Option B: Impact of doubled discount rate and halved prices of unsaturated 

HFCs on the MACC of the 2030 HFC emission reduction potential 

N.B.:. The middle curve displays the base case. The upper curve indicates the effect of a discount rate of 
8%. The emission reduction potential at abatement costs below €50 /tCO 2eq is only slightly lower 
than that in the two other cases, amounting to ca. 21 Mt CO2eq. As can be seen on the x-axis from 
1.5 Mt CO2eq onwards the curve for the base case is congruent with the curve for “half price of 
unsaturated HFCs” because there is no difference between the abatement costs in four of the five 
sectors concerned. 

Fig. A_VIII-1 shows that the three curves do not substantially split from each other. In 
summary,  even  under  a  very  high  discount  rate  (indicating  focus  on  short-term 
profitability) this option can be considered effective and efficient.  

EN 

127 

   EN 

 
€
 
 
 
 
3. 

OPTION  D  "QUANTITATIVE  LIMITS  FOR  THE  PLACING  ON  THE  MARKET  OF 
CERTAIN HFCS" 

This option assumes that the emission reduction potential follows the gradual growth of 
the  penetration  rates  of  alternative  technologies  i.e.  that  in  each  year  all  technically 
feasible replacement solutions for new equipment are utilised according to the assumed 
penetration mix even though the full market penetration potential might not have been 
achieved yet. The technically feasible reduction potential by 2030 is estimated at 72.9 
Mt CO2eq. The emission reductions which can be achieved at high efficiency is lower. 
Screening showed the following result: The reduction potential can reach 69.2 Mt CO2 
if  all  relevant  sectors  with  emission  abatement  costs  below  50 €/t  CO2eq  make  the 
assumed transitions to low-GWP options. The efficiency criterion causes the exclusion 
of  four  sectors  from  the  option:  PU  spray  foam,  heat  pumps,  rail  vehicle  AC,  with 
potential  emission  reduction  of  3.7  Mt  CO2eq.  The  estimated  average  emission 
abatement  cost  for  the  remaining  25  sectors  is  16.5 €/t  CO2eq  (for  all  these  data  see 
Table A_VIII-4, first column).  

Table A_VIII-4: Option D “Quantitative limit for the placing of HFCs on the market”: Impact 
of  doubled  discount  rate  and  halved  cost  of  unsaturated  HFCs  on  emission 
reduction 2030 for option D “Quantitative limits for the placing on the market 
of certain F-Gases” 

Discount rate 

4% 

4% 

8% 

 Unsaturated HFC 

High cost  

Half cost  

High cost  

Maximum emission reduction 
potential 2030 
Abated at < €50/tCO2eq 
Average abatement cost 
(€/tCO2eq) 
Sectors > 50€/tCO2eq 
Not abated emissions 
(>€50/tCO2eq) 

72,915 

69,239 

16.5 

3 

3,676 

72,915 

70,608 

9.9 

2 

2,307 

72,915 

64,441 

28.1 

7 

8,474 

EN 

128 

   EN 

 
 
Table A_VIII-5: Option D: Sectors excluded in the screening due to low efficiency 

 Discount rate 

4% 

4% 

8% 

 Unsaturated HFCs 

High cost 

Half cost 

High cost 

Heatpumps 

Heatpumps 

Heatpumps 

Rail mobile AC 

Rail mobile AC 

Rail mobile AC 

PU spray foam 

PU spray foam 

Bus mobile AC 

Refrigerated vans 

Large industrial 
refrigeration 

Commercial 
hermetics 

3.1. 

Effects of prices for unsaturated HFCs 

Table A_VIII-4 (column 2) shows that the reduction in prices for all unsaturated HFCs 
by 50% leads to a decrease of the average abatement cost from 16.5 to 9.9 €/tCO2eq. As 
a  result,  PU  spray  foam  (application  of  HFC-1234ze)  will  be  included  in  the  option 
because the abatement costs of the sector mix of low-GWP alternatives decrease from 
62  to  42  €  /t  CO2eq.,  falling  below  the  efficiency  threshold  of  €  50/t  CO2  eq.  As  a 
consequence, the overall emission reduction potential increases by 1.4 Mt CO2eq, from 
69.2  to  70.6  Mt  CO2eq.  It  must  be  added  that  Schwarz  et  al.  (2011)9  assume  that 
unsaturated HFCs are included in the 2030 penetration mix only in 16 of the 25 sectors 
of concern.   

3.2. 

Effects of discount rate 

The third column of Table A_VIII-4 reveals that the quantitative impact from a discount 
rate of 8% compared to 4% is significantly higher than the impact of the price reduction 
of unsaturated HFCs. 

The  average  abatement  costs  per  t  CO2eq  increase  to  € 28.1,  and  cause  a  drop  in 
efficiently abated emissions to 64.4 Mt CO2eq (compared to 69.2 Mt CO2eq in the base 
case).  In  contrast  to  the  base  case,  four  additional  sectors  will  be  excluded  from  the 
option  because  of  low  cost  effectiveness  (threshold  is  € 50/t  CO2eq):  bus  AC, 
refrigeration of vans, large industrial refrigeration and commercial hermetic systems.  

It must be mentioned that under the assumption of a discount rate of 4%, the abatement 
cost  for  large  industrial  refrigeration  are  the  lowest  of  all  sectors  (-  22  €/tCO2eq)  but 

EN 

129 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
turn positive, to even + 65 €/tCO2eq, if a discount rate of 8 % is applied. This is a result 
of the high absolute investment cost of large ammonia-based refrigeration plants which 
are  assumed  to  replace  conventional  R-404A  systems.  This  means  that  operators’ 
commitment  to  short-term  profitability  is  in  the  industrial  refrigeration  sector 
particularly detrimental to the introduction of low-GWP alternatives. 

3.3 

Conclusions 

The price reduction of unsaturated HFCs by 50% increases the cost-effective emission 
reduction  potential  of  the  option  “Quantitative  limits  for  the  placing  on  the  market  of 
HFCs” by 1.4 Mt CO2eq (+ 2%) while the doubling of the discount rate decreases the 
cost effective emission reduction potential by 4.8 Mt CO2eq (- 7%).  

Option "Quantitative limits to Placing on the market" 
Impact of doubled  discount rate / halved prices of unsaturated HFCs on 2030 emission 
reduction potential (MACC)

150

100

50

q
e
2

O
C

t

/

0

0

-50

20.000

40.000

60.000

80.000

ktCO2eq

Fig. A_VIII-2:   Option D: Impact of doubled discount rate and halved prices of unsaturated 

HFCs on the MACC of the 2030 HFC emission reduction potential 

N.B.: The middle curve displays the base case. The upper curve indicates the effect of a discount rate of 
8%,  showing  that  64.4  Mt  CO2eq  can  be  reduced  with  abatement  costs  below  €50  /tCO 2eq.  The 
lower  curve  represents  the  impact  of  a  price  reduction  of  unsaturated  HFCs  by  50%;  the  cost 
effective  emission  reduction  potential  is  higher,  amounting  to  70.6  Mt  CO2eq.  It  is  the  same 
reduction potential as in the base case (middle curve). 

Fig. A_VIII-2 shows that the three curves do not substantially differ indicating that even 
doubling of the discount rate would not put the policy option “Quantitative limits for the 
placing on the market of certain F-Gases” at risk. 

It can be concluded that even under a high discount rate (indicating focus on short-term 
profitability) the option can be considered effective and efficient.  

EN 

130 

   EN 

 
€
 
 
4. 

OPTION  E  "BAN  THE  PLACING  ON  THE  MARKET  OF  CERTAIN  OPEN  AND 
CLOSED APPLICATIONS OF F-GASES" 

In the option “Quantitative limits for the placing on the market” it was assumed that the 
reduction potential of replacement solutions follows the penetration rates of alternative 
technologies without delay, i.e. every year all available replacement solutions for new 
equipment are installed according to the penetration mix. In the option “Ban the placing 
on the market of certain open and closed applications of F-Gases” a ban can, however, 
only  be  established  if  the  penetration  mix  is  at  100%  (or  less  provided  that  specific 
exemptions can be clearly specified). Therefore, in the screening process a considerable 
number  of  sectors  have  been  excluded  from  the  ban  option  because  the  assumed 
penetration mix of low-GWP alternatives will not reach the required market penetration 
by 2030. Even when 100% penetration can be reached by 2030, there is a delay in the 
introduction  of  low-GWP  alternatives  which  reduces  the  2030  emission  reduction 
potential compared to the option “Quantitative limits for the placing on the market” (or 
“Voluntary agreements”) in sectors where two (or three) options are feasible.  

Furthermore, certain small sectors with emission reduction potential < 1 Mt CO2eq are 
considered to be too small to be included in the ban option. The total number of sectors 
for which bans are technically feasible before 2031 and sufficiently effective is 16 (out 
of 27). However, two of the remaining sectors do not fulfil the efficiency criterion <50€ 
/t CO2eq, and are also excluded from the option (heat pumps, PU spray foam).  

The 2030 emission reduction potential of bans in the remaining 14 sectors of closed and 
open  applications  was  estimated  at  52.3  MtCO2eq  by  Schwarz  et  al.  (2011)9.  A 
precondition is that all sectors make the assumed transitions to low-GWP options. The 
estimated average abatement cost for the 14 sectors is 15.9 €/tCO2eq. (Table A_VIII-6, 
column 1). 

Table A_VIII-6:   Option  E  Ban  of  placing  on  the  market  of  certain  open  and  closed 
applications with HFCs: Impact of doubled discount rate and halved cost of 
unsaturated HFCs on the 2030 emission reduction 

 Discount rate  

4% 

4% 

8% 

 Unsaturated HFC 

High cost  

Half cost 

High cost 

Maximum reduction potential 

Abated at< €50/tCO2eq 

Avabatement cost (€/tCO2eq) 

Sectors> 50€/tCO2eq 

Not abated emissions 
(>€50/tCO2eq) 

57,092 

52,278 

15.9 

2 

4,814 

57,092 

52,278 

8.3 

2 

4,814 

57,092 

51,929 

26.5 

4 

5,163 

EN 

131 

   EN 

 
Table A_VIII-7: Option E: Sectors excluded by screening for lack of cost efficiency 

 Discount rate 

4% 

4% 

8% 

 Unsaturated HFCs 

High cost 

Half cost 

High cost 

Heatpumps 

Heatpumps 

Heatpumps 

PU spray foam 

PU spray foam 

PU spray foam 

Industrial refrigeration 

Commercial hermetics 

4.1. 

Effects of prices for unsaturated HFCs 

As  can  be  seen  in  Table  A_VIII-6  (column  2),  the  reduction  in  prices  by  50%  for  all 
unsaturated HFCs leads to a decrease of the average abatement costs from 15.9 to 8.3 
€/tCO2eq.  Compared  to  the  calculations  with  higher  prices  of  unsaturated  HFCs,  no 
additional  sector  falls  below  the  efficiency  threshold  of  €  50/t  CO2eq.  As  a 
consequence,  the  overall  emission  reduction  potential  is  the  same  for  both  price 
estimates.  

4.2. 

Effects of discount rate 

The third column of Table A_VIII-6 reveals that there is a quantitative impact from the 
doubling of the discount rate not only to the average emission abatement costs, which 
will almost double, but also to the emission reduction potential, which will be reduced 
by a small amount.  

The  average  abatement  costs  per  t  CO2eq  increase  to  € 27.5,  and  cause  a  drop  in 
efficiently abated emissions by 0.35 Mt CO2eq from 52.3 Mt CO2eq. Two sectors more 
than in the base case will be excluded from the option because of low cost effectiveness 
(threshold  €50/t  CO2eq):  large  industrial  refrigeration  and  commercial  hermetic 
systems.  

Under  a  discount  rate  of  4 %  the  abatement  costs  for  large  industrial  refrigeration  are 
the  lowest  of  all  sectors  (-22€/t  CO2eq)  but  turn  positive,  to  +  65  €/t  CO2eq,  if  a 
discount rate of 8 % is applied. This is a result of the high absolute investment costs of 
large ammonia-based refrigeration plants which are assumed to replace conventional R-
404A systems. This means that operators’ commitment to short-term profitability is in 
the  industrial  refrigeration  sector  particularly  detrimental  to  the  introduction  of  low-
GWP alternatives. The increase in abatement costs in the sector of commercial hermetic 
systems is in the same range, rising from -0.8 € to +111 €/t CO2eq. This is also due to 
the fact that the investment costs of systems with low-GWP refrigerants (R-290 and R-
744)  are  substantially  higher  than  for  systems  with  conventional  HFCs,  even  if  the 
absolute difference is comparably small.  

EN 

132 

   EN 

 
 
 
 
 
 
 
 
 
4.3. 

Conclusions 

Option Ban Placing on the Market of certain open and closed applications 
Impact of doubled discount rate / halved prices of unsaturated HFCs on emission 
reduction potential 2030 (MACC)

150

100

q
e
2
O
C

t

/

50

0

0

-50

10,000

20,000

30,000

40,000

50,000

60,000

ktCO2eq

Fig. A_VIII-3:   Option E: Impact of doubled discount rate and halved prices of unsaturated 

HFCs on the MACC of the 2030 HFC emission reduction potential 

N.B.:  The middle curve displays the base case. The upper curve indicates the effect of a discount rate of 
8%,  showing  that  51.9  Mt  CO2eq  can  be  reduced  with  abatement  costs  below  €50  /tCO 2eq.  The 
lower  curve  represents  the  impact  of  a  price  reduction  of  unsaturated  HFCs  by  50%;  the  cost 
effective  emission  reduction  potential  is  higher,  amounting  to  52.2  Mt  CO2eq.  It  is  the  same 
reduction potential as in the base case (middle curve). 

Fig  A_VIII-3  shows  that  the  three  curves  do  not  substantially  split  from  each  other, 
indicating  that  even  doubling  of  the  discount  rate  would  not  set  the  policy  option  E 
“Ban  placing  on  the  market  of  certain  open  and  closed  applications”  at  risk.  In 
summary,  even  under  a  very  high  discount  rate  (indicating  focus  on  short-term 
profitability) the option E can be considered effective and efficient.  

EN 

133 

   EN 

 
€
 
 
 
 
 
ANNEX  IX: Model Description of the EmIO-F Europe Input-Output 
model and Sensitivity Analysis of Employment impacts  

1. 

INTRODUCTION 

This  Annex  contains  a  more  detailed  description  of  the  model  EmIO-F  Europe  - 
Employment  Input-Output  Model  for  Analysis  of  Policies  and  Measures  for  the 
European Union and the results of a sensitivity analysis of the employment impacts. 

2. 

THE  INPUT-OUTPUT MODEL 

EmIO Europe is a static Input-Output Model to determine direct and indirect output and 
employment effects of environmental policies and measures for the European Union. In 
this  case,  the  model  is  calibrated  to  accommodate  the  effects  of  the  revised  F-Gas 
regulation  (hence  EmIo-F).  The  model  is  based  on  the  Eurostat  Input-Output  Table 
(EU-27)  for  domestic  production  at  basic  prices  for  the  year  2007  as  well  as  Eurostat 
employment  data  for  the  same  year.  The  inverse  (Leontief)  coefficient  matrix  is 
calculated and used to analyse the direct effect a demand shift (e.g. investment) has on 
the  output  of  a  sector  and  all  indirect  effects  triggered  in  other  sectors  providing 
intermediate inputs to production of this sector. The vector of employment coefficients 
(derived  by  dividing  the  level  of  employment  per  sector  by  aggregate  output  of  this 
sector) defines the level of employment per unit of production and can thus be used to 
investigate the effect on employment of an increase or decrease in production activity. 

The Model incorporates 59 NACE Rev.1.1 2-digit sectors. The relevant sectors for an F-
Gas  related  analysis  are:  29  “Machinery  and  equipment  n.e.c.”,  24  “Chemicals, 
chemical products and man-made fibres” and 40 “Electrical energy, gas, steam and hot 
wa-ter”.  Sector  29  not  only  includes  manufacturing  of  machinery  and  equipment,  but 
also  repair  and  maintenance  (e.g.  29.23  “Non-domestic  cooling  and  ventilation 
equipment”). From 2012 onwards (reporting year 2008) countries will report to Eurostat 
according to NACE Rev.2. In this more disaggregated classification sector, the sectors 
for  servicing  and  maintenance  will  be  differentiated  from  manufacturing  sectors  and 
thus permit a more detailed treatment of the effects on investment in new equipment vs. 
changes in service and maintenance needs. 

To  apply  the  model,  information  on  both  investment  and  operation  and  maintenance 
(O&M) activities induced by the policy measure is required and needs to be assigned to 
sectors  within  the  Input-Output  model.  This  includes  information  on  increased 
investment and O&M activity stimulated by the policy or measure in some areas (blue 
box  in  A_IX-1)  as  well  as  information  on  decreased  activity  due  to  the  policy  or 
measure  in  other  sectors  (red  box  in  A_IX-1).  In  case,  information  is  provided  on  a 
more  detailed  level,  the  data  needs  to  be  aggregated  in  accordance  with  the  sectoral 
aggregation  level  of  the  input-output  statistics.  In  the  process  of  aggregation,  some 
activities  may  need  to  be  assigned  to  one  and  the  same  sector  (e.g.  machinery  and 
equipment or services relating to maintenance and repairs) and information on positive 

EN 

134 

   EN 

 
and negative stimulation and their individual effects on employment may no longer be 
disentangled. The overall net effect, however, would be assessed.  

Climate policies 

Yield a net cost or 
benefit for economic 
agents 

Generate activities 
(HFO, new foams…) 

Reduce greenhouse gas 
emitting activities 
(HFC placing on the 

Raise or reduce 
demand for other 
activities

Create jobs

Destroy jobs

Positive or negative 
induced employment 
effect  

Net employment 
effect, positive or 
negative 

Fig. A_IX-1: 

Main economic mechanisms of job creation and destruction 

Source: adapted from Quirion and Demailly (2008)79 

This  approach  may  present  a  bias  towards  the  most  expensive  technical  and 
organisational option, because a large amount of these costs is due to additional labour 
costs. It is therefore important to account for the fact that economic agents (households, 
businesses,  governments)  will  necessarily  pay  for  these  extra  costs  and  will  therefore 
reduce  other  expenses,  thus  inducing  a  negative  effect  on  output  and  employment. 
Taking into account this "income effect" (purple (larger) box in the above Fig. A_IX-1) 
requires  some  additional  assumptions,  notably  relating  to  which  economic  actors  will 
bear the extra costs and how they will change their saving and consumption in response 
to  these  extra  costs.  EmIO  Europe  can  distinguish  whether  the  cost  of  the  policy  or 
measure  is  borne  by  consumers,  by  industry  or  by  the  government.  As  F-Gases  are 
mainly  associated  with  end-use  products,  we  assume  that  any  additional  costs  to  the 
production sectors will be fully passed on to consumers.  

79 

EN 

P.  Quirion  and  D.  Demailly  (2008),  "-30%  de  CO2  =  +  684000  emplois,  l'équation 
gagnante  pour 
for  WWF  France,  http://www.centre-
cired.fr/perso/quirion/quirion_emploi_wwf.pdf   

la  France", 

study 

135 

   EN 

 
 
                                                 
Currently  two  variations  are  implemented  in  EmIO  Europe  to  account  for  consumer 
reaction. Both have been applied in the current context: i) the additional costs incurred 
from  compliance  with  the  policy  will  reduce  final  demand  proportionally  for  all 
production sectors (proportional scenario), ii) the additional costs will not affect demand 
for basic products (such as food, textiles, furniture, electronic equipment, most services) 
but  will  reduce  demand  for  products  from  those  sectors  that  are  affected  by  the 
regulation (subsistence scenario).  

The model further distinguishes two methodological variants concerning the financing 
of changes in activities (e.g. investment):  

(1)  One variant labelled “Ex-post financing by consumers” which models the 
net effect (direct and indirect) on production stimulated by the policy (i.e. 
investment in hardware, changed maintenance requirements, purchase of 
materials and changed electricity consumption) and shows the effect of a 
change in household consumption after this initial impulse has been fed 
through the economy.  

(2)  A  second  variant  labelled  “Ex-ante  financing  by  consumers”  which 
simultaneously  takes  into  consideration  the  initial  impulse  and  the 
induced  reduction  in  demand  by  consumers  needed  to  finance  this 
impulse. Total impact on employment is thus based on direct and indirect 
production  effects  as  well  as  consumer  demand  effects  (purple  (larger) 
box in Fig. A_IX-1). 

In  the  context  of  the  F-Gas  regulation  variant  2)  concerning  the  financing  of 
investments was applied in EmIo Europe, i.e. the effect on consumer was assessed after 
the  initial  impulse  and  induced  demand  reaction  of  the  policy  was  fed  through  the 
economy. 

Summarising  an  analysis  of  output  and  employment  effects  in  response  to  a  policy  or 
measure  needs  to  tackle  all  those  sectors  that  are  affected  because  of  the  regulation-
induced  changes  in  demand  for  goods  and  products.  These  include  direct  output  and 
employment  effects  because  of  the  change  in  investment  or  production,  such  as 
increased  investment  in  a  specific  technology,  as  well  as  indirect  output  and 
employment effects because of the change in demand of products and goods further up 
the production chain. While direct output and employment effects can be assessed based 
on  simple  input  coefficients  (e.g.  additional  output  and  employment  per  unit  of  in-
vestment, additional output and employment per unit of turnover etc.), assessing indirect 
effects  requires  an  economic  approach  that  covers  all  economic  sectors  and  their 
interactions. Using a more comprehensive modelling framework based on official input-
output  statistics,  e.g.  input-output  analysis  as  applied  by  EmIO  Europe,  allows 
addressing both direct and indirect output and employment effects.  

EmIO Europe can give a basic assessment of the effect of the additional burden a policy 
or measure may impose on the economy as well of the effect of recycling of revenues 
that  may  be  raised  by  a  policy  or  measure.  The  financial  burden  to  cover  needed 
investments can be expressed as a reduction in demand distributed across sectors, while 

EN 

136 

   EN 

 
revenue recycling may – even at the same time – stimulate demand across the same or 
others  sectors.  The  model  can  differentiate  these  demand  induced  third-stage 
employment effects for households, industry and/or government. 

EmIO  Europe  provides  a  fairly  easy-to-use  tool  for  understanding  linkages  between 
different parts of the economy. It has the advantage of  

– 

– 

– 

Providing direct and indirect effects 

Giving a relatively high resolution of sectoral detail (for the EU: NACE 
Rev1.1 59 2-digit sectors, higher resolution in NACE Rev.2) 

Input-output and employment data readily available (data on investment, 
however, is required) 

–  Medium degree of complexity 

– 

– 

– 

Simple  relationships  (Leontief  production  structure  for  production 
sectors) 

No special software requirement: Spreadsheets 

High transparency  

However, one has to keep in mind that the Input-Output Model is static and therefore 
assumes  fixed  ratios  for  inputs  and  production.  Furthermore,  it  lacks  supply-side 
information or budget constraints. The model can be used to give a good indication of 
the magnitude and direction of the effects. It can be considered a basic assessment and 
may also provide a first stage of a more comprehensive assessment. 

EN 

137 

   EN 

 
3. 

SENSITIVITY ANALYSIS OF EMPLOYMENT IMPACTS 

This section presents a sensitivity analysis of the output effects by relaxing some of the 
assumptions made. As the calculation of the output effect is an intermediate step in the 
calculation  of  the  employment  effects  those  effects  are  likely  of  the  same  sign  and 
magnitude.  

The first assumption concerns the way in which households react to increased costs by 
reducing their demand for goods. Up to now we have assumed that the additional costs 
incurred  from  compliance  with  the  policy  reduces  final  demand  proportionally  for  all 
production sectors (proportional scenario). If instead the additional costs do not affect 
demand for basic products (such as food, textiles, furniture, electronic equipment, most 
services) but will reduce demand for products from those sectors that are affected by the 
regulation  (subsistence  scenario).  The  analysis  shows  that  the  output  effect  of  the 
subsistence scenario is less pronounced. This is due to the fact that more of the demand 
reduction concerns imports in the subsistence scenario (24% instead of 16%) and thus 
does  not  stimulate  production  activity  in  the  EU.  Figure  A_IX-2  compares  the  output 
effects of the two variations for all three policy options.  

Proportional

Subsistence/ Elasticity

Phase-Down

Ban

VA

0.00%

0.00%

0.00%

-0.01%

-0.01%

-0.01%

-0.01%

-0.01%

-0.02%

Fig. A_IX-2:   Output effect of different assumptions on demand reduction by consumers 

However,  independent  of  the  assumptions  relating  to  the  demand  reaction,  the  overall 
effect remains about the same (see Fig. A_IX-3 below). 

EN 

138 

   EN 

 
 
Fig. A_IX-3: 

Output  effect  for  the  different  options  under  different  assumptions  on 
consumer reaction (as % of 2007 overall output) 

The second sensitivity analysis estimates output effects sensitivity of reduced prices for 
unsaturated HFCs. The most notable effect occurs in the chemicals sector, for which the 
policy-induced change in investment is now negative for all three options, with the least 
negative effect on production activity occurring for Option D (Phase Down) (See Figure 
A_IX-4).  This  effect  is  due  to  the  fact  that  under  this  assumption  that  conventional 
HFCs are more expensive than their replacements, meaning that less money flows into 
the  chemicals/gases  sector.  Again,  however,  the  overall  picture  remains  very  close  to 
the base case (see Figure A_IX-5). 

EN 

139 

   EN 

 
 
Fig. A_IX-4:  Output  effects  of  half-price  scenario  on  the  chemicals/gases  sector  (as  %  of 

2007 sector output) 

Fig. A_IX-5: 

Overall effects of a half-price scenario (as % of 2007 output) 

EN 

140 

   EN 

 
 
 
 
 
 
ANNEX X: Mechanism for the Placement of HFCs on the EU Market 

1. 

INTRODUCTION AND SUMMARY 

The  main  concept  for  a  phasedown  mechanism  entails  defining  a  reduction  pathway  between 
the current and a future level for the placing of HFCs on the EU market.  

In this annex, sub-options for mechanisms implementing the policy option to phasedown of the 
placing  on  the  market  of  HFCs  (option  D)  are  developed  and  discussed.  For  each  set  of  sub-
options one option was chosen for further consideration. 

In  the  chosen  scope  of  the  proposed  phasedown  mechanism,  “placing  on  the  market”  (POM) 
refers to making available HFCs to the EU market (sold production + import) for the first time 
and  is  limited  to  HFC  flows  in  bulk  quantities,  thus  not  accounting  for  HFCs  contained  in 
imported  products  or  equipment.  Exported  bulk  HFCs  are  not  regarded  as  “placed  on  the 
market” if they are either directly exported by producers or exported by third parties when the 
quantities had been purchased for that purpose. The list of HFCs covered by the phasedown is 
almost  identical  to  the  list  of  HFCs  covered  by  the  current  F-Gas  Regulation:  The  list  is 
amended by two additional HFCs (HFC-152 and HFC-161) for which the IPCC provided GWP 
values in its Fourth Assessment Report. The GWPs of the Fourth IPCC Assessment Report shall 
be  used  for  the  conversion  of  physical  tonnes  into  CO2  equivalents.  No  exemptions  for  HFC-
using sectors are foreseen. 

The  limitation  for  the  placing  of  HFCs  on  the  EU  market  (“cap”)  for  subsequent  periods 
decreases  over  time.  The  proposed  reduction  schedule  features  a  step-wise  reduction,  starting 
with a freeze at a baseline level in 2015, a first reduction step in 2016 and a final step down in 
2030 reaching 29% of the baseline. The reduction steps are based on the expected feasibility of 
using  alternative  substances.  Decisions  on  the  additional  reductions  beyond  2030  should  be 
made  at  a  later  stage,  but  well  before  2030,  taking  into  account  new  technological 
developments. 

Under the reduction scheme, entities that place HFCs on the EU market have to hold rights to 
place  HFCs  on  the  market  (quotas),  expressed  in  tonnes  of  CO2eq.  The  sum  of  these  quotas 
should not exceed the defined maximum level for a respective year for the EU. The Commission 
allocates  quotas  to  involved  producers  and  importers,  using  a  central  database  where  quota 
accounts  of  all  companies  placing  HFCs  on  the  EU  market  are  held.  The  allocation  method 
chosen  for  further  consideration  is  allocation  by  grandfathering,  i.e.  based  on  past  activities. 
Quotas may be transferred between companies, but the transfer of unused quota at the end of a 
year to subsequent years is not allowed.  

As  under  the  present  F-Gas  Regulation,  stakeholders  annually  report  to  the  Commission  and 
Member  States  on  stocks,  production,  import  and  exports  of  regulated  HFCs  which  allow  the 
calculation of their respective placing of HFCs on the market. Reports above certain thresholds 
shall  be  subject  to  independent  verification.  Reporting  on  reclamation  and  destruction  is 
enhanced.   

Enforcement and compliance, beyond the administration of the quotas at EU level, follows the 
general responsibilities for the enforcement of EU legislation. MS would need to take measures 
in  cases  of  non-compliance  as  part  of  the  implementation  of  a  revised  F-Gas  regulation  to 
ensure that the HFC phasedown is implemented.  

EN 

141 

   EN 

 
 
In  order  to  ensure  the  integrity  of  the  phasedown  mechanism  it  is  necessary  to  foresee 
complementary measures addressing the placing on the market of equipment pre-charged with 
HFCs.  Already  today  the  amounts  of  HFCs  imported  in  equipment  account  for  11%  of  the 
overall  EU  demand  and  is  expected  to  reach  a  share  of  18%  in  2030  if  left  unaddressed. 
Whereas for hermetically sealed systems bans of certain types of equipment are envisaged, for 
other systems a ban on pre-charging before importation should ensure that the quantities used 
for the first fill are captured by the phasedown.   

2. 

SCOPE 

2.1. 

Coverage of substances 

Any  mechanism  limiting  the  placing  on  the  market  of  HFCs  needs  to  clearly  define  the 
substances controlled under such a scheme.  

HFCs to be specified individually in a list 

2.2. 
The current Regulation (EC) No 842/2006 defines the scope by means of a general definition80 
complemented by a list of individual substances in an annex in which the individual substances 
are  grouped  according  to  their  chemical  similarities.  The  Montreal  Protocol  and  the  Kyoto 
Protocol  use  a  similar  approach  by  listing  the  gases  covered.  Such  a  list  of  HFCs  would  be 
annexed to a regulation or decision in the same way as in the current F-Gas Regulation and for 
HFCs such a list could include the following chemical species as indicated in Table A X-1. This 
list includes all HFCs for which the IPCC has already provided an official GWP. 

HFC-152  and  HFC-161,  which  are  included  in  Table  1,  are  not  covered  by  the  current  F-Gas 
Regulation  but  should  be  included.  These  HFCs  could  become  potential  alternatives  to  other 
HFCs, in particular in preparations. Under the UNFCCC there is an agreement that new HFCs 
for which the Fourth IPCC Assessment Report has provided a GWP should be included in the 
future  reporting  of  greenhouse  gas  emission  inventories  and  also  in  emission  reduction 
commitments  of  a  second  commitment  period  under  the  Kyoto  Protocol81.  For  consistency  in 
monitoring  and  reporting  with  the  future  modalities  under  the  UNFCCC  and  the  Kyoto 
Protocol,  it  is  therefore  recommended  that  all  HFCs  are  included  in  such  a  list  for  which  the 
IPCC has provided a GWP in its most recent assessment report. 

In both amendment proposals to the Montreal Protocol that have currently been proposed, the 
scope  of  substances  covers  all  HFCs  as  listed  in  Table  A_X-1.  In  addition,  two  unsaturated 
HFCs, i.e. HFC-1234yf (GWP 4) and HFC-1234ze (GWP 6) are also included, which are not 
included in the Fourth IPCC Assessment Report and do not have an GWP determined under the 
UNFCCC.   

80 

81 

‘Fluorinated greenhouse gass’ means hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and 
sulphur hexafluoride (SF6) as listed in Annex I and preparations containing those substances, but 
excludes substances controlled under Regulation (EC) No 2037/2000 of the European Parliament 
and  of  the  Council  of  29  June  2000  on  substances  that  deplete  the  ozone  layer. 
‘Hydrofluorocarbon’ means an organic compound consisting of carbon, hydrogen and fluorine, 
and where no more than six carbon atoms are contained in the molecule. 
Annex III to decision -/CP.17 on “the Revision of the UNFCCC reporting guidelines on annual 
inventories  for  Parties  included  in  Annex  I  to  the  Convention”  and  decision  -/CMP.7  on 
“greenhouse gass, sectors and source categories, common metrics to calculate the carbon dioxide 
equivalence  of  anthropogenic  emissions  by  sources  and  removals  by  sinks,  and  other 
methodological issues”  

EN 

142 

   EN 

 
                                                 
Table A_X-1 

List  of  HFC  species  and  GWPs  according  to  the  IPCC  2nd  Assessment 
Report (SAR), 3rd (TAR) and 4th Assessment Report (FAR) 

Chem ical Form ula

Industrial 
Designation or 
Com m on Nam e

Hydrofluorocarbons

HFC-23

HFC-32

HFC-41

HFC-125

HFC-134

HFC-134a

HFC-143

HFC-143a

HFC-152

HFC-152a

HFC-161

HFC-227ea

HFC-236cb

HFC-236ea

HFC-236fa

HFC-245fa

HFC-245ca

HFC-365mfc

HFC-43-10mee

CHF3
CH2F2
CH3F
CHF2CF3
CHF2CHF2
CH2FCF3
CH2FCHF2
CH3CF3
CH2FCH2F
CH3CHF2
CH3CH2F
CF3CHFCF3
CF3CF2CH2F
CF3CHFCHF2
CF3CH2CF3
CHF2CH2CF3
CH2FCF2CHF2
CH3CF2CH2CF3
CF3CHFCHFCF2CF3 or (C5H2F10)

Global Warm ing Potential for 100-
year tim e horizon

SAR

TAR 

FAR

11,700

12,000

14,800

650

150

2,800

1,000

1,300

300

3,800

550

97

3,400

1,100

1,300

330

4,300

140

120

2,900

6,300

560

3,500

1,300

1,200

9,400

950

640

890

675

92

3,500

1,100

1,430

353

4,470

53

124

12

3,220

1,340

1,370

9,810

1,030

693

794

1,300

1,500

1,640

Despite  the  inconsistency  with  the  proposed  amendments,  the  scope  of  the  phasedown 
mechanism should be limited to HFCs for which the IPCC has provided an 'official' GWP, as 
this is currently the major science-based process for such a determination. Otherwise it would 
be necessary to establish a parallel scientific process to assess the GWPs for new gases which 
seems beyond the mandate of the revision of the F-Gas Regulation.  

The inclusion of unsaturated HFCs with a low GWP in the phasedown would only have a minor 
impact on the calculated future supply if expressed in CO2eq. In the scenarios calculated for this 
report,  the  consumption  of  unsaturated  HFCs  totals  approx.  216  kt  CO2eq  in  2030.  This  is 
0.16%  of  the  total  supply  in  2030.  The  two  unsaturated  HFCs  should  be  included  in  the 
reporting requirements under a revised F-Gas Regulation in order to ensure adequate monitoring 
and  reporting  of  their  production  and  consumption,  also  for  the  case  an  international  HFC 
phasedown mechanism, including these substances, is agreed. 

2.3. 

Considered alternative(s) 

Beside an enumeration of the covered HFCs in a list, the alternative option considered was to 
include  only  HFCs  above  a  certain  (GWP)  threshold.  In  view  of  ensuring  consistency  with 

EN 

143 

   EN 

 
 
current policy approaches and the initiatives at international level, but also to avoid uncertainties 
with  regards  to  the  determination  of  a  GWP  for  a  substance  in  question,  the  latter  option  has 
been discarded. 

2.4. 

Coverage of mixtures/preparations 

It  is  also  necessary  to  define  how  substances  that  consist  of  mixtures  of  HFCs  or  mixtures  of 
HFCs with other substances would be treated. A consistent treatment would mean that only the 
specific  component  of  a  mixture  would  fall  under  the  scope  of  a  phasedown  mechanism  if  a 
controlled HFC component specified in the list is contained in the mixture. In terms of enforcing 
the  regulation  this  means  that  the  components  of  the  mixtures  are  treated  as  individual 
substances  and  measures  are  needed  to  enable  the  identification  of  the  components  of  such 
mixtures.  

Such a rule would diverge from the current F-Gas Regulation that defines “preparations“ as a 
mixture composed of two or more substances, at least one of which is a fluorinated greenhouse 
gas,  except  where  the  total  GWP  of  the  preparation  is  less  than  150.  However,  it  seems 
inconsistent  to  use  a  GWP  threshold  for  preparations,  but  not  in  general  for  the  scope  of  F-
Gases.  

2.5. 

Recovered, recycled and reclaimed HFC 

Recovered, recycled and reclaimed HFC quantities should not be included in the scope 
of the phasedown mechanism in order not to offset efforts made according to Article 4 
of the F-Gas Regulation which reduces the demand for virgin HFCs. This is also in line 
with  the  ODS  Regulation,  which  excludes  these  quantities  from  controls  of 
production.82  

3. 

ACTIVITIES SUBJECT TO QUANTITATIVE RESTRICTIONS 

The proposed HFC phasedown mechanism refers to the placing on the market of HFCs 
in the EU and is thus related to the supply of HFCs. “Placing on the market” is defined 
in the F-Gas Regulation (Article 2 point 7) as “the supplying of or making available to a 
third party within the Community for the first time, against payment or free of charge, 
[…] and includes import into the customs territory of the Community”.  

3.1. 

HFCs in imported equipment 

The  phasedown  mechanism  follows  the  approach  chosen  under  the  Montreal  Protocol 
for ozone depleting substances and reduces the availability of HFCs over time, in this 
way  eliminating  potential  sources  of  future  emissions.  Whether  measures  on  bulk 
substances  alone  would  be  sufficient  to  reach  the  intended  emission  reductions  in  the 
EU depends on the share of emission sources in the EU not covered by the mechanism 
in  such  a  case.  The  supply  of  bulk  HFC  in  the  EU  does  not  represent  accurately  the 
amount  of  substances  which  can  potentially  be  emitted  in  the  EU  if  there  is  a 
considerable  amount  of  substances  contained  in  imported  pre-charged  equipment.  The 
first fill of such equipment is carried out in a third country and manufacturing emissions 

82 

ODS  Regulation:  “No  amount  recovered,  recycled  or  reclaimed  shall  be  considered  as 
production“. 

EN 

144 

   EN 

 
                                                 
occur  there.  After  import  and  installation  of  the  equipment,  use-phase  and  disposal 
emissions arise in the EU. 

HFC  quantities  contained  in  pre-charged  equipment  already  account  for  a  significant 
share of HFCs on the European market in several sectors, such as mobile and stationary 
AC, and is projected to increase. Most relevant is the stationary AC sector (in particular 
smaller AC units such as single-splits and movables) for which high growth is projected 
(Schwarz et  al.  (2011)9.  75-90%  of  the  split  and  multi-split air conditioners and small 
moveable systems are imported from outside the EU, in particular from Asia.  

The  ratio  of  HFCs  in  pre-charged  equipment  being  imported  to  the  EU  relative  to 
overall  EU  demand  is  currently  11%  (18  Mt  CO2eq)  and  is  projected  to  amount  to  a 
share of 18% or 31 Mt CO2eq HFC supplied to the EU in the year 2030 (see Table A_X-
2 and Figure A_X-1). ). Details on the sectoral distribution are provided in Tables A_X-3 
and A_X-4.  

Table A_X-2 

Supply  of  HFCs  in  EU-27  (Mt  CO2eq)  in  the  baseline  scenario  (F-Gas 
Regulation and MAC Directive in place; option A) in the period 2010-2050 
– with and without pre-filled systems 

Year 

2010 

2015 

2020 

2030 

2050 

Supply  for  domestic  fill/refill 
(supply) 

Supply  of  HFCs  in  imported 
pre-filled systems  

Total  demand  incl.  pre-filled 
imported systems 

Source: AnaFgas 

152 

18 

170 

141 

24 

165 

140 

27 

167 

139 

31 

170 

143 

32 

174 

EN 

145 

   EN 

 
HFC supply in EU-27. WM  scenario 
excluding and including imported pre-filled systems 

q
e
2

O
C

t
k

200,000

180,000

160,000

140,000

120,000

100,000

80,000

60,000

40,000

20,000

0

2000

2005

2010

2015

2020

2025

2030

2035

2040

2045

2050

HFCs incl imported prefill

HFCs for domestic fill+refill only

Fig. A_X-1: 

Supply of HFCs to EU-27 (kt CO2eq) in the baseline (WM) scenario (F-Gas 
Regulation and MAC Directive in place; option A) in the period 2000-2050 
with and without pre-charged systems 

With regard to pre-charged equipment, two categories need to be distinguished:  

– 

– 

Hermetically  sealed  pre-charged  equipment  is  filled  during  manufacture  and 
sealed  before  import;  refilling  is  not  required.  Only  the  import  of  moveable 
room  air  conditioners  is  quantitatively  relevant.  Other  types  of  hermetically 
sealed  pre-charged  equipment  are  not  imported  in  large  quantities,  e.g. 
commercial  refrigeration  systems,  heat  pumps,  tumble-dryers  and  domestic 
refrigerators containing HFCs.  

Other pre-charged equipment, for example split-air conditioners, is usually filled 
with an initial charge during manufacture. This type of equipment needs in some 
cases to be topped up with refrigerant before use and possibly during service.  

On the other hand, some quantities of HFCs supplied in the EU are not used and finally 
emitted  in  the  EU  but  filled  into  equipment  which  is  exported.  Domestic  first  fill  for 
export  equipment  is  relevant  with  regard  to  mobile  air  conditioners  of  motor  vehicles 
and  medical  aerosols  (MDIs).  XPS  (extruded  polystyrene)  insulation  boards  blown 
using HFC-134a constitute an export stream of HFCs in products as well.  

Table  A_X-3  presents  in  a  more  disaggregated  way  the  sectorial  figures  on  the  HFC-
using sectors  affected by the proposed phasedown  scheme.  It  indicates the HFC  types 

EN 

146 

   EN 

 
 
mainly  used,  main  replacement  options  and  demand  estimates  for  2010  and  2030, 
including  bulk  substance  plus  imports  of  pre-charged  systems  and  exports  of  prefilled 
systems.  It  also  indicates  the  sectors  in  which  imports  or  exports  of  equipment  or 
products containing HFCs are relevant.  

Table A_X-4 provides quantitative data on the sectorial demand in CO2eq tonnes. 

EN 

147 

   EN 

 
Table A_X-3 

Sectoral demand of HFCs and shares of imported or exported equipment / products containing HFCs 

Sector 

HFCs used 

HFC  demand 
CO2eq] 

(ext2) 

[kt 

Replacement 
options 

2010 

2030 
baseline 
scenario 

Growth 
2030  vs. 
2010 

Pre-charged 
HFC 
equipment/ 
products  

Import:  
share 
pre-
charged 
of 
demand 
2010 

Export: 
share 
pre-
charged 
of 
demand 
2010 

Remarks 

Total    
   Refrigeration 

   Domestic Refrigeration 

   Commercial Refrigeration 

Industrial Refrigeration 

Road 
Refrigeration 
Shipping 
(fisheries) 

transport 

Refrigeration 

HFC-134a 
HFC  134a;  HFC  143a; 
HFC 125 
HFC  134a;  HFC  143a; 
HFC 125; HFC-32 
HFC  134a;  HFC  143a; 
HFC 125 
HFC  134a;  HFC  143a; 
HFC 125 

Stationary  A/C  and  Heat 
Pumps 

   Room A/C moveables 

HFC-32; HFC-125 

   Room A/C single split 

HFC-32; HFC-125 

   Rooftop 

HFC-32; HFC-125 

Variable Refrigerant Flow 
& Multisplit 

HFC-32; HFC-125 

   Chillers (displacement) 

HFC-134a;  HFC-32; 
HFC-125 

169,853  170,421 
55,265 
60,557 
0 
3 

568 
-5,292 
-3 

negl. 

negl. 

no 

36,320 

34,867 

-1,453 

negl. 

HC 
HFC-1234yf; 
HC; CO2 

NH3 

20,128 

14,046 

-6,082 

negl. 

HFC-1234yf; 
HC; CO2 

3,718 

5,348 

1,630 

negl. 

NH3 

388 

1,004 

616 

no 

39,240 

72,724 

33,484 

no 

no 

no 

no 

negl. 

negl. 

negl. 

no 

CO2; 

HFC-1234yf; 
HC; CO2 
HFC-1234yf; 
HC; 
HFC32 
HFC-1234yf; 
HC; CO2 
HFC-1234yf; 
HC; CO2 
HFC-1234yf 
HC; CO2; NH3 

2,391 

6,980 

4,589 

yes 

69% 

negl. 

23,492 

45,428 

21,936 

yes 

50% 

negl. 

1,175 

1,358 

183 

yes 

22% 

negl. 

2,618 

5,187 

2,570 

yes 

42% 

negl. 

6,610 

6,722 

112 

yes 

4% 

negl. 

EN 

148 

EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Sector 

HFCs used 

HFC  demand 
CO2eq] 

(ext2) 

[kt 

Replacement 
options 

2010 

2030 
baseline 
scenario 

Growth 
2030  vs. 
2010 

Pre-charged 
HFC 
equipment/ 
products  

Import:  
share 
pre-
charged 
of 
demand 
2010 

Export: 
share 
pre-
charged 
of 
demand 
2010 

Remarks 

   Centrifugal chillers 

HFC-134a 

   Heat Pumps 

HFC-32; HFC-125 

uHFCa,  HC, 
H2O 
HFC-1234yf; 
HC; 
HFC32 

CO2; 

567 

605 

38 

no 

2,386 

6,443 

4,057 

negl. 

no 

negl. 

   Mobile A/C 

40,326 

11,953 

-28,373 

   Car A/C 

HFC-134a 

HFC-1234yf 

33,837 

3,453 

-30,384  yes 

8% 

10% 

   Bus A/C 
   Truck A/C 

Ship A/C 
   Rail A/C 

   Foams 

HFC-134a 
HFC-134a 
HFC-134a 
HFC-134a 

HFC-1234yf 
HFC-1234yf 
NH3, XP10 
CO2 

   One Component Foam 

PU foam 

HFC-134a 
HFC-365mfc;  HFC-
227ea; HFC-134a 

HC 
HFC-1234ze; 
HC 

   XPS 

HFC-134a; HFC-152a 

HFC-1234ze; 
HC; CO2 

1,918 
3,532 
901 
137 
10,935 
255 

1,870 
4,688 
1,771 
171 
10,810 
311 

-48 
1,155 
869 
35 
-125 
56 

6,128 

5,947 

-181 

yes 
yes 
yes 
no 

negl. 

negl. 

3% 
9% 
4% 

6% 
11% 
no 

negl. 

negl. 

4,553 

4,553 

0 

yes 

no 

20% 

   Other HFCs 
   Aerosols 
   Metered dose inhalers 

Solvents 

HFC-134a 
HFC-134a; HFC-227ea   
HFC-43-10mee 

HFC-1234ze 

18,795 
3,960 
7,670 
330 

19,668 
3,960 
8,471 
330 

873 
0 
801 
0 

negl. 
yes 
no 

negl. 
negl. 

negl. 
50% 

After  2017: 
HFC  
No 
import 
, 
export 
100%  

only  with 
HFC-134a 
(not 152a) 

EN 

149 

EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Sector 

HFCs used 

HFC  demand 
CO2eq] 

(ext2) 

[kt 

Replacement 
options 

2010 

2030 
baseline 
scenario 

Growth 
2030  vs. 
2010 

Pre-charged 
HFC 
equipment/ 
products  

Import:  
share 
pre-
charged 
of 
demand 
2010 

Export: 
share 
pre-
charged 
of 
demand 
2010 

Fires extinguishers 

HFC-227ea;  HFC-23; 
HFC 236fa; HFC-125 

FK-5-1-12 

6,721 

6,785 

64 

no 

Aluminium & Magnesium 
Casting 

HFC-134a 

Semiconductor 
Photovoltaics 

and 

HFC 23 

Note: a uHFC: unsaturated HFC 

Source: Estimates based on AnaFgas  

39 

47 

76 

76 

9 

0 

no 

no 

HFCs: List of substances as in Table A X-1; GWPs of Fourth IPCC Assessment Report 

Remarks 

HFC-134a 
is 
replacement 
for SF6 

EN 

150 

EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Table A_X-4 

Sectoral demand of HFCs and unsaturated HFCs (uHFC) and shares of imported/exported equipment/products containing HFCs [GWP] 

HFC demand (ext2)  

[Mt CO2eq] 

Sector 

uHFC demand  

(ext 2)  

[Mt CO2eq] 

Thereof 
pre-charged equipment 

import  HFC 

[Mt CO2eq] 

HFC 
imported 

Thereof 
refill 
pre-charged 
equipment.  

[Mt CO2eq] 

Thereof  export  HFC 
pre-charged equipment  

[Mt CO2eq] 

2010 

2030 
baseline 
(WM) 
scenario

Growth 
2030 
vs. 
2010 

2030  

Phasedown 
(WAM 
scenario) 

Red. 
potential 
2030 WAM 
vs. WM 

2030 
WM 
scenario 

2030 
WAM 
scenario

2010

2030 
WM 
scenario

2030 
WAM 
scenario

2010

2030  WM 
scenario 

2010

2030 
WM 
scenario 

2030 
WAM 
scenario 

Total    
   Refrigeration 

Stationary A/C and 
Heat Pumps 

Room A/C 
moveables 
Room A/C single 
split 
   Rooftop 
Variable 
Refrigerant Flow 
& Multisplit 
Chillers 
(displacement) 

   Mobile A/C 
   Car A/C 
   Bus A/C 

170 
61 

39 

170
55

73

1
-5

33

2.4 

7.0

4.6

23.5 

45.4

21.9

1.2 

2.6 

6.6 

40 
33.8 
1.9 

1.4

5.2

6.7

12
3.5
1.9

0.2

2.6

0.1

-28
-30.4
-0.0

36
9

7

-

-

0.0

0.2

0.3

6
3.5
0.2

EN 

0.3
0.0

0.1

18
0

15

31
0

30

0.0

1.7

4.8

0.1

11.7

22.7

0.0

0.3

0.0

1.1

0.0

0.1
0.1
0.0

0.3

3
2.7
0.1

0.3

2.2

0.3

1
-
0.1

-134
-46

-66

-7.0

-45.4

-1.3

-5.0

-6.5

-6
-
-1.7

0.1 
- 

- 

- 

- 

- 

- 

- 

0.1 
0.1 
- 

151 

9
0

0

9 
0 

0 

8 
0 

0 

0
0

0

-

-

0.0

8
0

8

0.6

6.3

0.1

0.1

0.9

16
0

15

1.6

11.3

0.1

2.4

0.0

0
-
0.0

0

1

4
3.5
0.1

4 
3.5 
0.1 

4 
3.5 
0.0 

EN 

 
  
  
  
  
 
  
  
  
  
 
  
  
  
 
  
  
  
  
 
  
  
  
  
 
 
 
  
  
  
 
 
  
 
 
   Truck A/C 
   Ship A/C 

   Foams 

   XPS 
   Other HFCs 
   MDI 

3.5 
0.9 
11 
4.6 
19 
7.7 

4.7
1.8
11
4.6
20
8.5

1.2
0.9
-0
-
1
0.8

0.7
1.1
4
-
10
8.5

-4.0
-0.6
-6
-4.6
-9
-

- 
- 
- 
- 
- 
- 

0.3
0.0
0

0

0.0
-
0.0
0.0
0.0
-

0.4
0.1
0

0

0.1
0.0
0

0

0.4

0.8

0.4

0

0

0

0

1
0.9
4
3.8

0.5 

1 
0.9 
4 
4.2 

0.1 

0 
- 
4 
4.2 

Note: a uHFC: unsaturated HFCs: HFC-1234yf (GWP 4), HFC-1234ze (GWP 6) 

Source: Estimates based on AnaFgas; HFCs: List of substances as in TableA X- 1; GWPs of Fourth IPCC Assessment Report 

EN 

152 

EN 

 
  
  
  
 
 
 
  
  
  
 
 
 
 
 
  
 
 
 
 
 
3.2. 

Options for taking measures on pre-charged equipment 

Without  specific  measures  on  HFCs  in  pre-filled  equipment  alongside  a  phasedown 
mechanism, these HFCs would be a continuously growing source of HFCs emissions in 
the EU.  

As a first approach it was therefore considered to integrate quantities contained in pre-
charged equipment in a phasedown regime. The high number of entities which would be 
covered by this extended scheme was one determining factor to discard this option. In 
2010, 107 stakeholders were involved in production, import and export of bulk HFCs in 
quantities of more than 1 tonne/year.83 For import and export of products and equipment 
containing  HFCs,  no  reporting  obligations  exist  so  far.  The  numbers  of  producers, 
importers and exporters of pre-charged equipment can be estimated as shown in Table 
A_X-5.  Whereas  the  number  of  producing  firms  of  prefilled  equipment  is  limited,  the 
amount  of  distributors  can  only  be  estimated  and  is  most  likely  high.  The  order  of 
magnitude  of  affected  importers  and  exporters  could  be  thousands,  depending  on  the 
thresholds for the application of the phasedown mechanism chosen. 

Table A_X-5 

Estimates of producers and distributors of products or equipment containing 
HFCs 

2010 

XPS-134a 

Air 
passenger cars 

conditioned 

Air  conditioned  lorries 
(N1-N3) 

Air conditioned buses 

Stationary AC 

-  Chillers 

Stationary AC 

-  Excluding 
chillers 

MDI 

Third 
country 
based  producers 
of 
for 
systems 
export into EU 

EU 
producers 
systems 
export 
countries 

to 

based 
of 
for 
third 

EU-based 
distributors  of 
systems 
imported  from 
third countries 

based 
EU 
distributors 
of 
systems for export 
to third countries 

0 

10 

5 

0 

10 

10 

0 

3 

12 

12 

5 

4 

2 

8 

0 

unknown 

high number 

unknown 

high number 

unknown 

few 

few 

high number 

< 10 

very high 
number 

0 

< 10 

~ 30 

Source:  

Estimates Öko-Institute 

83 

8 producers, 70 importers and 68 exporters submitted reports, some companies carry out two or 
all activities. 

EN 

153 

   EN 

 
                                                 
Hence,  the  inclusion  of  imports  of  pre-charged  equipment  would  subject  a  presently 
unknown, high number of importers as stakeholders to the phasedown mechanism. Most 
of  those  importers  would  probably  have  rather  small  amounts  of  placements  on  the 
markets. Experiences from the EU ETS show that “small” participants often have little 
knowledge of the system and create a lot of problems in administering the system.  

Furthermore, the market for HFCs in bulk is mature and stable with regard to the market 
players and shares. Under these conditions a reduction of the flexibility of this market, 
which  would  be  the  result  of  any  phasedown  mechanism,  seems  acceptable.  But  this 
would not be the case for an inhomogeneous market, like the one for the broad variety 
of  HFC  containing  equipment,  which  has  to  be  open  for  new  entrants  and  innovative 
products.  An  inclusion  of  HFC  contained  in  pre-charged  equipment  in  the  phasedown 
mechanism  could  in  particular  negatively  impact  on  the  market  access  for  SMEs 
launching new types of equipment or extending current activities. Moreover, importers 
of equipment and products that shift towards alternatives would be able to transfer their 
allocated  POMs 
and generate  windfall  profits.  Consequently, since domestic 
producers of  similar  equipment  and  products  do  not  receive  POMs  that  could  be  used 
for  providing windfall  profits,  they would  be  put  at  a  price competitive  disadvantage 
compared to importers. 

Consequently, a direct inclusion of imports under the cap is not a good solution as it is 
discriminatory  (as  only  importers  would  be  subjected  to  a  registration  and  reporting 
scheme,  while  domestic  producers  only  experience  possible  price  increases  from  the 
cap),  difficult  to  administer  and  design  in  the  absence  of  reliable  data  and  given  the 
potentially  high  number  of  entities  to  be  regulated,  and  is  likely  to  create  perverse 
incentives and windfall profits. Furthermore, the flexibility of the inhomogeneous and 
dynamic market has to be preserved.  

Therefore, other options for addressing imports of pre-charged equipment and products 
containing  HFCs  were  considered  alongside  a  phasedown  mechanism  for  bulk 
substances.  Possibilities  include  (i)  to  prohibit  HFC  imports  contained  in  non-
hermetically sealed equipment (i.e. require filling in the EU), and (ii) specific bans. 

Imports  of  HFC  contained  in  non-hermetically  sealed  pre-charged  equipment  (i.e. 
single-split, multi-split, rooftops) may be addressed by means of a ban on precharging 
of these kinds equipment. All non-hermetically sealed equipment used in the EU should 
be filled on their installation site with HFC quantities which were either produced in the 
EU or imported in bulk quantities, and are thus subject to the phasedown mechanism. 
Such  a  measure  would  apply  to  both  domestically  and  foreign  produced  equipment 
equally and is therefore non-discriminatory. Equipment relying on HFCs would have to 
be imported or produced with a holding charge (e.g nitrogen) only. This measure would 
therefore also reduce possible emissions during transportation. By ensuring that HFCs 
fall  under  the  phasedown  cap,  replacement  of  HFCs  will  be  incentivised  also  for 
imported  equipment.  For  equipment  that  no  longer  relies  on  HFCs  the  filling 
requirement ceases to apply. 

The  first  fill  during  installation  has  the  additional  advantage  that  the  risk  of  illegal 
installations  by  unqualified  personnel  resulting  in  high  emissions,  malfunctioning  and 
loss of energy efficiency is greatly reduced. 

EN 

154 

   EN 

 
As  regards  manufacturing  costs,  these  are  estimated  to  not  exceed  €0.50  per  unit, 
including investments for additional equipment and labour costs, even when considering 
the most conservative assumption on the additional cost per unit (for split AC). Slightly 
higher costs for the user may occur for installing equipment where the phasedown cap 
has not yet triggered HFC replacement, for HFC equipment where topping up with gas 
is currently not necessary. 

Hence, due to the high consistency with the phasedown measure (i.e. HFCs for use in 
Europe all covered by phasedown), stakeholder acceptance and flexibility (as opposed 
to bans) and potential to improve compliance with installation requirements, requiring 
on-site  filling  is  the  preferred  option  to  address  HFCs  imported  in  non-hermetically 
sealed  (RAC)  equipment.  This  would  cover  86%  of  the  imported  AC  equipment 
refrigerant mass (data for 2008). 

The use of HFCs in sealed equipment which have to be filled during the manufacturing 
process  might  become  subject  to  specific  bans  as  analysed  in  Schwarz  et  al.  (2011)9. 
Such  bans  would  affect  imported  equipment  as  well  as  domestically  produced 
equipment and should in particular address, where possible, hermetically sealed systems 
(i.e AC movables), which represent 14% of imported refrigerant mass in AC equipment 
(data for 2008). 

3.3. 

Export of products containing HFCs 

The treatment of direct exports of products or equipment containing HFCs by producers 
or designated dealers is no issue for the environmental integrity of a phasedown system 
focused  on  the  EU  market,  as  emission  from  exported  HFCs  would  occur  outside  the 
EU.  However,  exports  of  products  containing  HFCs  previously  placed  on  the  EU 
market  would  be  covered  by  a  phasedown  scheme  and  would  reduce  the  quantities 
available  for  use  in  the  EU.  Thus,  exporters  of  EU-produced  products  or  equipment 
containing HFCs face a certain competitive disadvantage since the HFC needed for their 
products is included in the scope of a phasedown scheme. Sectors of concern are motor 
vehicles (including passenger cars, buses and lorries), metered dose inhalers (MDIs) and 
foams 
these 
products/equipment  fall  under  the  phasedown  measure  so  that  there  is  a  certain 
incentive to develop and use alternatives. For passenger cars the MAC Directive already 
limits  the  use  of  HFCs  drastically  so  this  is  not  an  issue  here.  Extra  cost  due  to  HFC 
price will also be very small for all transport AC sectors.  

insulation  boards).  HFCs  used 

(HFC-134a-blown  XPS 

in 

An unknown high number of exporters is affected. However, a differentiation of HFCs 
to  be  used  in  production  according  to  the  destination  of  the  final  products  is  not 
practicable at the moment of the placing on the market of the HFCs, in particular when 
the  substance  is  not  directly  purchased  from  a  producer  or  importer.  A  crediting  of 
exports, which could then be used for new production of HFCs or their import would, 
due  to  the  high  number  of  participants  and  transactions,  render  the  system 
unmanageable. 

EN 

155 

   EN 

 
3.4. 

Sectors covered 

Based  on  the  approach  of  the  Montreal  Protocol,  all  sectors  relying  on  HFCs  are 
covered by a phasedown mechanism. In this way, the phasedown could be established 
in the most flexible manner and would not inhibit innovation in particular areas.  

The  MAC  Directive  already  represents  an  implementing  measure  for  mobile  AC  in 
passenger cars and contributes to the overall phasedown. A sufficiently high tail supply 
should  integrate  sectors  and  applications  which  also  in  the  future  are  likely  to  rely  on 
HFCs  in  the  period  until  2030  and  for  which  alternatives  may  face  technical  or 
economic  constraints.  Such  a  tail  supply  would  need  to  include  HFC  quantities 
projected to be required for:  

(3) 

(4) 

(5) 

MDIs; 

particular  sectors  where  no  technically  feasible  and  safe  alternatives  are 
available such as technical aerosols, industrial refrigeration, XPS foams; 

Additional quantities for applications not known today or which today play a 
minor  role  but  could  possibly  increase  (e.g.  ORC,  specific  heat  pump 
applications, for example in tumble driers). 

In one quantitatively minor case, an HFC phasedown leading to higher HFC prices on 
the  domestic  EU  market  would  entail  a  perverse  incentive:  For  magnesium  foundries, 
HFC-134a (GWP FAR: 1430) is the replacement substance for SF6 (GWP FAR 22800) 
as the protective agent for the melt. Smaller magnesium foundries that do not fall under 
the  ban  as  defined  in  the  F-Gas  Regulation  would  receive  a  financial  incentive  not  to 
switch the F-Gas. However, if the phasedown is accompanied by a ban of the use of SF6 
in small magnesium foundries, this perverse incentive would vanish. 

It could be considered to establish exemptions from the phasedown of particular sectors 
or  subsectors.  It  is,  however,  likely  that  this  would  cause  considerable  difficulties  in 
defining  the  exact  scope  of  such  exemptions  and  would  substantially  increase  the 
administrative  burdens  for  all  authorities  and  companies  involved.  Furthermore, 
exemptions would open up possibilities for fraud.  

Feedstock use of HFCs is known in only one case: In one F-Gas manufacturing plant, 
HFC-23  (by-product)  is  not  fully  emitted  or  treated  in  an  incineration  device.  Large 
shares of this by-production, ca. 400-500 tonnes per year, are used in the same plant for 
halon-1301  production.  Halon-1301  serves  as  basic  material  for  the  manufacture  of  a 
broad-spectrum  insecticide.  It  is  not  recommended  to  introduce  any  exemptions  from 
the  phasedown  scope  for  HFCs  used  as  feedstock,  as  these  would  concern  only  very 
singular cases which do not warrant an administrative complication of the system. 

4. 

REDUCTION  SCHEDULE  FOR  A  PHASEDOWN  FOR  PLACING  HFCS  ON  THE 
MARKET 

The  proposed  phasedown  schedule  has  been  developed  on  the  basis  of  the  bottom-up 
model  (AnaFgas),  assessing  the  future  availability  and  pace  of  introduction  of 

EN 

156 

   EN 

 
alternative technologies in all main sectors currently relying on HFCs. The scope of that 
assessment  referred  to  the  EU  F-Gas  demand  including  imported  pre-charged 
equipment.  The  reduction  scenario  is  established  in  a  way  that  early  retirement  of 
equipment  already  in  use  does  not  count  towards  the  reduction,  while  new  equipment 
that is put into use after the old equipment has reached the end of its technical lifetime 
would fall under the cap. Therefore, the market has time to adjust to the new regulation 
and unforeseen costs for investors are not minimised. 

It has to be acknowledged that a bottom-up technology-based model like AnaFgas can 
never fully catch all applications of F-Gases and arrive at the same values like the top-
down  sales  statistic  of  the  EU  reporting.  Amongst  the  number  HFC  sub-sectors  not 
included in the model for lack of sufficient data are e.g. heat pump tumble dryers, water 
heating heat pumps, organic rankine cycle (ORC), thermometers, magnesium cover gas, 
semiconductor  etching  gas,  and  other  applications  which  may  not  be  known  to  the 
authors  of  the  model.  To  account  for  such  data  gaps,  inventory  makers  often  use  a 
“bottom-up surcharge” for “other” in the range of 10-20%. 

Reporting under the F-Gas directive is restricted to bulk substances. Thus imports and 
exports  of  HFCs  contained  in  pre-charged  equipment  is  not  accounted  for.  Reported 
sales  2010,  i.e.  approx.  192  Mt  CO2eq  (based  on  FAR),  are  above  the  model  values 
shown in Table A_X-4: in the latter case 152 Mt CO2eq (FAR) are calculated for bulk 
supply to the EU in 2010 (HFC demand: 170 Mt CO2eq minus import of HFC in pre-
charged  equipment:  18  Mt  CO2eq).  This  deviation  of  26%  is  not  surprising,  not  only 
because  of  the  sectors  not  covered  by  the  model,  but  also  due  to  high  2010  figures 
which  compensate  for  2009  losses  in  the  economic  crisis.  The  AnaFgas  model  was 
developed  in  2008  and  primarily  optimised  to  calculate  emissions  comparable  to  the 
emission  inventories.  Thus,  2010  demand  effects  were  hardly  foreseeable.  The  EU 
reporting system on F-Gases is still relatively new, and the demand of quality control in 
checking and aggregating the companies’ reports has proven to be very high. Thus, an 
overestimation in the reported EU figures is not impossible. 

To compensate for the mentioned uncertainties the phase-out schedule calculated on the 
basis of the model has been up scaled to match the quantities reported under the F-Gas 
regulation;  a  precaution  avoiding  a  shortage  in  supply  for  applications  which  are  not 
(yet) replaceable.     

In the following section the calculations of the demand with and without the inclusion 
of HFC contained in pre-charged equipment are illustrated, before in a second step the 
implications of the complementary measure (banning the placing on the market of non-
hermetic equipment which already contains a HFC pre-charge) are included. Finally, the 
phase-out  schedule  is  scaled  up  to  ensure  consistency  with  the  top-down  data  derived 
from the reporting under the F-Gas regulation.  

EN 

157 

   EN 

 
EU HFC demand scenarios 

"original WM" scenario (Schwarz et al.)

"original WAM" scenario (Schwarz et al.)

"modified WAM" scenario

200

180

160

140

120

100

80

60

40

20

q
e
2
O
C
t

M

0
2010

2014

2018

2022

2026

2030

2034

2038

2042

2046

2050

Fig. A_X-2: 

EU HFC demand scenarios 

N.B.: For the original WM (baseline) and WAM (here: phasedown) scenarios, the term demand includes 
the first fill of pre-charged equipment imported into the EU. For the modified WAM scenario, the 
term demand does not includes the first fill of pre-charged equipment imported into the EU. 

Source: Calculations based on Schwarz et al. (2011)9 

Under  the  scenario  which  includes  the  quantities  imported  in  equipment  ("original 
WAM") the higher demand until around 2020 is generated by the first fill (carried our in 
the exporting country) which is accounted for under the phasedown. It is assumed that 
under this scenario the number of imported equipment decreases over the time as result 
of the mechanism.  

Under the modified WAM scenario this incentive to switch to alternative technologies 
is missing and it is assumed that imports continue to increase (see Table A_X-2).84 As a 
consequence the demand for HFCs for the servicing of such systems, carried out in the 
EU,  is  increasing  and  exceeds  the  overall  demand  calculated  for  the  "original  WAM" 
scenario. 

In order to derive the total amount of virgin HFCs that needs to be placed on the market 
(POM) to fulfil the EU demand in the starting year, the estimated amounts of reclaimed 

84 

It must be noted that Table A_X-2 does not reflect the impact of a phasedown scheme without 
addressing HFCs in imported pre-charged equipment. It is likely that that import shares would 
increase even more in this case. 

EN 

158 

   EN 

 
 
 
                                                 
HFC  need  to  be  deducted  from  the  modified  WAM  demand  scenario.  Figure  A_X-3 
shows the comparison of demand and the calculated POM which is necessary to meet 
that demand for the modified WAM scenario. 

EU HFC demand and POM in the modified WAM scenario

EU HFC demand

Placment of bulk HFCs on the EU market for the
first time (POM)

180

160

140

120

100

80

60

40

20

q
e
2
O
C
t

M

0
2010

2014

2018

2022

2026

2030

2034

2038

2042

2046

2050

Fig. A X-3: 

Demand and POM in the modified WAM scenario 

Source: Calculations based on AnaFgas 

Reclaimed amounts are estimated by assuming that disposal emissions as calculated in 
the  AnaFgas  model  are  on  average  50%  of  the  F-Gas  content  at  the  end-of-life.  The 
other half is estimated to be partly reclaimed (16%) and destroyed (34%). 

The POM in the modified WAM scenario and the proposed phasedown steps are shown 
in Figure A X-4. The first limitation ("freeze") of the POM is suggested to take place in 
2015.  The  first  two  reduction  steps  are  designed  to  be  above  the  calculated  POM  in 
order  to  grant  more  flexibility  to  ensure  that  companies  have  sufficient  time  to  adapt: 
For the first reduction step in 2016 an additional margin of 10% of the model results for 
POM  are  added,  for  the  second  reduction  step  a  margin  of  5%  is  used.  All  later 
phasedown steps are designed to follow closely the technically feasible reduction of the 
modified  WAM  scenario.  At  present,  the  reduction  schedule  is  defined  up  to  2030. 
Decisions  on  the  pathway  beyond  2030  should  be  made  at  later  stage  but  well  before 
2030. 

EN 

159 

   EN 

 
 
 
Proposed EU bulk HFC POM phase-down steps

POM  [Mt CO2eq]

Proposed phase-down
steps

q
e
2
O
C
t

M

180

160

140

120

100

80

60

40

20

0

2010

2014

2018

2022

2026

2030

2034

2038

2042

2046

2050

Fig. A_X-4: 

Phasedown steps (POM of bulk HFCs) 

Source: Calculations based on AnaFgas 

If the bulk phasedown is accompanied by measures on HFC imports contained in non-
hermetically sealed equipment, a similar effect as explained for the difference between 
the  original  and  the  modified  WAM  scenarios  is  assumed:  In  the  first  years,  a  higher 
POM  within  the  EU  would  be  necessary  in  order  to  serve  the  additional  demand  for 
filling imported equipment. In later years (after 2020) a lower demand for HFCs can be 
expected, because for imported  non-hermetic equipment the  same rate of switching to 
alternatives to HFCs can be assumed as for domestically produced equipment. 

EN 

160 

   EN 

 
 
 
Proposed EU bulk HFC POM phase-down steps (incl. import ban)

Proposed EU bulk HFC POM phase-down steps (including measures on PCE) 

(incl. measures on PCE) 

POM  [Mt CO2eq]

Proposed phase-down steps

q
e
2
O
C
t

M

180

160

140

120

100

80

60

40

20

0

2010

2014

2018

2022

2026

2030

2034

2038

2042

2046

2050

Fig. A_X-5: 

Phase-down  steps  (POM  of  bulk  HFCs  accompanied  by  measures  on  pre-
charged equipment (PCE)) 

Source: Calculations based on AnaFgas 

As mentioned above, the reduction schedule derived from the model needs to be scaled 
up by 26% in order to meet the level of EU reporting on HFCs. Figure A_X-6 and Table 
A_X-6 describe the scaled phasedown schedule, which should be proposed as basis for 
the phasedown mechanism under the revised regulation. 

EN 

161 

   EN 

 
 
   
Proposed EU bulk HFC POM phase-down steps (including measures on PCE) 

Proposed EU bulk HFC POM phase-down steps (incl. import ban)

POM  [Mt CO2eq]

Proposed phase-down steps

q
e
2
O
C
t

M

200

180

160

140

120

100

80

60

40

20

0

2010

2014

2018

2022

2026

2030

2034

2038

2042

2046

2050

Fig. A_X- 6:  Phasedown  steps  (POM  of  bulk  HFCs  accompanied  by  measures  on  pre-
charged equipment (PCE)) (model results scaled to EU reporting levels) 

EN 

162 

   EN 

 
 
 
 
Table A_X-6  Key  features  of  the  proposed  phasedown  schedule,  accompanied  by  measures 

on pre-charged equipment (model results scaled to EU reporting levels) 

Coverage 

Baseline period 

Year of first control level 

Proposed first control level  

Final phasedown level 

Year of final step down 

Approximated  Placing  on  the  market 
for  the  first    time  of  bulk  HFCs  in 
2010  a 

Control schedule 

Proposed Reduction schedule  

Bulk HFC placing on the market  

2008-2011 

2015 

100%a 

21%a 

2030 

186 Mt CO2eq 

Starting Year 

POM Limit  
[Mt CO2 eq] 

Percentage of 2010a 

2015 

2016 

2018 

2021 

2024 

2027 

2030 

186 

173 

123 

83 

58 

44 

38 

100% 

93% 

63% 

45% 

31% 

24% 

21% 

Note:  a  The  final  values  for  the  POM  of  bulk  HFCs  in  the  2008-2011  are  not  yet  available.  Thus,  the 
percentages shown in this were calculated taking as a reference the AnaFgas model calculations for 2010 
and have illustrative character only. 

EN 

163 

   EN 

 
 
 
 
  
 
5. 

IMPLEMENTATION MECHANISM AND QUOTA ALLOCATION 

In order to implement the established reduction schedule, the placing on the market of 
HFCs needs to be quantitatively restricted. The cap and corresponding quotas should be 
expressed  in  tonnes  of  CO2  equivalents,  rather  than  physical  tonnes  or  kg  of  HFCs  in 
order  to  adequately  address  the  main  objective  of  reducing  greenhouse  gas  emissions. 
Using CO2 equivalents also has the advantage that companies focussing their portfolio 
on low GWP gases have the  highest benefits  and the pressure to innovate is strongest 
for substances with particular high GWP. 

All  producers  and  importers  of  bulk  HFCs  falling  under  the  scope  of  the  mechanism 
have  to  hold  quotas  representing  the  right  to  place  a  certain  amount  of  HFCs  on  the 
market.  Consumers  such  as  operators  of  equipment  or  maintenance  and  service 
companies  will  have  no  obligation  under  the  scheme.  To  avoid  disproportionate 
administrative burden, in particular for SMEs, a threshold should apply, comparable to 
the current threshold of one metric tonne of fluorinated gases currently applicable to the 
reporting requirements under Regulation (EC) No 842/2006. In view of the objective of 
the  regulation  to  reduce  the  climate  impact  of  F-Gas  emissions,  a  CO2  weighted 
threshold  should  be  chosen,  thus  creating  an  additional  incentive  to  prefer  HFCs  with 
lower  GWPs.  A  value  of  1 000  t  CO2eq  would  be  for  most  HFCs  (with  GWPs  above 
1,000) slightly more stringent than the existing one (one metric tonne).  

The  reduction  schedule  refers  to  the  EU  consumption  of  bulk  substances  defined  as 
production + imports – exports. Therefore, exported quantities do not count against the 
placing on the market quota.  

5.1. 

Quota allocation – allocation through grandfathering or auctioning 

The Commission establishes a central database for managing the allocation and use of 
quotas for individual companies (producers and importers). At the end of each year, the 
amount of HFCs placed on the market by each producer and importer has to be below or 
equal  to  the  quota  allocated  to  the  company  (expressed  in  CO2eq).  Compliance  is 
assessed based on reports provided by the companies on the HFC quantities placed on 
the market for the respective year. 

The  quotas  could  either  be  sold  via  an  auctioning  system  or  distributed  for  free.  The 
auctioning of quotas could have some advantages, as the generation of revenues and a 
high flexibility to react on market developments, also facilitating accessibility for new 
market players. An  auctioning system  would, however, require the development of an 
auctioning  platform,  providing  the  means  of  access  to  the  auctioning  process.  The 
auctioning process would consist of various tasks including the registration of potential 
bidders, providing a platform and IT infrastructure, collecting bids, managing collateral, 
running  the  auction  and  ensuring  payment  and  delivery.  Even  if  the  development  and 
operation of the system would be outsourced, experience with the EU ETS shows that 
the  supervision  of  the  system  would  require  a  level  of  resources  (either  at  Member 
States' or Commission level). Such a system would appear disproportionate to the size 
of the market addressed.   

EN 

164 

   EN 

 
In  addition,  the  structure  of  the  market  of  bulk  HFCs  raises  doubts  about  the 
appropriateness  of  an  auctioning  of  HFC  POM  quotas.  Already  today  the  market  is 
highly  concentrated  in  the  hands  of  very  few  suppliers.  It  can  be  expected  that  their 
market power would diminish the effectiveness of the pricing in the auctioning process 
and hamper the functioning of the market. 

For these reasons the option of an auctioning system was discarded. 

5.2. 

Grandfathering or allocation on demand 

The  allocation  of  quotas  could  either  be  organised  on  the  basis  of  periodical  requests 
declaring the expected, individual demand for a given time span, or by grandfathering 
based upon the past activity level, i.e. the amount of HFCs placed on the EU market by 
a participant during a base period multiplied with a reduction factor in order to meet the 
cap.  
Under  the  previous  regulations  on  ODS85,  the  phase-out  of  these  substances  was 
implemented  through  quotas  for  the  placing  on  the  market  of  ODS  allocated  through 
grandfathering  based  on  historic  market  shares.  In  a  case  where  quotas  for  substances 
intended  for  an  exempted  use  are  subject  to  an  EU-wide  cap,  the  current  ODS 
Regulation  combines  the  grandfathering  approach  with  a  demand-based  allocation 
mechanism.86 For ODS intended for essential laboratory and analytical purposes it was 
deemed  necessary  to  allow  new  entrants  to  benefit  from  this  exemption,  which  is  not 
limited  in  time.  Since  the  HFC  phasedown  does  not  aim  at  a  complete  ban  on  HFCs 
(unlike  the  phase-out  of  ODS  for  other  emissive  uses),  it  is  appropriate  to  follow  the 
same combined approach as for the permanently exempted ODS uses.  

An  allocation  mechanism  which  would  only  be  based  on  a  declaration  of  expected 
demands had been considered, but was discarded due to experiences acquired with the 
ODS quota system. Some companies seem to exaggerate their demand more than others 
and could receive a larger proportion of their real demand for free than others providing 
a more realistic estimate. Whilst declarations at the higher end of the expected demand 
are legitimate to prevent shortages in the upcoming allocation period. But massive over-
declarations have the potential to disrupt the functioning of the allocation mechanism. 
As  long  as  only  a  small  proportion  of  the  market  would  be  concerned  by  this  risk, 
certain  specific  allocation  rules  -  as  the  ones  adopted  under  the  ODS  regime87  -  can 
sufficiently mitigate the risk and ensure an adequate level of fairness of the system. 

The grandfathering allocation scheme should, therefore, be complemented by a demand 
based  allocation  to  new  entrants.  The  necessary  quotas  can  be  reserved  in  a  ‘new 
entrants’ reserve’. In view of the maturity of the market in bulk HFC a share of 5% of 

85 

86 

87 

See  Regulation  (EC)  No  2037/2000  on  substances  that  deplete  the  ozone  layer,  OJ  L  244, 
29.9.2000, p. 1. 
See Article 10 of Regulation (EC) No 1005/2009 on substances that deplete the ozone layer, OJ 
L 286, 31.10.2009, p. 1. 
Commission Regulation (EU) No 537/2011 of 1 June 2011 on the mechanism for the allocation 
of  quantities  of  controlled  substances  allowed  for  laboratory  and  analytical  uses  in  the  Union 
under  Regulation  (EC)  No  1005/2009  on  substances  that  deplete  the  ozone  layer,  OJ  L  147, 
2.6.2011, p. 4. 

EN 

165 

   EN 

 
                                                 
the  historic  baseline  should  be  sufficient  to  satisfy  the  demand  of  new  entrants.  An 
option  could  be  allowing  new  entrant  to  acquire  a  “historic”  baseline  in  future  years 
(e.g. after two full years of operation), which would also reduce the administrative effort 
linked  with  the  recurring  allocation  processes.  The  reduction  factor  used  should  be 
identical to the one for allocation to incumbents.  

If the sum of allocations based on expected demand and reduction factor was to surpass 
the  amount  in  the  reserve,  all  applicants  would  be  entitled  to  an  equal  share  of  the 
reserve. If the reserve is not entirely used, the remaining quota could be distributed to 
eligible companies on a pro-rata basis.   

5.3. 

Determination of the baseline 

For  individual  companies  the  choice  of  the  baseline  for  the  grandfathering  is  an 
important distributional matter. The baseline should be representative for the activities 
of  the  majority  of  the  participants.  Given  that  the  levels  of  activity  of  individual 
companies  may  fluctuate  from  one  year  to  another  due  to  both  internal  and  external 
factors,  the  setting  of  a  baseline  based  on  an  average  of  several  years  is  regarded  as 
fairer.  Reporting  data  is  available  from  2007  onwards,  excluding  the  first  year(s)  (as 
data quality tends to be lower when a reporting requirement is applied for the first time); 
a 3-year period (2009-2011) or a 4-year period (2008-2011) would is a viable option. 

5.4. 

Treatment of exports 

The  treatment  of  exports  in  the  calculation  of  the  baseline  has  to  be  considered 
carefully.  The  cap  is  designed  to  represent  the  demand  on  the  EU  market  only,  so 
exports  are  excluded.  Allocations  could  therefore  exclude  exports  as  well.  Companies 
which  mainly  produce  or  import  for  the  EU  market  will  receive  allocation  for  the 
physical  placing  on  the  domestic  market  only.  If  a  company  is  only  exporting  bulk 
substances the allocation should be zero.   

An  alternative  would  be  to  base  the  allocation  on  the  sum  of  production  and  imports 
without  taking  into  account  the  exports.  In  this  case  exporting  companies  would  be 
favoured above those selling mostly to the inland market, as they receive allocation for 
amounts  that  they  will  export  and  for  which  they  have  no  need  to  hold  a  quota.  As 
exports play a major role in the current F-Gas market, the allocation factor would seem 
rather  low,  because  the  sum  of  imports  and  production  is  by  definition  above  the 
domestic supply. The latter alternative was therefore discarded. 

5.5. 

Implementation and required data  

Entities should be obliged to annually measure and report the quantities of HFCs placed 
on  the  market  and  to  hold  the  corresponding  quotas  for  doing  so.  Annual  reporting 
reduces the risk that participating firms could place more substances on the market than 
they are entitled to. 

The  phasedown  of  placing  HFCs  on  the  EU  market  should  be  facilitated  by  a  central 
database  ensuring  the  accurate  accounting,  issuing,  holding  and  deleting  quotas.  All 
participants in the phasedown (producers and importers) register in the database to open 
an account. The central database may be operated by the European Commission, as the 

EN 

166 

   EN 

 
number  of  players  is  limited  and  an  implementation  at  Member  States  level  is  not 
necessary.  

The following information would be recorded in the database: 

• 

• 

• 

• 

• 

Accounts held by a company or physical person with contact information; 

Allocation of quotas to each participating undertaking; 

Transfers  of  quotas  ("transactions")  performed  between  the  account  holders. 
Payments and contracts for the transactions of allowances between companies 
are settled outside the registry system; 

Annual verified quantities of HFCs placed on the EU market by each account 
holder;  

Compliance  status  in  regard  to  the  last  annual  verification.  If  no  verified 
quantities of HFCs placed on the market are reported by the deadline set, the 
accounts of these undertakings are blocked. 

Part of the information would be available only to the account holder, the Commission 
and  the  competent  authorities  of  the  Member  State  concerned,  but  other  information 
might  be  made  available  to  the  public.  As  the  proposed  phasedown  mechanism  has 
many similarities to the European ODS phase-out mechanism, the ODS database might 
be extended for that purpose. 

The  data  requirements  under  a  grandfathering  system  would  include  the  domestic 
production,  imports  and  exports  of  bulk  substances.  Data  on  production,  purchases, 
sales,  stock  changes,  imports  and  exports  of  bulk  substances  are  currently  reported 
under Commission Regulation (EC) No 1493/200788 for the years 2007 to 2010.  

5.6. 

Transferability of quotas  

If a company ceases its activities, its quota would be lost unless the closing company is 
entitled to transfer its quota to other market participants. Since the phasedown steps are 
calculated on the basis of the necessary supply to sectors for which alternatives to HFCs 
are  not  (fully)  available,  a  reduction  of  the  overall  amount  available  HFCs  should  be 
avoided. The  possibility of quota transfers between active producers or importers also 
offers  the  advantage  of  enabling  market  access  for  new  entrants  and  to  increase  the 
flexibility  for  the  holders  of  quota  to  satisfy  additional  demand  occurring  during  an 
allocation period. 

The  transferability  is  an  important  element  to  compensate  for  the  freeze  of  market 
shares  of  companies  resulting  from  the  chosen  grandfathering  approach  for  the  quota 
allocation. The transferability would create a market value for the quota which should 
reflect the average marginal abatement costs across the sectors. The price signal would 
incentivise  the  reduction  and  substitution  of  the  use  of  F-Gases,  especially  those  with 

88 

Commission  Regulation  No  1493/2007  of  17  December  2007  establishing,  pursuant  to 
Regulation (EC) No 842/2006 of the European Parliament and of the Council, the format for the 
report to be submitted by producers, importers and exporters of certain fluorinated greenhouse 
gass, OJ, 18.12.2007, L332, p. 7. 

EN 

167 

   EN 

 
                                                 
high  GWP.  The  transferability  of  quotas  between  undertakings  would  enable  the 
environmental  objective  of  the  HFC  phasedown  mechanism  to  be  achieved  in  a  more 
cost-effective manner.  

Given the small size of the market and to avoid disproportionate administrative burden, 
the  transfers  should  be  agreed  bilaterally  between  entities  registered  in  the  central 
database. Any transfer should be notified to and be registered in this database.    

5.7. 

Administrative costs for companies 

For the allocation  though grandfathering,  total one-off  costs to industry of  1.7 million 
Euros  are  estimated.  One-off  costs  per  company  would  range  between  approximately 
0.4  and  60  thousand  Euros,  in  average  approximately  20  thousand  Euros.  Other  costs 
are  mainly related  to the  verification procedure, therefore an appropriate  threshold  for 
third party verification should be considered in order to avoid disproportionate burden 
in particular for SMEs. No annual costs would occur for the allocation of quotas, except 
for new entrants before they acquired a 'historic' reference baseline after a certain period 
of activities (e.g. two years).  

6. 

MONITORING, REPORTING AND VERIFICATION 

6.1. 

Reporting 

Reporting  provisions  set  out  by  Article  6  of  the  F-Gas  Regulation  and  Commission 
Regulation  (EC)  No  1493/2007  allow  an  overview  of  the  quantities  of  bulk  F-Gases 
produced, imported and exported to/from the EU market. Reporting obligations apply to 
companies  producing,  importing  or  exporting  F-Gas  quantities  and  preparations  >1 
tonne  and  reports  are  to  be  submitted  annually  to  the  EU  Commission  and  the 
competent  authorities  of  the  Member  State  concerned.  The  current  reporting  scheme 
under the F-Gas Regulation is basically suitable to retrospectively verify the bulk F-Gas 
uantities  placed  on  the  EU  market.  At  present,  F-Gases  contained  in  products  or 
equipment are not covered by the reporting obligation.  

However,  the  reporting  obligations  under  the  current  F-Gas  Regulation  would  require 
some  modifications  in  view  of  the  HFC  phasedown.  The  additional  requirements 
concern the scope of substances and thresholds in terms of metric tonnes or tonnes of 
CO2 equivalents produced, imported, exported, reclaimed or destroyed by stakeholders: 

- 

- 

All  substances  included  in  the  phasedown  regime  need  to  be  integrated  in  the 
reporting  requirements.  As  discussed  before,  a  de  minimis  rule  should  be 
foreseen. For the application of the phasedown mechanism a threshold of 1 000 
t CO2  equivalents  of  HFCs  placed  on  the  market  per  year  is  suggested.  All 
production,  import  or  export  above  that  threshold  should  be  reported.  In 
addition,  in  order  to  enable  an  evaluation  of  the  policy  measures,  any  such 
activity involving more than 1 metric tonne should be reported, regardless of the 
before mentioned threshold of 1 000 t CO2 equivalent. 

The unsaturated HFCs HFC-1234yf and HFC-1234ze are under discussion to be 
included in an amendment to the Montreal Protocol. Both substances are neither 
proposed to be included in the scope of the HFC phasedown nor covered in the 

EN 

168 

   EN 

 
- 

- 

- 

reporting  obligation  under  the  F-Gas  Regulation.    An  inclusion  of  these 
substances in reporting obligations is thus not necessary in order to underpin an 
EU  HFC  phasedown,  but  it  would  be  very  useful  to  track  the  consumption  of 
unsaturated substances for purposes of policy verification and evaluation. Such 
data would also strongly assist in explaining future HFC emission trends in the 
EU.  In  the  case  of  an  amended  Montreal  Protocol  such  a  reporting  obligation 
would  also  become  necessary.  Furthermore,  concerns  on  the  eco  toxicity  of 
breakdown  products  warrant  a  continuous  monitoring  of  the  quantities  of 
unsaturated HFCs.  

An  extension  of  the  reporting  requirement  on  imports  and/or  exports  of  HFCs 
contained in products or equipment – although not covered by the scope of the 
phasedown - would help monitor the effectiveness of the policy. A sufficiently 
high threshold should be foreseen to limit the administrative burden to the very 
high number of importers and exporters of such products or equipment. 

Recovered  HFC  quantities  for  re-use/recycling  or  reclamation  are  not  counted 
within  the  scope  of  the  HFC  phasedown  as  POM  means  by  definition  the 
placement  on  the  market  “for  the  first  time”.  However,  estimated  amounts  of 
reclaimed HFCs were subtracted from the estimated demand of HFCs in order to 
calculate the cap for the overall quota to be placed on the market in a given year. 
Thus reclaimed HFC amounts are available to consumers beyond the POM cap. 
Therefore,  a  proper  monitoring  of  reclaimed  HFC  amounts  is  important  to 
monitor the performance of the phasedown mechanism. 

Reclaimed F-Gases are covered under the present reporting scheme of Art 6 F-
Gas Regulation only for F-Gas producers, importers and exporters. Specialised 
HFC  reclamation  facilities  are  not  yet  covered  and  should  be  included  in  the 
reporting obligation. 

Destruction of F-Gases is covered under the present reporting scheme of Art. 6 
F-Gas  Regulation  only  for  F-Gas  producers, 
importers  and  exporters. 
Specialized  destruction  facilities  are  not  covered.  For  the  purpose  of  the  POM 
phasedown scheme, there is no need to enhance reporting on destruction.  

In the case of an amended Montreal Protocol, full information on the destroyed 
amounts  of  HFCs  might  be  needed  and  such  a  reporting  obligation  including 
specialised  destruction  facilities  might  become  necessary.  However,  according 
to  operators  of  destruction  facilities,  a  reporting  on  destroyed  HFC  species  by 
species  is  not  at  all  feasible:  Destruction  facilities  do  not  perform  analyses  to 
specify the components of these mixtures. According to operators, it is uncertain 
whether  appropriate 
techniques  are  available,  which  would  allow  a 
determination  of  the  specific  HFC  contents  (and  thus  GWPs)  of  the  destroyed 
quantities  are  available.  At  present,  destruction  facilities  report  to  MS  waste-
management  authorities  the  metric  tonnes  of  an  unspecified  mix  of  HFCs, 
HCFCs  and  other  refrigerants,  only.  A  reasonably  exact  determination  of  the 
amount of HFCs destroyed expressed in CO2 equivalents thus appears not to be 
possible. 

EN 

169 

   EN 

 
- 

Direct  exports  by  producers  do  not  count  against  their  quotas,  since  those 
substances are, by definition, not placed on the market. The same should apply 
to quantities which are purchased from a EU producer by an exporter, although 
this  transaction  would  have  to  be  considered  as  placing  on  the  market.  Both 
producer and exporter would have to specify the HFC amounts exported in the 
same allocation period. 

Article 6  of  the  current  F-Gas  Regulation  established  reporting  requirements  for  each 
producer,  importer  and exporter of fluorinated greenhouse gass, as well as destruction 
facilities,  to  the  Commission  and  the  same  information  shall  be  made  available  to  the 
competent authority of the Member State concerned. The same procedure is suggested 
related  to  the  extended  reporting  under  an  HFC  phasedown  mechanism.  The 
Commission  could  also  designate  an  entity  to  collect  the  reported  information.  The 
European  Environment  Agency  (EEA)  could  be  such  an  entity  because  the  EEA  will 
collect,  assess  and  compile  the  submitted  reports  under  the  F-Gas  Regulation  and  the 
ODS Regulation starting from 2012. 

6.2. 

Verification 

For  an  HFC  phasedown  mechanism  it  is  essential  to  verify  that  participating 
undertakings  do  not  place  more  HFCs  on  the  EU  market  than  the  quantity  for  which 
they hold quotas.  

Currently some checks on the reported data under the F-Gas Regulation are performed 
by  the  consultants  who  compile  and  assess  the  reported  data  for  the  Commission. 
However these checks are limited to rather obvious mistakes and do not deliver a clear 
answer  whether  the  reported  data  is  accurate.  Measures  for  effective  implementation 
and enforcement need to allow tracking of the quantities of individual HFC species and 
of HFC species in mixtures of substances on the EU market. 

Especially if quotas are transferable and represent a monetary value to holders, a robust 
verification system should be established to ensure that the reported amounts of HFCs 
placed on the market are accurately reflecting the real amounts placed on the market. 

independent  verification  of 

A  system  of 
the  reports  should  be  envisaged, 
complementing the supervision carried out by the competent authorities of the Member 
States  as  for  other  pieces  of  EU  environmental  legislation.  It  is  assumed  that  reports 
might be verified rather easily by external business accountants, since the verification of 
production,  imports  and  exports  at  company  level  concerns  regular  commercial 
transactions.  

In order to reduce administrative burden, a certain threshold for low volume producers, 
importers  and  exporters  should  be  introduced  below  which  third  party  verification 
would  not  be  demanded.  Administrative  costs  could  be  further  lowered  with  a 
verification  system  that  does  not  require  annual  verification  checks  for  all  companies, 
but  that  checks  the  data  reported  for  some  of  the  companies  each  year.  These  checks 
could include some previous years. Thus each company may only be verified every 3 or 
5 years. Such a system would still provide an incentive to report correctly because the 
likelihood that any fraud is discovered at some point in time would be high. The costs 
for such an independent verification system should be borne by companies. 

EN 

170 

   EN 

 
An  involvement  of  the  customs  authorities  in  the  verification  of  reported  imports  and 
exports had been considered, as practiced under the ODS regulation. However, the trade 
in ODS requires a systematic licensing of each consignment which forms the basis for 
the  checks  carried  out  by  the  customs  authorities.  Unless  required  by  an  international 
agreement under the Montreal Protocol, a licensing system should not be envisaged for 
the HFC in order to reduce the administrative burden for the companies and authorities 
involved.  Furthermore,  the  applicable  customs  codes  do  not  (yet)  distinguish  between 
HFCs  and  other  substances  serving  the  same  purposes.  Based  on  the  current  HS  code 
for HFCs (CN 2903 39), additional end-numbers for different HFC types in bulk would 
need  to  be  established  to  allow  customs  verifying  in  spot  checks  the  HFC  types  and 
quantities shipped across the EU border. 

6.3. 

Compliance and enforcement 

The following areas of infringements of provisions of an HFC phasedown mechanism 
would be particularly relevant for an enforcement and compliance system: 

(1) 

(2) 

The  correct  reporting  of  the  amounts  of  HFCs  placed  on  the  EU  market 
(production, imports, exports, imports in pre-filled equipment); 

The  placement  of  HFCs  on  the  market  by  a  company  shall  not  exceed  the 
quotas available by the same company.  

Member  States  are  obliged  to  ensure  that  Union  policies  are  implemented  and  can 
usually  decide  themselves  on  the  means  of  enforcement.  In  this  respect,  controls  and 
inspections play a crucial role. A legal instrument for a HFC phasedown should foresee 
that  Member  States  shall  lay  down  measures  to  ensure  that  the  provisions  have  been 
implemented and potential consequences applicable to infringements of the provisions 
of a regulation for an HFC phasedown.  

An  infringement  of  reporting  requirements  could  consist  in  a  lack  of  reporting  or  in 
incorrect  reporting.  In  the  annual  reporting  cycle  it  would  be  registered  if  an 
undertaking  does not submit a required annual report. If companies do not submit  the 
required annual reports, Member States are required to take action to ensure compliance 
and sanction breaches of the legislation.  

Incorrect reporting would be detected during the independent verification of the annual 
reports  on  the  amounts  of  HFCs  placed  on  the  EU  market  and  any  excess  of  the 
allocated quotas mainly at EU level. To enable enforcement at Member State level, the 
Commission should inform Member States of any detected problems with the reporting 
or with the accuracy of the reported information as well as of the non-compliances with 
the individual quantitative limits.  

Infringements with the reporting requirements detected by the independent verification 
could simply lead to a correction of the reported quantities if small corrections of errors 
occur. This could be implemented as part of the verification process and the correction 
should be transparently documented in the report of the independent verifiers. For major 
cases of misreporting specific penalties should be established at Member State level.   

EN 

171 

   EN 

 
In  addition  to  sanctions  imposed  by  Member  States  for  companies  exceeding  their 
allocated POM quotas,  a  reduction  of  the  quota for these companies for the following 
year should be foreseen.  

EN 

172 

   EN 

 
ANNEX XI: Schedule for the Introduction of Bans 

Table A_XI-1 

Starting points for bans in policy option E 

Application 

Commercial 
Centralized systems) 

refrigeration 

Industrial refrigeration 

(Stand-alone 

systems,  Condensing  units, 

2020 

Starting year of ban 

Transport refrigeration (Refrigerated trucks and trailers)  

Stationary  AC  (Moveable  systems,  single  split  systems,  multi  split/VRF 
systems, rooftop systems, displacement chillers) 

HFC-23 in fire protection 

Non-medical technical aerosols 

HFC-134a in XPS foam blowing  

SF6 Magnesium die-casting <850 kg/ y and recycling of die casting alloys 

Mandatory destruction of HFC-23 

203089 

2030 

2020 

2015 

2020 

2015 

2015 

2015 

These starting points are based on the calculation of when 100% penetration rates can 
be reached in the different sectors (see Annex XVI). 

89  

Bans are possible earlier for larger industrial systems above a certain capacity. See also Becken 
et al. (2010)4 

EN 

173 

   EN 

 
 
 
 
 
                                                 
ANNEX XII: Analysis of Administrative Costs  

1. 

METHODOLOGY 

In this Annex, a transparent documentation of the estimation of administrative costs for 
the analysed policy options is provided. All administrative costs are to be understood as 
difference costs to policy option A (no policy change). 

follows 

the  EU  Impact  Assessment 
The  employed  methodology  strictly 
guidelines90:  For  each  policy  option,  a  quantitative  estimate  of  changes 
in 
administrative costs and administrative burden that may be incurred by stakeholders 
in implementing that policy option in so far as activities to provide information are 
concerned.  The  definition  of  administrative  costs  refers  to  the  costs  incurred  by 
enterprises,  the  voluntary  sector,  public  authorities  or  citizens  in  meeting  legal 
obligations  to  provide  information  on  their  action  or  production,  either  to  public 
authorities  or  to  private  parties.  The  term  “information”  is  used  in  a  broad  sense, 
covering labelling, reporting, registration, monitoring and assessment needed to provide 
information  as  well  as  the  transfer  of  information  to  public  authorities  and  private 
parties (e.g. trade associations). Any other costs possibly incurred by stakeholders, i.e. 
not  related  to  providing  information,  are  not  regarded  as  administrative  costs. 
Administrative costs are to be understood on top of business-as-usual costs. Business-
as-usual costs are the costs that currently result from the monitoring and reporting under 
the F-gas Regulation which would continue in the absence of new legislation. 

Costs  incurred  by  the  Commission  are  similarly  not  included  in  the  estimates  for 
administrative costs. 

For each policy option, all relevant and additional information requirements were first 
identified.  To  this  end,  the  kind  of  information  requirements/actions  are  defined  as 
within or without the scope of administrative costs needed to be defined in detail. As the 
general concept, a normal functioning of the analysed policy options was assumed. For 
example, eventual judicial proceedings were not considered. As well, all further action 
by  authorities  or  stakeholders  to  first  establish  a  policy  option,  i.e.  drafting  or 
commenting on the final legal or contractual texts, was not considered. 

For  each  identified  information  requirement,  a  concept  was  established  for  how  to 
estimate specific cost per single action and overall costs for the EU-27. Data sources for 
specific costs include questionnaires to/interviews with stakeholders with experience in 
comparable information requirements as well as expert estimates. Specific cost data was 
multiplied with data on the number of affected stakeholders in order to arrive at absolute 
costs.  

According  to  the  guidelines,  costs  are  distinguished  as  one-off  costs  and  annually 
recurring  costs.  Furthermore,  costs  are  differentiated  as  personnel  costs,  equipment 
costs and outsourcing costs. Equipment costs appeared to be not relevant for any of the 
considered  options.  For  the  estimation  of  personnel  costs,  first  working  time  was 

90 

http://ec.europa.eu/governance/impact/commission_guidelines/docs/iag_2009_annex_en.pdf 

EN 

174 

   EN 

 
                                                 
estimated.  In  order  to  arrive  at  costs,  the  working  time  was  multiplied  with  country 
specific  and  job-level  specific  tariffs  for  gross  earnings.  For  activities  assumed  to  be 
relevant  for  the  considered  policy  options,  the  country-specific  tariffs  of  job-level  2 
“professionals”  were  used.  These  were  considered  to  serve  as  a  proxy  for  a  probably 
applicable  mix  of  job-levels  1  (“legislators,  senior  officials  and  managers”),  2 
(“professionals”)  and  3  (“technicians  and  associate  professionals”).  Table  A_XII-1 
contains the used tariff data. 

Table A_XII-1 

Overview of used country-specific tariffs 

Country specific tariffs – job level 2 (“Professionals”) 

€ / h (2006) 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

IE 

38.75 

35.25 

2.24 

20.29 

7.74 

43.15 

45.40 

7.83 

21.00 

23.94 

34.74 

47.02 

7.78 

45.94 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

59.26 

6.06 

41.58 

5.81 

13.21 

35.19 

10.37 

19.32 

5.97 

40.47 

18.75 

5.19 

49.75 

Source: European Commission,, 2011 

In  the  detailed  questionnaires  (see  Annex  XIII)  to  stakeholders  for  creating  data  on 
time/cost efforts, each information requirement was further disaggregated according to 
the guidelines into the following set of activities: 

EN 

175 

   EN 

 
 
 
• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Familiarising with the information obligation 

Training members and employees about the information obligations 

Retrieving relevant information from existing data 

Adjusting existing data 

Producing new data 

Designing information material (e.g. leaflet conception) 

Filling forms and tables (including recordkeeping) 

Holding meetings (internal/external with an auditor, lawyer etc.) 

Inspecting  and  checking  (including  assistance  to  inspection  by  public 
authorities) 

Copying (reproducing reports, producing labels or leaflets) 

Submitting the information to the relevant authority (e.g. sending it to the 
relevant authority) 

Filing the information 

Buying  (IT)  equipment  &  supplies  (e.g. 
specifically used to fulfil information obligations 

labelling  machines) 

to 

• 

Other. 

These  activities  were  reflected  in  the  questionnaire  as  appropriate  for  the  individual 
questions. Not all types of activities were relevant for every question asked. Partly, the 
“other” category was further elaborated in order to adapt it to the specific question. 

In  the  following  sections,  for  each  option  and  each  information  requirement,  the  cost 
estimates and data sources are documented. 

2. 

POLICY OPTION A: NO POLICY CHANGE 

Administrative  costs  are  defined  as  difference  costs  to  the  application  of  present 
policies. Thus, no costs are assumed for this option. 

3. 

POLICY OPTION B: VOLUNTARY AGREEMENTS 

There are already voluntary agreements for fluorinated gases at international, European 
or  Member  State  level.  Therefore  additional  or  enhanced  voluntary  agreements  are 

EN 

176 

   EN 

 
considered  as  a  policy  option  for  reducing  emissions  of  fluorinated  gases  in  the  EU. 
Voluntary agreements considered are identified in chapter 5.2.  

According to the Communication on environmental agreements at Community level91, 
environmental  agreements  or  voluntary  agreements  should  have  quantified  and  staged 
objectives  and  should  include  a  monitoring  and  reporting  system  for  achieving  the 
this  respect,  Option  B  “Voluntary  agreements”  will  cause  an 
objectives.  In 
administrative burden for the participating business sectors in relation to the monitoring, 
reporting and verification of the reduction of F-Gas consumption.  

Given that the concrete sectors and the objectives for voluntary agreements restricting 
the  use  of  F-Gas  in  certain  appliances  would  have  been  agreed  between  the  relevant 
actors, it is assumed that no administrative costs will occur for the following steps: 

• 

• 

Identify the relevant actors in the sector for a voluntary agreement,  

Define  reliable  indicators  to  monitor  compliance  with  objectives  and 
(interim)  targets  including  costs  for  research  information  and  scientific 
and technological background data, and 

• 

Define the objectives of the voluntary agreement and the baseline. 

3.1. 

Overview  of  information  requirements  for  the  option  of  voluntary 
agreements 

Table A_XII-2 gives an overview of information requirements which are necessary for 
voluntary  agreements.  Each  line  taken  into  account  for  the  quantitative  estimation  of 
administrative cost is further explained in the following sections. 

91 

European Commission 2002: Communication from the Commission to the European Parliament, 
the  Council,  the  Economic  and  Social  Committee  and  the  Committee  of  the  Regions  - 
Environmental Agreements at Community  Level Within the Framework of the Action Plan on 
the  Simplification  and  Improvement  of  the  Regulatory  Environment,  COM(2002)  412  final  of 
17.7.2002. 

EN 

177 

   EN 

 
 
                                                 
Table A_XII-2 

Overview of information requirements for voluntary agreements 

Information requirements for voluntary agreements in policy option B 

No. 

Obligation 

Frequency 

Affected stakeholder group 

Type 

No. 

Comment / Approach 

Source of information 

VA01 

Nominate monitoring 
institution & set up 
monitoring system 

VA02  Annual report on HFC use 

VA03 

Independent verification of 
HFC use reports / submission 
to trade association / 
monitoring institution 

Once 

Trade associations 

6 VAs 

The setting-up of VAs is neglected as 
defined not to be part of administrative 
costs. 

Once per 
year 

Operators/producers of 
equipment/ products 

No. of 
companies 
per VA  

Use reporting efforts under F-Gas 
Regulation (PD 18). 

Companies presently 
reporting acc. Art 6 F-
Gas Regulation 

Assumption: 
6 VAs 

Operators/producers of 
equipment/ products 

No. of 
companies 
per VA  

Verification cost per company & year 
equal to verification cost of annual 
reports in phasedown option (PD19). 

Companies presently 
reporting acc. Art 6 F-
Gas Regulation 

VA04  Annual monitoring report 

Once per 
year 

Trade associations/ 
Monitoring institutions 

6 VAs 

Cost per VA: 

Build on experience of existing VAs 

Trade association 
having experience with 
VA, e.g. ESIA. 

VA05 

Check of monitoring reports 

Once per 
year / of 6 
VAs 

COM 

1 

Is neglected as COM efforts are not 
included in administrative costs. 

VA06 

Communication with 
stakeholders 

Once per 
year 

Trade associations/ 
Monitoring institutions 

6 VAs 

Cost per VA/year: 

Trade associations with VA experience 
estimate communication costs 

Trade association 
having experience with 
VA, e.g. ESIA. 

EN 

178 

EN 

 
  
 
 
Information requirements for voluntary agreements in policy option B 

No. 

Obligation 

Frequency 

Affected stakeholder group 

Type 

No. 

Comment / Approach 

Source of information 

VA07 

Communication with 
stakeholders 

Once per 
year / on 6 
VAs 

COM 

1 

Is neglected as COM efforts are not 
included in administrative costs. 

EN 

179 

EN 

 
  
 
3.2. 

Annual report on HFC use 

The information obligation VA02 “Annual report on HFC use” determines the relevant 
costs for operators/producers of equipment/products containing HFC which fall within 
the  scope  of  the  respective  voluntary  agreement.  In  order  to  determine  their 
administrative costs it will be referred to reporting efforts of a company under the F-Gas 
Regulation (Table A_XII-3). 

Table A_XII-3 

Administrative  burden  per  operator/producer:  VA02  -  Annual  report  on 
HFC use 

VA 02 - Annual report on HFC use 

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

Outsourcing  
costs [€] 

Annual 

55 

506 

Source: Öko-Institute estimate 

Table A_XII-4 contains the estimated number of operators and producers falling under 
the scope of the relevant voluntary agreement. 

EN 

180 

   EN 

 
 
 
Table A_XII-4 

Number of affected operators / producers per voluntary agreement: VA02 - 
Annual report on HFC use 

Number of affected operator / producers per voluntary agreement 

Voluntary Agreement 

No. of affected operators/ 
producers 

Source 

Sub-option B-1: Voluntary agreements to 
phase-out HFCs in commercial 
refrigeration 

Sub-option B-2: Voluntary agreement to 
replace HFC-134a in XPS foams 

Sub-option B-3: Voluntary agreement to 
replace HFC-23 in fire protection 

Sub-option B-4: Voluntary agreement for 
destruction of HFC-23 emissions from 
halocarbon production 

Sub-option B-5: Update of voluntary 
agreement with semiconductor industry 
related to PFCs, NF3, HFC-23 and SF6 

Sub-option B-6: Voluntary agreement to 
replace SF6 and NF3 in photovoltaic 
industry 

ca. 20 (industrially 
manufactured stand- alone 
equipment) 

 ca. 16 (large companies) 

ca.1000 (small companies 
for condensing units, 
centralized systems) 

13 

30 

1 

19 

8 

Total amount 

1,107 

Ökoinstitute  estimate 

See Schwarz et.al. 2011.9 

Estimation of total number 
of EU based original 
equipment manufacturers, 
see Schwarz et.al. 20119, p. 
235. 

Schwarz et al 20119, p.175 

19 Manufacturers are 
member of EECA (ESIA) 

See Schwarz et. al. 20119, p. 
233. 

EN 

181 

   EN 

 
 
 
 
 
Table A_XII-5   Distribution of population in MS for EU-27 in %. 

Distribution of population in MS  

[% of EU-27]  

Belgium 

Bulgaria 

Czech Republic 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Italy 

Cyprus 

Latvia  

Lithuania 

2.19 

1.49 

2.09 

1.12 

16.30 

0.26 

0.92 

2.25 

9.21 

12.62 

12.12 

0.22 

0.44 

0.64 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

0.10 

1.99 

0.08 

3.33 

1.67 

7.61 

2.13 

4.27 

0.42 

1.08 

1.08 

1.87 

United Kingdom 

12.50 

EU-27 

100.00% 

Source: www.weltbevölkerung.de, data from June 2011 

As the distribution of affected companies in the EU-27 is not known, a weighted tariff 
based  on  the  distribution  of  population  in  the  EU-27  issued  to  calculate  the  personnel 
costs per company. Using the country specific tariffs for professionals (see Table A_XII-
1) the thus weighted average tariff for the EU-27 is € 35.82 per hour. 

In  Table  A_XII-6  the  administrative  costs  for  producing  annual  reports  on  the  use  of 
HFC are shown. The figures are calculated for a number of 1,107 operators / producers 
affected by voluntary agreements,  55 hours personnel time and € 506 outsourcing costs 
per report / per company (cf. Table A XII-3) and on a weighted tariff for the EU-27 of 
€ 36. 

EN 

182 

   EN 

 
Table A_XII-6  Overall administrative burden for all operators /producers in EU-27: VA 02 - 

Annual report on HFC use 

VA 02 - Annual report on HFC use 

Overall administrative burden for all operator/producer in EU-27 

[Thousand €] Annual 

Personnel costs 

Equipment costs  Outsourcing costs 

Total costs  

2,192 

0 

560 

2,752 

In option B for the obligation VA 02 the overall annual costs to annually report on HFC 
use is estimated to be € 2.75 million. 

3.3. 

Independent  verification  of  HFC  use  reports  /  submission  to  trade 
association / monitoring institution 

According to the information obligation VA03 operators and producers of equipment & 
products will have their annual reports on the use of HFC to be verified by independent 
organisation.  Furthermore,  they  have  to  submit  them  to  the  relevant  trade  association 
and monitoring institution. As the verification cost per company / year is assumed to be 
equal  to  verification  cost  of  annual  reports  in  the  phasedown  option  (Annex  X),  the 
respective specific burden estimated there will be used as a calculation basis. 

Table A_XII-7 

Administrative  burden  per  operator/producer:  VA03 
verification of HFC use reports 

- 

Independent 

VA03 - Independent verification of HFC use reports 

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

Outsourcing  
costs [€] 

annual 

25 

6,183 

Source:  Analysis  of  questionnaires  sent  to  F-Gas  producers  &  importers  (Annex  XIII)  &  Öko-Institute 

estimate 

In Table A_XII-8 the administrative costs for operators and producers of equipment and 
products to verify the annual reports on the use of HFC by independent organisation are 

EN 

183 

   EN 

 
 
 
stated. The figures are calculated on a number of 1,107 operators / producers affected by 
voluntary agreements, 25 hours personnel time and € 6000 outsourcing costs per report / 
per company (cf. Table A_XII-7) and on a weighted tariff for the EU-27 of € 35.82 (as 
calculated for VA02). 

Table A_XII-8 

Overall administrative burden for all operators /producers in EU-27: VA03 
-  Independent  verification  of  HFC    use  reports  /  submission  to  trade 
association / monitoring institution 

VA 03 - Independent verification of HFC use reports / submission to trade association / 
monitoring institution 

Overall administrative burden for all operator/producer in EU-27 

[Thousand €] Annual 

Personnel costs 

Equipment costs  Outsourcing costs 

Total costs  

973 

- 

6,844 

7,818 

In  option  B  for  the  obligation  VA03  the  overall  annual  costs  for  independent 
verification  of  HFC  use  reports,  the  submission  to  trade  association  and  monitoring 
institution is estimated to be € 7.8 million. 

3.4. 

Annual monitoring report to EU 

The  assumption  for  obligation  VA04  “Annual  monitoring  report”  is  that  for  each  VA 
one  industry  association  is  responsible  for  collecting  all  the  reports  prepared  by  the 
associated members and produces an overall report once a year.  

To estimate the costs for VA 04 a questionnaire listing the required action within VA 04 
was sent to 31 associations. Six associations responded not to have any VA within their 
field of experience. Four industry associations reported administrative costs for a VA; 
no information was received by the other associations.  

Figures  shown  in  Table  A_XII-9  are  the  resulting  average  hours  necessary  for  an 
industry association to prepare an annual monitoring report for the Commission. 

EN 

184 

   EN 

 
 
Table A_XII-9 

Administrative burden per association: VA 04 – Annual monitoring report 

VA04 - Annual monitoring report to EU  

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

68 

annual 

- 

Outsourcing  
costs [€] 

3,500 

Source: Analysis of questionnaires sent to trade associations 

Due to the low response no outliers were identified. 

In Table A_XII-10 for each possible voluntary agreement within the policy option B the 
affected  European  Industry  Association(s)  and  the  number  of  associated  national 
member associations or associated companies is given. 

EN 

185 

   EN 

 
Table A_XII-10 

Industry Associations affected by Voluntary Agreements 

Industry Associations affected by Voluntary Agreements 

Voluntary Agreement 

Affected Association 

No. of associated 
Members/Companies 

Sub-option B-1: 
Voluntary agreements to 
phase-out HFCs in 
commercial refrigeration 

ASERCOM (Association 
of European Refrigeration 
Component Manufacturers)

EXIBA (European 
Extruded Polystyrene 
Insulation Board 
Association) 

Sub-option B-2: 
Voluntary agreement to 
replace HFC-134a in XPS 
foams 

ISOPA (European 
Diisocyanate & Polyol 
Producer Association) 

PU Europe (Polyurethane 
(PUR/PIR) Insulation 
Industry) 

EUROFEU (The European 
Committee of the 
Manufacturers of Fire 
Protection Equipment and 
Fire Fighting Vehicles) 

EFCTC (Association of 
fluorocarbon producers) 

European Semiconductor 
Industry Association 
(EECA)(ESIA) 

Sub-option B-3: 
Voluntary agreement to 
replace HFC-23 in fire 
protection 

Sub-option B-4: 
Voluntary agreement for 
destruction of HFC-23 
emissions from 
halocarbon production 

Sub-option B-5: Update 
of voluntary agreement 
with semiconductor 
industry related to PFCs, 
NF3, HFC-23 and SF6 

16 

9 

8 

11 

18 

192 

19 

92 

So  far  only  one  facility  for  destruction  of  HFC-23  emissions  from  halocarbon  production  in 
Europe exists. Therefore the administrative costs for a voluntary agreement are negligible. 

EN 

186 

   EN 

 
 
 
 
 
 
                                                 
Industry Associations affected by Voluntary Agreements 

Voluntary Agreement 

Affected Association 

No. of associated 
Members/Companies 

Sub-option B-6: 
Voluntary agreement to 
replace SF6 and NF3 in 
photovoltaic industry. 

EPIA (European 
Photovoltaic Industry 
Association) 

240 

Based  on  a  number  of  8  European  industry  associations  who  would  be  engaged  in  6 
voluntary  agreements  the  overall  annual  costs  for  producing  an  annual  monitoring 
report  are  estimated  in  Table  A_XII-11.  As  the  European  industry  associations  are 
generally located in Brussels (Belgium) the weighted tariff for professionals of € 35.25 
per hour for Belgium is used. 

Table A_XII-11  Overall administrative costs for European industry associations affected by 

Voluntary Agreements 

VA04 - Annual monitoring report to EU  

Overall administrative cost in EU 27 

Personnel 
costs 

Equipment 
costs 

Outsourcing 
costs 

Total cost 

[Thousand €] annual 

19.1 

- 

28.0 

47.1 

In  option  B  for  the  obligation  VA04  the  overall  annual  costs  for  producing  an  annual 
monitoring report are estimated at approximately € 47,000. 

3.5. 

Communication with stakeholders 

The obligation VA06 within a voluntary agreement addresses the administrative efforts 
per  year  of  a  European  industry  association  to  communicate  with  other  stakeholders 
(Member States, industry, NGOs, etc.) concerning the voluntary agreement.  

The  administrative  effort  is  based  on  the  figures  received  from  questionnaires  sent  to 
industry associations which are having experiences with voluntary agreements.  

Table A_XII-12 states that the average time needed per European industry association to 
communicate with stakeholders is 139 hours. 

EN 

187 

   EN 

 
 
 
Table A_XII-12  Administrative  burden  per  association:  VA06  –  Communication  with 

stakeholders  

VA06 – Communication with stakeholders  

Administrative burden per entity 

Time [hours] 

Equipment costs [€]  Outsourcing costs [€] 

139 

annual 

4,563 

- 

Source: Analysis of questionnaires to industry associations experienced with VAs in the field of F-Gases 

Based  on  a  number  of  8  European  industry  associations  who  would  be  engaged  in  6 
voluntary agreements, the overall annual costs to produce an annual monitoring report 
are  estimated  in  Table  A_XII-13.  As  the  European  industry  associations  are  generally 
located in Brussels (Belgium) the weighted tariff for professionals of € 35.25 per hour 
for Belgium is used. 

Table A_XII-13  Overall administrative costs for European industry associations affected to 

communicate with stakeholders – VA06 

VA06 - Communication with stakeholders  

Overall administrative cost in EU 27 

Personnel 
costs 

Equipment 
costs 

Outsourcing 
costs 

Total cost 

[Thousand €] annual 

39.2 

36.5 

- 

75.7 

In  option  B  for  the  obligation  VA06  the  overall  annual  costs  to  communicate  with 
stakeholders are estimated to be approximately 76,000 Euros. 

EN 

188 

   EN 

 
3.6. 

Summary of administrative costs of voluntary agreements 

The  estimation  of  the  overall  annual  administrative  costs  in  the  EU-27  for  the  policy 
option B “Voluntary Agreements” is stated in Table A_XII-14. 

Table A_XII-14  Overall  annual  administrative  costs  in  the  EU-27  for  the  policy  option  B, 

Voluntary Agreements 

Summary administrative cost phase-down (annual)
Overall administrative cost in EU 27

Information requirement

Personnel 
cost

VA04

VA03

VA02 Annual report on HFC use
Independent verification of 
HFC use reports
Annual monitoring report to 
EU 
Communication with 
stakeholders 
Total annual

VA06

2,196

973

19

39

3,228

Outsourcing 
Equipment 
Cost
cost
[Thousand €] annual
- 

560

Total Cost

2,756

7,818

47

76

6,844

28

- 

7,432

10,697

- 

- 

37

37

Approximately  73%  of  the  estimated  annual  costs  of  10.7  million  €/year  is  due  to 
independent verification of reported HFC use. 

EN 

189 

   EN 

 
 
 
4. 

POLICY OPTION C: EXTENDED SCOPE OF CONTAINMENT MEASURES  

For this policy option, no administrative costs were assumed. 

5. 

POLICY OPTION D: ESTABLISHMENT OF QUANTITATIVE LIMITS FOR PLACING 
CERTAIN F-GASES (HFCS) ON THE EU MARKET (PHASEDOWN) 

5.1. 

Overview of information requirements for the phasedown option 

Table  A_XII-15  gives  an  overview  of  information  requirements  occurring  in  the 
phasedown  option.  Each  line  taken  into  account  for  the  quantitative  estimation  of 
administrative  costs  is  further  explained  in  the  following  sections.  Table  A_XII-16 
contains a shortlist of those information requirements quantitatively assessed. 

For the present assessment of administrative cost, any administrative efforts related to 
the  complementary  measures  on  pre-charged  equipment  have  not  be  assessed.  Such 
efforts would occur for Member States and would not be identical to the efforts assessed 
for policy option E (bans) as a different set of stakeholders would need to be controlled. 

EN 

190 

   EN 

 
 
 
Table A_XII-15  

Overview of information requirements in the phasedown option 

Overview of information requirements in the policy option on quantitative limits  
for placing on the market of HFCs (phasedown) 

No 

Information requirement 

Frequency 

Affected stakeholders 

Group 

No 

Comment / Approach 

Source of 
information 

PD01 

Set-up of F-Gas data base 

Once 

COM 

PD02 

Operation of F-Gas data 
base 

Permanent 

COM 

PD03 

Registration in F-Gas data 
base 

Once 

Producers & importers above 
CO2eq threshold  

PD04 

Submission of verified 
baseline report 

PD05 

Verification of baseline 
report 

Once 

Once 

Producers & importers above 
CO2eq threshold 

Producers & importers above 
CO2eq threshold 

PD06 

Check of verified baseline 
report + allocation decision 

Once 

COM 

PD07 

Transfer of baselines 

Once 

Producers & importers above 
CO2eq threshold (mainly in the 
case of mergers & acquisitions)  

1 

1 

80 

80 

80 

1 

10 

COM efforts are not to be included in 
Impact Assessment. 

COM efforts are not to be included in 
Impact Assessment. 

Experience of ODS actors, cost per 
company 

ODS 
companies 

Only transfer of information as data is 
available from the reports under the F-
Gas regulation 

Own estimate 

Cost per year taken from annual report 
verification cost PD19 below 

PD19 

COM efforts are not to be included in 
Impact Assessment. 

Not regarded as information 
requirement. Flexibility option offering 
a business opportunity. 

EN 

191 

EN 

 
  
 
 
 
 
Overview of information requirements in the policy option on quantitative limits  
for placing on the market of HFCs (phasedown) 

No 

Information requirement 

Frequency 

Affected stakeholders 

Group 

No 

Comment / Approach 

Source of 
information 

PD08 

Adjustment of baselines for 
allocation reflecting baseline 
transfers (mergers & 
acquisitions) 

Yearly, cases 
depend on 
mergers & 
acquisitions 

PD09 

Allocation to new entrants + 
check of verified reports of 
future HFC use 

4 times a year, 
cases depend 
on the number 
of new 
entrants 

COM 

COM 

PD10 

Set up of auctioning 
platform 

Once 

COM 

PD11 

Auction of rights to POMs 

Regular (6 
times per year) 

COM 

1 

1 

1 

1 

COM efforts are not to be included in 
Impact Assessment. 

COM efforts are not to be included in 
Impact Assessment. 

Not considered for chosen phasedown 
option - relevant for auctioning system 
only. 

COM efforts are not to be included in 
Impact Assessment. 

Not considered for chosen phasedown 
option - relevant for auctioning system 
only. 

COM efforts are not to be included in 
Impact Assessment. 

PD12 

Auction of rights to POMs 

Regular (6 
times per 

Producers  &  importers  above  80 

Not considered for chosen phasedown 
option - relevant for auctioning system 

Own estimate 

EN 

192 

EN 

 
  
 
 
 
 
Overview of information requirements in the policy option on quantitative limits  
for placing on the market of HFCs (phasedown) 

No 

Information requirement 

Frequency 

year), entities 
participating 3 
times only  

5x times per 
year per 
participating 
entity = 400 

PD13 

Transfer of rights to POMs 

Affected stakeholders 

Group 

No 

Comment / Approach 

Source of 
information 

CO2eq threshold 

only. 

Producers  &  importers  above 
CO2eq threshold 

80 

Cost per company & auction: Only 
conservative estimate of time 
technically needed to place the bids. 
Business strategy not to be included! 

Not regarded as information 
requirement. Rather a/ business 
opportunity 

Cost per transfer: Only conservative 
estimate of time technically needed to 
place the bids. Business strategy not to 
be included! 

Own estimate 

PD14 

Definition of eligibility 
criteria for verifiers 

Once 

MS  

27 MS 

Not counted as administrative costs: 
Part of legislative procedure 

PD15 

Deleted 

PD16 

Definition of eligibility 
criteria for verifiers 

Once 

COM 

1 

Not counted as admin costs: Part of 
legislative procedure.  

Same cost as for one MS. 

COM efforts are not to be included in 

EN 

193 

EN 

 
  
 
 
Overview of information requirements in the policy option on quantitative limits  
for placing on the market of HFCs (phasedown) 

No 

Information requirement 

Frequency 

Affected stakeholders 

Group 

No 

Comment / Approach 

Source of 
information 

Impact Assessment. 

PD17 

Deleted 

PD18 

Report (Art 6) on placing on 
the market, import & 
export+ reclamation, 
recycling & destruction  

PD18b 

Additional reporting on 
exports on behalf of 
producers 

Once per year 

Producers, importers & exports 
above one tonne. 

100 

Baseline: Not to be counted as 
administrative cost, obligation of 
existing F-Gas regulation 

Once per year 

Selected producers& exporters 

~15 

Companies 
presently 
reporting 
under Art 6 F-
Gas 
Regulation 

Companies 
presently 
reporting 
under Art 6 F-
Gas 
Regulation 

Not regarded as information 
requirement. Flexibility option offering 
a business opportunity. 

Concerns only HFC reports, no HFO 
reports 

Data source: estimates by Companies 
presently reporting und Art 6 F-Gas 
Regulation; reduction to 30% due to 
assumed higher threshold for 
verification needs 

Not regarded as information 
requirement. Flexibility option offering 
a business opportunity. 

PD19 

Verification of reporting & 
submission to MS or central 
authority 

Once per year 

Producers & importers above 
CO2eq threshold + exporters 
wishing to benefit 

30 

PD19b 

Verification for additional 
reporting on exports on 
behalf of producers 

Once per year 

Selected exporters 

~10 

EN 

194 

EN 

 
  
 
 
Overview of information requirements in the policy option on quantitative limits  
for placing on the market of HFCs (phasedown) 

No 

Information requirement 

Frequency 

Affected stakeholders 

Group 

No 

Comment / Approach 

Source of 
information 

PD20 

Deleted 

PD21 

Deleted 

PD22 

Deleted 

PD23 

Introduce compliance 
system at MS level 

Once 

MS 

PD24 

Check of compliance  

Once per year  COM 

PD25 

Impose penalties in case of 
non-compliance 

Once per year  MS 

PD26 

Deleted 

PD27 

Deleted 

PD28 

Deleted 

27 

1 

27 

No relevant additional effort compared 
to present F-Gas Regulation 
considered. 

MS are informed by COM on 
compliance issues. 

COM efforts are not to be included in 
Impact Assessment. 

Not counted for admin costs: 
Assumption: companies comply  

PD29 

Deduct non-compliance 

Once per year  COM 

1 

Negligible! 

EN 

195 

EN 

 
  
 
 
 
 
Overview of information requirements in the policy option on quantitative limits  
for placing on the market of HFCs (phasedown) 

No 

Information requirement 

Frequency 

Affected stakeholders 

Group 

No 

Comment / Approach 

Source of 
information 

amounts from next 
allocation to non-compliant 
actor 

PD30 

Reporting on reclamation 
and destruction 

Once per year 

Specialised reclamation and 
destruction facilities 

65 

COM efforts are not to be included in 
Impact Assessment. 

Let facilities estimate cost for HFC / 
blend-specific reporting 

Not necessarily needed for the 
phasedown. However, advisable. 
Necessary in case of amended 
Montreal Protocol. 

Specialised 
reclamation 
facilities 

EN 

196 

EN 

 
  
 
Table A_XII-16  Shortlist of information requirements quantitatively assessed for administrative costs in the phasedown option 

Shortlist on quantitatively assessed administrative costs  
in the policy option on quantitative limits for placing on the market of HFCs (phasedown) 

No 

Obligation 

frequency 

Affected stakeholders 

Group 

PD03 

Registration in F-Gas data 
base 

PD04 

Submission of verified 
baseline report 

PD05 

Verification of baseline 
report 

once 

once 

once 

Producers & importers above 
CO2eq threshold  

Producers & importers above 
CO2eq threshold 

Producers & importers above 
CO2eq threshold 

PD19 

Verification of reporting & 
submission to MS or central 
authority 

Once per year 

Producers & importers above 
CO2eq threshold + exporters 
wishing to benefit 

PD30 

Reporting on reclamation 
and destruction  

Once per year 

Specialised reclamation and 
destruction facilities 

No. 

80 

80 

80 

30 

65 

Comment / Approach 

Source of 
information 

Experience of ODS actors, cost per 
company 

ODS 
companies 

Only transfer of information as data 
is available from the reports under 
the F-Gas regulation 

Own estimate 

Cost per year taken from annual 
report verification cost PD19 below 

PD19 

Concerns only HFC reports, no HFO 
reports 

Data source: estimates by Companies 
presently reporting und Art 6 F-Gas 
Regulation; reduction to 30% due to 
assumed higher threshold for 
verification needs 

Let facilities estimate cost for HFC / 
blend-specific reporting 

Not necessarily needed for the 
phasedown. However, advisable. 

Companies 
presently 
reporting  under 
Art  6  F-Gas 
Regulation 

Specialised 
reclamation 
facilities 

EN 

197 

EN 

 
  
Shortlist on quantitatively assessed administrative costs  
in the policy option on quantitative limits for placing on the market of HFCs (phasedown) 

No 

Obligation 

frequency 

Affected stakeholders 

Group 

No. 

Comment / Approach 

Source of 
information 

Necessary in case of amended 
Montreal Protocol. 

EN 

198 

EN 

 
  
 
5.2. 

PD03 - Registration in F-Gas database 

All  stakeholders  intending  to  place  HFCs  on  the  markets  above  a  threshold  of 
1 kt CO2eq need to register in a database operated by the European Commission. This is 
a one-off cost. 

The  effort  is  estimated  to  be  comparable  to  the  registration  to  the  Commission’s 
database  on  production,  import  and  export  of  ozone  depleting  substances  (ODS)93. 
Thus,  companies  currently  involved  in  the  ODS  phase-out  scheme  were  addressed  to 
gather information on specific costs. 

The number of affected entities is estimated at 80, based on experiences with the present 
reporting  under  the  F-Gas  Regulation  (Art  6).  This  is  a  conservative  estimate  as  the 
number includes entities which presently exclusively deal with PFCs and SF6 and thus 
would not be affected by the HFC phasedown scheme. 

Information  on  the  distribution  of  entities  to  Member  States  is  available,  as  well  as 
based on experience with the present reporting under the F-Gas Regulation (Art 6). As 
this data includes exporters, the percentage per country is used as a proxy (Table A_XII-
17). 

93 

http://ec.europa.eu/clima/policies/ozone/ods/index_en.htm 

EN 

199 

   EN 

 
                                                 
Table A_XII-17  Distribution  of  entities  placing  HFCs  on  the  EU  market  between  Member 

States 

Distribution of entities placing HFCs on the EU market between MS 

[% of EU-27] 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

IE 

- 

7.5% 

3.7% 

1.9% 

1.9% 

11.2% 

0.9% 

2.8% 

2.8% 

8.4% 

1.9% 

7.5% 

3.7% 

1.9% 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

EU-27 

10.3% 

- 

3.7% 

- 

1.9% 

3.7% 

4.7% 

1.9% 

1.9% 

2.8% 

1.9% 

- 

11.2% 

100.0% 

Source: European Commission 2011: Confidential Report on F-Gases 2010 

The  distribution  between  Member  States  in  combination  with  the  country-specific 
tariffs as shown in Table A_XII-1 leads to a weighted average tariff of 32.55 €/h. 

Table  A_XII-18  shows  the  evaluation  of  the  questionnaires.  Three  answers  were 
received.  Thus,  no  outliers  could  be  identified.  Estimates  for  equipment  cost  and 
outsourcing  costs  were  summarised  as  outsourcing  costs.  Figures  shown  are  the 
resulting averages. 

EN 

200 

   EN 

 
Table A_XII-18  Administrative burden per entity: PD 03 - Registration in F-Gas data base 

PD03 - Registration in database 

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

Outsourcing  
costs [€] 

once (one-off) 

68    

155 

Source: Analysis of questionnaires sent to ODS stakeholders 

Table  A_XII-19  shows  the  resulting  overall  cost  (one-off)  in  the  EU-27  taking  into 
account administrative burden per entity, the weighted tariff per hour, and the number 
of affected entities. 

Table A_XII-19  Overall  administrative  costs  for  EU-27:  PD03  -  Registration  in  F-Gas 

database 

PD03 - Registration in database 

Overall administrative cost in EU-27 

Personnel 
costs 

Equipment 
Costs 

Outsourcing 
costs 

Total Cost 

[Thousand €] once (one-off) 

177.1  

0.0 

12.4 

189.5  

EN 

201 

   EN 

 
 
 
5.3. 

PD04 - Submission of verified baseline report 

As the basis for the allocation of rights to POMs in the analysed grandfathering system, 
undertakings  intending  to  place  HFCs  on  the  market  need  to  submit  a  baseline  report 
covering their respective activities in the base period. The necessary data are assumed to 
be easily available to the undertakings, as these data had to be reported in previous years 
according  to  Art  6  of  the  F-Gas  Regulation.  Concerning  the  specific  administrative 
burden  per  company,  a  conservative  estimate  of  two  person-days  (16  hours)  is  made. 
Time  needed  would  concern  gathering,  combination,  internal  checks  of  the  data,  the 
filling  of  tables  and  submission  of  the  report.  Efforts  for  the  verification  of  the  report 
are estimated separately below in 5.4 (PD05 – Verfication of baseline report).  

Table A_XII-20  Administrative  burden  per  entity:  PD04  -  Submission  of  verified  baseline 

report 

PD 04 - Submission of verified baseline report 

Administrative burden per entity 

Once (one-off) 

Time [hours] 

Equipment costs [€] 

Outsourcing costs [€] 

16 

- 

- 

This  requirement  would  apply  to  the  same  set  of  involved  stakeholders  as  in  PD03 
above (chapter 5.2), i.e. undertakings that place HFCs on the market above a threshold 
of 1 kt CO2eq. Thus, the same estimated number of affected entities in the EU-27 (80 
undertakings) and the same EU-wide weighted tariff of 32.55 €/h is used here in order 
to calculate overall cost for EU-27, as well.  

Table  A_XII-21  shows  the  resulting  overall  costs  (one-off)  in  the  EU-27  taking  into 
account administrative burden per entity, the weighted tariff per hour, and the number 
of affected entities. 

EN 

202 

   EN 

 
Table A_XII-21  Overall  administrative  costs  for  EU-27:  PD04  -  Submission  of  verified 

baseline report 

PD04 - Submission of verified baseline report 

Overall administrative cost in EU-27 

Personnel 
costs 

Equipment 
Costs 

Outsourcing 
costs 

Total Cost 

[Thousand €] once (one-off) 

41.7  

0.0 

0.0 

41.7  

5.4. 

PD05 - Verification of baseline report 

Baseline reports for the allocation of quotas in a grandfathering system (as described in 
chapter 5.3 above) need to be verified. The estimate for the specific burden for reporting 
companies  are  based  on  estimates  which  were  collected  among  F-Gas  reporting 
companies  regarding  the  additional  external  verification  of  an  annual  report  on 
production,  import  and  export  (as  presently  required  under  the  F-Gas  Regulation). 
Those  specific  costs  are  multiplied  by  three  in  order  to  take  into  account  that  the 
baseline report would cover not one single year but a series of three years. 

Table A_XII-22  Administrative burden per entity: PD05 - Verification of baseline report 

PD05 - Verification of baseline report 

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

Outsourcing  
costs [€] 

once (one-off) 

74 

0

18 000 

This  requirement  would  apply  to  the  same  set  of  stakeholders  involved  in  PD03  – 
Registration in  F-Gas database (chapter 5.2),  i.e. undertakings that  place HFCs on the 
market above a threshold of 1 kt CO2-eq. Thus, the same estimated number of affected 
entities in the EU-27 (80 undertakings) and the same EU-wide weighted tariff of 32.55 
€/h is used here in order to calculate the overall costs for EU-27 as well.  

EN 

203 

   EN 

 
 
 
Table  A_XII-23  shows  the  resulting  overall  costs  (one-off)  in  the  EU-27  taking  into 
account administrative burden per entity, the weighted tariff per hour, and the number 
of affected entities. 

Table A_XII-23  Overall  administrative  costs  for  EU-27:  PD  05  -  Verification  of  baseline 

report 

PD05 - Verification of baseline report 

Overall administrative cost in EU-27 

Personnel 
costs 

Equipment 
Costs 

Outsourcing 
costs 

Total Cost 

[Thousand €] once (one-off) 

192  

- 

1 440 

1,632  

5.5. 

PD18  -  Report  (Art.  6)  on  placing  on  the  market,  import  &  export, 
reclamation, recycling & destruction 

The administrative effort of undertakings presently reporting according to Art 6 of the 
F-Gas regulation is not to be considered as administrative costs within the phasedown 
policy option. However, reporting undertakings were asked to estimate their respective 
efforts  in  order  to  be  able  to  estimate  potentially  more  precisely  the  implications  of  a 
change of scope of the reporting obligation. 

Table A_XII-24 shows the evaluation of the questionnaires. 24 answers were received. 
Seven  outliers  could  be  identified  and  discarded  from  the  analysis.  Estimates  for 
equipment  cost  and  outsourcing  costs  were  summarised  as  outsourcing  costs:  Partly, 
undertakings use external consultants to help prepare their reporting. Few undertakings 
report  one-off  equipment  costs  for  IT.  In  order  to  estimate  annual  costs  for  this 
assessment, 20% of the average equipment costs were interpreted as annual outsourcing 
costs. Figures shown in Table A_XII-24 are the resulting averages. 

EN 

204 

   EN 

 
 
Table A_XII-24  Administrative  burden  per  entity:  PD18  -  Reporting  acc.  Art  6  F-Gas 

Regulation 

PD18 - Reporting acc. Art 6 F-Gas Regulation 

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

Outsourcing  
costs [€] 

annual 

55    

506 

Source: Analysis of questionnaires sent to F-Gas producers & importers 

This  requirement  applies  to  the  same  set  of  involved  stakeholders  as  in  PD03  – 
Registration  in F-Gas  database (chapter 5.2),  i.e. undertakings that  place HFCs on the 
market.  Thus,  the  same  estimated  number  of  affected  entities  in  the  EU-27  (80 
undertakings) and the same EU-wide weighted tariff of 32.55 €/h is used here in order 
to calculate the overall costs for EU-27 as well.  

Table  A_XII-25  shows  the  resulting  overall  costs  (annual)  in  the  EU-27  taking  into 
account administrative burden per entity, the weighted tariff per hour, and the number 
of affected entities. 

Table A_XII-25  Overall administrative costs for EU-27: PD 18 - Reporting according to Art 

6 F-Gas Regulation 

PD18 - Reporting acc. Art 6 F-Gas Regulation 

Overall administrative cost in EU-27 

Personnel 
costs 

Equipment 
Costs 

Outsourcing 
costs 

Total Cost 

[Thousand €] annual 

144.2  

0.0 

40.5 

184.7  

EN 

205 

   EN 

 
5.6. 

PD  19  –  Verification  of  Reporting  &  submission  to  MS  or  central 
authority 

The annual reporting by undertakings needs to be verified. Thus, reporting undertakings 
were  asked  to  estimate  the  costs  of  a  verification  of  an  annual  report  by  an  external 
business accountant. 

Table A_XII-26 shows the evaluation of the questionnaires. 15 answers were received. 
Two  outliers  could  be  identified  and  discarded  from  the  analysis.  Estimates  for 
equipment costs and outsourcing costs were summarised as outsourcing costs: Figures 
shown in Table A_XII-26 are the resulting averages. 

Table A_XII-26  Administrative burden per entity: PD 19 - Verification of Reporting acc. Art 

6 F-Gas Regulation 

PD19 - Verification of Reporting acc. Art 6 F-Gas Regulation 

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

Outsourcing  
costs [€] 

annual 

25    

6 183  

Source: Analysis of questionnaires sent to F-Gas producers & importers (Annex XIII) 

This requirement would in principle apply to the same set of involved stakeholders as in 
chapter 5.2 (PD 03 – Registration in F-Gas database), i.e. undertakings that place HFCs 
on  the  market.  However,  due  to  the  assumption  of  a  higher  threshold  for  verification 
needs, the number of affected entities in the EU-27 is estimated as 30 undertakings. The 
same  EU-wide  weighted  tariff  of  32.55  €/h  as  for  PD  03  is  used  here  in  order  to 
calculate the overall costs for the EU-27 as well.  

Table  A_XII-27  shows  the  resulting  overall  costs  (annual)  in  the  EU-27  taking  into 
account administrative burden per entity, the weighted tariff per hour, and the number 
of affected entities. 

EN 

206 

   EN 

 
Table A_XII-27  Overall  administrative  costs  for  EU-27:  PD  19  -  Verification  of  Reporting 

acc. Art 6 F-Gas Regulation 

PD19 - Verification of Reporting acc. Art 6 F-Gas 
Regulation 

Overall administrative cost in EU 27 

Personnel 
costs 

Equipment 
Costs 

Outsourcing 
costs 

Total Cost 

[Thousand €] annual 

24.0 

- 

185.5 

209.5 

5.7. 

PD 30 – Reporting on reclamation and destruction 

In order to improve monitoring and data availability, an obligation for reclamation and 
destruction  facilities  to  report  reclaimed  and  destroyed  F-Gas  quantities  should  be 
introduced.  Table  A_XII-28  gives  an  overview  of  specialised  reclamation  and 
destruction facilities in EU-27.  

EN 

207 

   EN 

 
 
 
Table A_XII-28  Number of reclamation and destruction facilities in the EU-27 

Number of reclamation facilities  

Number of destruction facilities 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

0 

3 

2 

0 

5 

3 

0 

0 

1a 

4 

0 

5 

3 

0 

3 

1a 

0 

0 

0 

3 

1 

0 

1 

1 

0 

0 

5 

Total 

41  

a License since March 2010 (Greece) and June 2010 (Lithuania)  

0 

1 

0 

0 

1 

5b 

2 

0 

0 

0 

1 

3 

2 

0 

3 

0 

0 

0 

0 

0 

1 

0 

1 

2  

0 

0 

2 

24  

b One company with 4 facilities referred to as 1 facility (only 1 out of the 4 facilities is operating). 

Source: Schwarz et al. (2011)9 

EN 

208 

   EN 

 
 
 
For  destruction,  quantities  are  already  monitored  and  reported  to  authorities  under  the 
waste  legislation  and  thus  are  readily  available  in  most  cases.  The  data  submitted, 
however, cannot be specified for particular HFC types or types of blends since mixtures 
of different HFCs, HCFCs and other refrigerants are usually delivered for destruction. 
Destruction  facilities  do  not  perform  analyses  to  specify  the  components  of  these 
mixtures.  According  to  operators,  it  is  uncertain  whether  appropriate  techniques  are 
available,  which  would  allow  a  determination  of  the  specific  HFC  contents  (and  thus 
GWPs) of the destroyed quantities are available. Therefore, it remains unknown to date 
whether  the  data  available  are  sufficiently  specific  for  monitoring  purposes  under  the 
phasedown  option,  even  more  in  the  case  of  monitoring  requirements  for  an  amended 
Montreal Protocol. 

Reclamation is carried out by few entities, notably gas distributors already reporting to 
authorities under the F-Gas Regulation. Reclaimed quantities are very low so far, since 
the technical process is complex and costly.  

Questionnaires  on  the  administrative  effort  required  for  reporting  of  F-Gases  by 
reclamation  and  destruction  facilities  have  been  sent  out  but  few  responses  have  been 
received  to  date.  Therefore,  expert  interviews  were  undertaken  via  telephone,  but 
estimates of the administrative burden are preliminary at this stage.  

Based on the assumption that data on reclaimed HFCs quantities (specific by HFCs) and 
on  destroyed  refrigerant  mixes  (including  HFCs)  are  readily  available  within  the 
undertakings,  the  additional  effort  for  reporting  to  the  Commission  is  conservatively 
estimated at one person-day (eight hours). 

Table A_XII-29  Administrative  burden  per  entity:  PD  30  –  Reporting  of  F-Gases  by 

reclamation/ destruction facilities not yet covered by reporting obligations 

PD 30 – Reporting of F-Gases by reclamation/ destruction facilities 

Administrative burden per entity 

Annual 

Time [hours] 

Equipment costs [€] 

Outsourcing costs [€] 

8 

0 

0 

In order to estimate a weighted average for tariffs, for each Member State, the number 
of destruction and reclamation facilities as shown in Table A_XII-28 is divided by the 
EU-27 total. The result is given in Table A_XII-30. 

EN 

209 

   EN 

 
 
Table A_XII-30  Distribution  of  EU-27  destruction  and  reclamation  facilities  between 

Member States 

Distribution of EU-27 destruction and reclamation facilities between MS 

[% of EU-27] 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

IE 

- 

6.2% 

3.1% 

- 

9.2% 

12.3% 

3.1% 

- 

1.5% 

6.2% 

1.5% 

12.3% 

7.7% 

- 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

EU-27 

9.2% 

1.5% 

- 

- 

- 

4.6% 

3.1% 

- 

3.1% 

4.6% 

- 

- 

10.8% 

100.0% 

Source: Calculated from Schwarz et al. (2011)9 

The number of affected facilities is 65 (Table A_XII-28). The multiplication of Member 
State-specific  tariffs  (Table  A_XII-1)  by  the  distribution  to  Member  States  leads  to  a 
weighted EU-27 average tariff of 33.29 €/h. 

Table  A_XII-31  shows  the  resulting  overall  costs  (annual)  in  the  EU-27  taking  into 
account administrative burden per entity, the weighted tariff per hour, and the number 
of affected entities. 

EN 

210 

   EN 

 
Table A_XII-31  Overall administrative costs for EU-27 

PD30 - Reporting on reclamation and destruction 

Overall administrative cost in EU-27 

Personnel 
costs 

Equipment 
Costs 

Outsourcing 
costs 

Total Cost 

[Thousand €] annual 

17.3  

0.0 

0.0 

17.3  

5.8. 

Summary of administrative cost of the phasedown option 

Table  A_XII-32  and  Table  A_XII-33  summarise  the  one-off  costs  and  annual  cost 
estimates for the phasedown option: 

Table A_XII-32   Summary of the one-off cost in the EU-27 for the phasedown option 

Summary administrative cost phasedown (one-off) 

Overall administrative cost in EU-27 

Information requirement 

Personnel 
cost 

Equipment 
Cost 

Outsourcing  
cost 

Total Cost 

[Thousand €] once (one-off) 

PD03  Registration in data base 

PD04 

Submission  of  verified 
baseline report 

PD05 

Verification  of  baseline 
report 

Total one-off 

177 

42 

192 

411 

- 

- 

- 

- 

12  

-  

190 

42 

1,484  

1,676 

1,496  

1,907 

EN 

211 

   EN 

 
 
  
  
  
  
 
Table A_XII-33   Summary of annual costs in the EU-27 for the phasedown option 

Summary administrative cost phasedown (annual) 

Overall administrative cost in EU-27 

Information requirement 

Personnel 
cost 

Equipment 
Cost 

Outsourcing  
cost 

Total Cost 

PD19 

Verification 
of 
Reporting  acc.  Art  6  F-
Gas Regulation 

PD30 

Reporting 
reclamation 
destruction 

on 
and 

Total annual 

[Thousand €] annual 

24 

17 

41 

- 

- 

- 

185  

209 

-  

17 

185  

227 

In  order  to  compare  both  cost  categories,  the  one-off  cost  can  be  converted  into 
annuities for 18 years (2013–2030) using an interest rate of 8%. Under these conditions, 
the  total  one-off  cost  would  correlate  to  €  203,000  per  year.  The  total  annualised 
administrative  costs  for  industry  incurred  by  the  phasedown  option  would  amount  to 
approximately  €  430,000  per  year.  About  90%  of  these  costs  are  induced  by  the 
verification of annual reports and the baseline report. 

However  it  should  be  noted  that  the  cost  estimated  for  the  reporting  of  destruction  of 
HFCs  would  cover  the  reporting  of  metric  tonnes  of  an  unspecified  mix  of  HFCs, 
HCFCs and other refrigerants, only. A reasonably exact determination of the amount of 
HFCs destroyed expressed in CO2 equivalents is not possible on this basis. 

6. 

– 

POLICY OPTION E: REGULATORY BANS 

Policy  option  E  refers  to  the  introduction  of  regulatory  bans  for  certain  open 
and  closed  applications  containing  fluorinated  greenhouse  gass  as  well  as  the 
mandatory destruction of HFC-23 from halocarbon production.  

In section 5.5 in the main part the included bans are listed. 

An  overview  of  the  information  requirements  in  policy  option  E  is  given  in  Table 
A_XII-34 covering the following obligations: 

• 

• 

Cooperation with audits & inspection by public authorities - B01, 

Carry out audits / inspections - B02, 

EN 

212 

   EN 

 
  
  
  
  
 
• 

• 

Report on implementation to Commission - B03 and 

Check the verification reports - B04. 

Given that the concrete sectors, gases, timelines of bans on the use of F-Gas in certain 
appliances would have been settled by the Commission beforehand, it is assumed that 
no  administrative  costs  will  occur  for  these  steps.  Furthermore  the  policy  option  is 
based  on  the  assumption  that  there  are  no  exemptions  from  a  ban.  This  assumption  is 
due to the fact that the management of exemptions would entail administrative costs for 
both undertakings and the Commission, inter alia covering the application process, legal 
assessment,  granting  or  rejection  of  an  exemption.  However,  such  costs  will  not  be 
treated  as  administrative  costs,  as  it  is  not  imposed  on  undertakings  to  apply  for  an 
exemption. 

Administrative  costs  regarding  obligation  B01  are  not  collected  from  the  stakeholder 
and  will  not  be  assessed,  as  the  enforcement  would  probably  consist  in  checking 
samples  of  imported/produced  marketed  products.  Checking  the  verification  reports 
(obligation  B04)  will  not  be  included  in  the  administrative  costs  of  the  option  as  that 
will  be  done  by  the  Commission  and  thus  can  be  neglected  following  the  impact 
assessment guidelines.  

6.1. 

Overview of information requirements for the ban option 

Table A_XII-34 gives an overview of information requirements which are necessary for 
regulatory  bans.  Each  line  taken  into  account  for  the  quantitative  estimation  of 
administrative cost is further explained in the following sections. 

EN 

213 

   EN 

 
Table A_XII-34   Overview of information requirements regarding regulatory bans 

Administrative costs of regulatory bans 

No. 

Obligation 

Frequency 

Affected stakeholder group 

Comment / Approach 

Source of information 

B01 

Cooperation with audits 
& inspection by public 
authorities 

B02 

Carry out audits / 
inspections  

Type 

No. 

Producers, 
importers of 
equipment/prod
ucts 

~1250 

Is neglected as enforcement 
would probably consist in 
checking samples of 
imported/produced marketed 
products. 

MS authorities 

27 MS 

Build on European experience 
in bans and own estimations: 

Unit of specific cost (cost per 
controlled entity) 

Depends on 
enforcement by 
MS: 
Assumption is 
once per year 

Once per year. 

No of 
inspections per 
year: No of 
producers/impor
ters (B01). 

B03 

B04 

EN 

Report on 
implementation to COM 

Once pear year  MS authorities 

27 MS 

Cost per MS based on 
experience with Art. 26 ODS 
reports. 

ODS competent authorities 

Check verification 
reports 

 27 reports once 
per year 

COM 

1 

Is neglected as COM efforts 
are not included in 
administrative costs. 

214 

EN 

 
  
 
 
 
 
 
 
 
 
 
6.2. 

B02 - Carry out audits/inspections 

Member  States  are  required  to  enforce  the  bans  established.  Therefore,  the  costs  for 
enforcement  activities  such  as  audits  or  inspections  at  relevant  companies  are  of 
interest. In general, inspections are carried out by relevant authorities whereas audits are 
normally  conducted  by  independent  experts  on  behalf  of  the  companies  for  quality 
control.  

National  legislation  on  F-Gases  in  France  requires  companies  holding  certificates 
(“attestation de capacité”; mandatory since 4 July 2009) to become audited by external 
bodies  every  5  years.  Such  audits  aim  at  the  control  of  personnel  certification,  data 
the  company  and  are  hence  rather 
monitoring  and  data  verification  within 
comprehensive  and  cannot  be  compared  to  measures  ensuring  compliance  with  a 
particular ban. Due to the legal requirement, all certified companies in France need to 
take audits.  

Within  an  inspection  campaign,  not  all  companies  active  in  a  particular  sector  are 
controlled, but particular measures are enforced at random samples.  

Despite  these  differences  between  the  general  nature  of  audits  and  inspections,  it  is 
estimated  that  the  efforts  to  be  made  by  companies  for  preparation  and  support  are 
comparable. As officials investigate the cases chosen, the costs for an inspection carried 
out  by  authorities  are  considered  to  be  lower  than  cost  for  an  audit  undertaken  by 
contracted external auditors.  

Questionnaires have been sent out to three authorities in Member States where bans of 
HFCs in certain products or general bans have been in place for some time. Only one 
answer has been received (from Denmark).  

It  should  be  noted  that  costs  for  inspections  to  enforce  bans  largely  depend  on  the 
degree  of  detail  such  investigations  are  aiming  at.  For  example,  in  Austria  control  of 
ODS bans in aerosols carried out in the 1990s included not only checks of the labels and 
company  data,  but  also  costly  and  time  consuming  chemical  analyses  by  means  of 
particular equipment. Bans of HFCs, in particular applications, have not been controlled 
in recent years.94 

With regard to ODS refrigerants, checks of equipment logbooks to enforce bans of the 
use  of  virgin  ODS  are  not  known  to  date.  Such  bans  are  enforced  by  means  of 
registration and control of F-Gas importers and distributors. 

Thus,  estimates  of  administrative  costs  for  one  inspection  are  based  on  their  own 
estimates for an inspection of the ban of the use of HFCs in stationary equipment. It is 
assumed  that  official  environmental  and/or  chemical  inspectors  undertake  an  on-site 
visit at one particular company. The inspection includes the check of the logbooks and 
servicing  information,  the  filling  in  forms  and  tables  and  filing  the  information.  No 
chemical analyses of products/equipment are carried out. 

Based  on  a  combination  of  the  above-mentioned  assumptions  and  the  response  of 
Denmark  authorities  who  estimated  to  need  65  hours  for  carrying  out  one 

94 

Telephone conversation with Austrian EPA, 22.12.2011. 

EN 

215 

   EN 

 
                                                 
audit/inspection  the  following  estimates  on  the  administrative  burden  per  entity  is 
provided in Table A_XII-35.  

Table A_XII-54   Administrative burden per entity: B02 – Carry out audits/ inspections 

B 02 – Carry out audits/ inspections 

Administrative burden per entity 

Annual 

Time [hours] 

Equipment costs [€] 

Outsourcing costs [€] 

20 

0 

0 

Table A_XII-36   Number of affected companies with closed application within the areas of a 

regulatory ban: B02 – Carry out audits/inspections 

Area of a regulatory ban 

(closed application) 

No. of companies in EU-27 placing the 
equipment on the market: 

Source 

EU producers & Importers 

Commercial refrigeration (Stand-
alone systems, Condensing units, 
Centralized systems). 

Industrial refrigeration 

Transport refrigeration 
(Refrigerated trucks and trailers), 

Stationary AC (Moveable 
systems, single split systems, 
multi split/VRF systems, rooftop 
systems, displacement chillers) 

ca. 20 (industrially manufactured stand-
alone equipment) 

ca. 16 (large companies) 

ca. 1000 (small companies for 
condensing units, centralized systems) 

ca. 100 

12 

10 (Producers) 

ca. 20 (Importers of OEM) 

HFC-23 in fire protection 

30 

Total amount 

ca. 1,200 

Ökoinstitute estimate 

Ökoinstituteestimate 

See Schwarz et. al. 
20119, p. 233. 

Ökoinstitute estimate 

Estimation on total number 
of EU based original 
equipment manufacturers, 
see Schwarz et.al. 20119, p. 
235. 

EN 

216 

   EN 

 
 
 
 
Table A_XII-37   Number of affected companies with open applications within the areas of a 

regulatory ban: B02 – Carry out audits/inspections 

Area of a regulatory ban 

(open application) 

XPS 134a foam blowing 

SF6  in  Magnesium  die-casting  <850 kg/y 
and recycling of die casting alloys 

Mandatory destruction of HFC-23. 

Technical aerosols 

Total amount 

No.  of  producing 
companies in EU-27  

Source of information 

See Schwarz et.al. 2011.9 

See Schwarz/Gschrey 200995, 
p. 18. 

Schwarz et al. (2011)9, p.175 

Ökoinstitute estimate 

13 

19 

1 

ca. 20 

53 

Table  A_XII-38  shows  the  resulting  overall  annual  costs  in  the  EU-27,  taking  into 
account  a  time  of  20  hours  for  the  carrying  out  audits/  inspections  per  company  (cf. 
Table A_XII-35)), the weighted tariff of 36 €/hour for EU-27 (as calculated in chapter 
3.2  of  this  annex)  and  1250  affected  companies  (sum  of  Table  A_XII-36  and  Table 
A_XII-37). 

Table A_XII-38   Overall administrative costs for EU-27: B02 – Carry out audits/ inspections 

B02 - Carry out audits / inspections 

Overall administrative cost in EU 27 

Personnel 
costs 

Equipment 
costs 

Outsourcing 
costs 

Total cost 

[Thousand €] annual 

895,6 

- 

- 

895,6 

95 

Schwarz/Gschrey (Öko-Recherche): Service contract to assess the feasibility of options to reduce 
emissions of SF6 from the EU non-ferrous metal industry and analyse their potential impacts. 

EN 

217 

   EN 

 
 
 
 
                                                 
6.3. 

B 03 – MS reports on implementation 

Obligation B03 “MS reports on implementation” envisages that competent authority in 
each Members State shall report to the Commission on the implementation of regulatory 
bans  in  their  Member  State.  It  is  assumed  that  the  effort  is  comparable  to  the 
administrative efforts necessary to report to the Commission on the implementation of 
ODS under Art. 26 ODS Regulation.  

A  questionnaire  listing  the  required  action  within  B03  was  sent  to  27  competent 
authorities  in  the  Members  States  in  charge  of  the  ODS  regulation.  Answers  from  10 
Member  States  were  received.  Figures  shown  in  Table  A_XII-39  are  the  resulting 
average  hours  necessary  to  report  on  the  implementation  to  EU  under  Art. 26  of  the 
ODS Regulation. 

Table A_XII-39   Administrative burden per MS: B03 - MS reports on implementation to EU 

B03 - MS reports on implementation 

Administrative burden per entity 

Time [hours] 

Equipment costs [€] 

306 

annual 

- 

Outsourcing  
costs [€] 

4,542 

Source: Analysis of questionnaires sent to MS competent authorities for ODS (Annex XIII) 

Figures  shown  in  Table  A_XII-40  are  the  resulting  minimum  and  maximum  hours 
necessary to report on the implementation to EU under Art. 26 of the ODS Regulation. 

Table A_XII-40   Minimum  and  maximum  administrative  burden  for  the  interviewed  MS:  

B03 - MS reports on implementation to EU 

B03 - MS reports on implementation to EU 

Minimum and maximum administrative burden for the interviewed MS 

Time [hours], annual 

Minimum 

16  

Maximum 

1,000  

Source: Analysis of questionnaires sent to MS competent authorities for ODS (Annex XIII) 

EN 

218 

   EN 

 
 
Two outliers were identified and removed from the analysis. One MS did not state any 
costs for reporting under Art. 26 ODS, one MS did not quantify the administrative costs 
and one MS stated 610 hours for reporting under Art. 26 ODS which is five times the 
average administrative burden.  

Only  one  Member  State  of  the  seven  reported  to  have  equipment  costs  of  €  2,250 
necessary  for  the  reporting  under  Art.  26  ODS  regulation  and  therefore  will  be 
evaluated as an outlier not be included in the following analysis.  

Table A_XII-41  shows that the resulting overall annual costs in the EU-27 is € 334.7 
taking into account administrative burden per MS of 212 hours per report/once a year 
and  the  average  tariff  per  hour  for  professionals  in  the  EU-27  of  €  26.  The  overall 
outsourcing costs are estimated to be € 122.6. 

Table A_XII-41   Overall administrative costs for EU-27: B03 - MS reports on implementation 

to EU 

B03 - MS reports on implementation 

Overall administrative cost in EU 27 

Personnel 
costs 

Equipment 
costs 

Outsourcing 
costs 

Total cost 

[Thousand €] annual 

212.0 

- 

122.6 

334.7 

The  following  comments  given  by  the  interviewed  Member  States  are  important  inter 
alia for the transferability of the administrative costs from reporting under Art. 26 ODS 
to a possible reporting under F-Gas Regulation in option E: 

In  Federal  States  (e.g.  Germany)  the  administrative  burden  may  vary  between  federal 
states.  According  to  competent  authorities  in  Germany  no  additional  equipment  or 
outsourcing is required and the administrative burden is rather low because authorities 
can often produce the required information from their collected enforcement data. Other 
kinds of information might take considerably longer to collect. 

In  small  countries  administrative  efforts  in  this  field  are  not  very  complicated  and 
comprehensive, e.g. everything in relation with reporting (Article 26) is carried out by 
one person over approximately 4 months (as part of regular work) in cooperation with 
stakeholders  who  provide  data.  However,  it  is  believed  that  costs  and  workload  will 
increase significantly if Member States will have to report on the use of F-Gases. 

Following  the  assessment  of  the  French  competent  authority  the  reporting  of  the  MS 
according to Article 26 ODS is not an administrative burden. Nevertheless, the French 
competent authority believes that Article 26 ODS is not the most appropriate one to be 
included  in  the  revision  of  the  Regulation  842/2006.  Instead  a  similar  reporting 
mechanism  (that  includes  production  and  destruction)  according  to  Article  27  ODS 

EN 

219 

   EN 

 
 
 
Regulation  should  be  included  in  the  revision  of  the  F-Gas  Regulation  and  should  be 
extended to pre-charged equipment as such information is necessary to any phasedown 
scenario of the production and consumption of F-Gases. 

6.4. 

Summary of administrative cost of the ban option 

The  overall  estimation  of  the  annual  administrative  costs  in  the  option  E  “Regulatory 
ban on certain open and closed uses of HFC” is given in Table A_XII-42. 

Table A_XII-42  Annual administrative costs of the ban option 

Summary administrative cost phase-down (annual)
Overall administrative cost in EU 27

Information requirement

Personnel 
cost

Outsourcing 
Equipment 
Cost
cost
[Thousand €] annual

Total Cost

B02

Carry out audits / inspections

B03

MS reports on 
implementation
Total annual

896

212

1,108

- 

- 

- 

- 

123

123

896

335

1,230

EN 

220 

   EN 

 
 
  
 
ANNEX XIII: Questionnaire assessing Administrative Costs of Stakeholders 

1. 

INTRODUCTION 

Regulation  (EC)  No  842/2006  on  certain  fluorinated  greenhouse  gass  ("F-Gas 
Regulation"),  supplemented  by  10  implementing  Commission  Regulations,  aims  at 
reducing  emissions  of  hydrofluorocarbons  (HFCs),  perfluorocarbons  (PFCs)  and 
sulphur  hexafluoride  (SF6)  (collectively  referred  to  as  "F-Gases",  all  of  which  are 
controlled  as  greenhouse  gass  under  the  Kyoto  Protocol)  in  the  European  Union, 
through a series of measures along two tracks of action: 

– 

– 

Avoiding  F-Gases  in  some  applications  in  which  more  environmentally 
superior  alternatives  were  already  cost-effective.  Measures  include  use 
and marketing restrictions. 

Reduce 
leakages  from  equipment  containing  F-Gases.  Measures 
comprise:  labelling  of  equipment  containing  F-Gases,  training  and 
certification  of  personnel  and  companies  handling  this  type  oF-Gases, 
containment and proper recovery.  

Article  10  of  the  F-Gas  Regulation  requires  the  European  Commission  to  publish  a 
report  in  2011  based  on  the  experience  of  its  application  and,  if  necessary,  present 
proposals for revision of the relevant provisions of the Regulation. 

On 26 September 2011 the Commission completed a review of the application, effects 
and adequacy of the F-Gas Regulation and issued a report96, drawing from the results of 
an analytical study (Schwarz et al. (2011)9.  

In  parallel,  the  European  Commission  has  contracted  a  consortium  including  Öko-
Institut, Öko-Recherche and HEAT International for support for the impact assessment 
of  a  possible  legal  proposal  to  revise  the  F-Gas  Regulation.  In  the  context  of  that 
contract several options for policy measures to revise the F-Gas Regulation in order to 
further  reduce  European  emissions  are  elaborated  and  subjected  to  an  impact 
assessment. As a  part of  that  impact assessment, this  questionnaire shall serve  to help 
assessing  the  administrative  costs  which  would  be  incurred  by  enterprises  and  public 
authorities in meeting additional legal obligations to provide information on their action 
or  production,  as  required  by  a  possible  revision  to  the  F-Gas  Regulation,  either  to 
public authorities or to private parties. 

Please  note  that  this  questionnaire  is  circulated  in  parallel  to,  but  is,  however, 
independent  from  the  stakeholder  consultation97  which  the  Commission  has  launched 
regarding  its  above  mentioned  report  of  26  September  2011.  In  case  you  wish  to 
communicate to the Commission your opinions and arguments concerning any type of 
policy options to revise the F-Gas regulation, we kindly ask you to use that stakeholder 
consultation  forum  for  that  purpose.  The  evaluation  of  this  questionnaire  will  not 

96http://ec.europa.eu/clima/policies/F-Gas/docs/report_en.pdf 
97http://ec.europa.eu/clima/consultations/0011/index_en.htm 

EN 

221 

   EN 

 
                                                 
include any general comments but will be restricted to the dimension of administrative 
cost connected to the range of policy options presented below. 

2. 

GENERAL GUIDANCE TO THE USERS 

The attached questionnaire is meant to underpin the Impact Assessment undertaken by 
the European Commission as part of the revision of the Regulation (EC) No. 842/2006 
on  certain  fluorinated  greenhouse  gass.  The  aim  of  the  questionnaire  is  to  elicit  a 
quantitative  estimate  of  changes  in  administrative  costs  and  administrative  burden 
that  may  be  incurred  by  stakeholders  in  implementing  the  requirements  of  a  revised 
Regulation  in  so  far  as  activities  to  provide  information  are  concerned.  The  term 
“information”  is  used  in  a  broad  sense,  covering  labelling,  reporting,  registration, 
monitoring  and  assessment  needed  to  provide  information  as  well  as  the  transfer  of 
information to public authorities and private parties (e.g. trade associations). Any other 
cost  possibly  incurred  to  stakeholders,  i.e.  not  related  to  providing  information,  is  not 
subject to this questionnaire. 

The  variety  of  possible  information  requirements  identified  in  this  questionnaire  is 
representative  of  a  range  of  possible  policy  orientations,  but  they  do  not  reflect  the 
Commission's views at this stage. 

In  order  to  facilitate  both  filling  in  and  evaluation  of  the  questionnaire,  we  have 
implemented the questionnaire as an Excel worksheet. 

Please  complete  the  questions  in  the  attached  Excel  worksheet  in  as  much  detail  as 
possible and return your response by //date// to //contact//, using the e-mail-address //E-
mail//. If you have any queries about the questionnaire, please also contact us using the 
E-Mail-address above.  

In the Excel worksheet specific questions are asked focusing  

– 

– 

on  stakeholders’  experience  on  administrative  cost  for  meeting 
information  requirements  which  are  comparable  to  those  that  might 
become  relevant  depending  on  policy  options  chosen  for  a  potential 
revision of the F-Gas Regulation, or 

on  stakeholders’  expectations  on  administrative  cost  for  meeting 
information  requirements  that  might  become  relevant  depending  on 
policy options chosen for a potential revision of the F-Gas Regulation. 

For  better  readability  the  questions  are  printed  in  section  3below  of  this  document,  as 
well. 

The addressees of the questionnaire are kindly asked to indicate the time needed to fulfil 
an  information  obligations  differentiated  by  a  set  of  activities.  According  to  the  EU 
Impact  Assessment  guidelines98  different  types  of  required  actions  are  categorized  as 
follows: 

98http://ec.europa.eu/governance/impact/commission_guidelines/docs/iag_2009_annex_en.pdf 

EN 

222 

   EN 

 
                                                 
– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

Familiarising with the information obligation 

Training members and employees about the information obligations 

Retrieving relevant information from existing data 

Adjusting existing data 

Producing new data 

Designing information material (e.g. leaflet conception) 

Filling forms and tables (including recordkeeping) 

Holding meetings (internal/external with an auditor, lawyer etc.) 

Inspecting  and  checking  (including  assistance  to  inspection  by  public 
authorities) 

Copying (reproducing reports, producing labels or leaflets) 

Submitting the information to the relevant authority (e.g. sending it to the 
relevant authority) 

Filing the information 

Buying  (IT)  equipment  &  supplies  (e.g. 
specifically used to fulfil information obligations 

labelling  machines) 

to 

– 

Other 

These  activities  are  reflected  in  the  questionnaire  as  appropriate  for  the  individual 
questions.  Note  that  not  all  types  of  activities  are  relevant  for  every  question  asked. 
Whilst 
fixed,  a 
“comments/assumptions”  section  has  been  included  to  allow  participants  to  provide 
further explanation of the estimates. 

the  questionnaire  are 

the  basic  data 

requirements 

from 

It  must  be  emphasised  that  the  Commission  places  great  importance  on  determining 
numerical values for the costs and benefits of proposals, wherever possible. Therefore, 
the addressees are urged to provide their best estimates of staff-days and/or cost data.  

The questions related to the administrative burden include the following elements: 

– 

– 

– 

Staff-hours:  the  number  of  hours  spent  by  staff  of  your  company  / 
institution fulfilling the requirement as defined in the question; 

Consultancy costs: fees for work done by external consultants; 

Capital costs: for software or other items purchased to fulfil information 
requirements. 

EN 

223 

   EN 

 
The  questionnaire  allows  for  insertion  of  staff-days  and/or  cost  data.  Please  clearly 
indicate which is being used by adding ‘days’ or ‘€’ (or other currency) in relevant cells. 
In case it is not possible to provide a fix numerical value, please provide an estimated 
range  of  staff  days/costs  and  explain  your  estimate  in  the  “comments/assumptions” 
column. 

EN 

224 

   EN 

 
3. 

• 

QUESTIONNAIRE ADDRESSING COMPANIES WITH EXPERIENCE UNDER THE ODS REGULATION 

Registration in database 

Obligation option PD03

Registration in data base

Addressed stakeholders:  Stakeholders with experience in registration in the EU ODS database

Answering entity based in: 

Frequency of obligation:  Once

specific question:  What was your administrative effort for registration with the ODS data base?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

Once

Once

Once

Remarks

No.

Description of required action(s)

1 Familiarising with the information obligation
2 Training members and employees about the information obligations
3 Retrieving relevant information from existing data
4 Adjusting existing data
5 Producing new data
7 Filling forms and tables

9

Inspecting and checking (including assistance to inspection by 
public authorities)

11 Submitting the information (sending it to the designated recipient)
12 Filing the information
14 Other

EN 

225 

EN 

 
  
 
4. 

• 

QUESTIONNAIRE ADDRESSING RECLAMATION AND/OR DESTRUCTION FACILITIES CURRENTLY NOT COVERED BY REPORTING OBLIGATIONS 

Reporting of F-Gases by reclamation and/or destruction facilities 

Obligation option PD30

Reporting of F-gases by reclamation and/or destruction facilities

Addressed stakeholders:  Reclamation and/or destruction facilities for F-gases currently not covered by reporting obligations

Answering entity based in: 

Frequency of obligation:  Annual

Specific question: 

What would be your administrative effort for annual reporting of reclamation and/or destruction of used F-gases 
by type?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

Annual

Annual

Annual

Remarks

No.

Description of required action(s)

1 Familiarising with the information obligation
2 Training members and employees about the information obligations
3 Retrieving relevant information from existing data
4 Adjusting existing data
5 Producing new data
7 Filling forms and tables

9

Inspecting and checking (including assistance to inspection by 
public authorities)

10 Copying (reproducing reports, producing labels or leaflets)
11 Submitting the information (sending it to the designated recipient)
14 Other

Monitor F-gas quantities for reclamation by F-gas type

EN 

226 

EN 

 
  
 
5. 

• 

QUESTIONNAIRE ADDRESSING MS AUTHORITIES WITH EXPERIENCE IN F-GAS BANS 

Carry out audits/inspections 

Obligation option B02

Carry out audits/ inspections

Addressed stakeholders:  Authorities in Member States

answering entity based in: 

Frequency of obligation:  Annually

specific question: 

Could you please estimate your administrative effort for carrying out one audit/inspection in order to enforce 
bans on fluorinated gases?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

Annually

Annually

Annually

Remarks

No.

Description of required action(s)

2 Training members and employees about the information obligations

3 Retrieving relevant information from existing data

7 Filling forms and tables

9

Inspecting and checking (including assistance to inspection by 
public authorities)

11 Submitting the information (sending it to the designated recipient)
12 Filing the information
13 Buying (IT) equipment & supplies 
14 Other

identifying and choosing relevant companies, scheduling of

e.g.
audit/inspection, preparing background information documents

e.g. travel to onsite inspections

EN 

227 

EN 

 
  
 
6. 

• 

QUESTIONNAIRE ADDRESSING MS COMPETENT AUTHORITIES UNDER THE ODS REGULATION 

Report on implementation of EU legislation to the Commission 

Obligation option B03

Report on implementation of  EU legislation to the Commission

Addressed stakeholders:  MS competent authorities under the ODS regulation

Answering entity based in: 

Frequency of obligation:  once

Specific question: 

What was your administrative effort to report on the implementation of the ODS regulation to the Commission 
(Art. 26)?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

once

once

once

Remarks

No.

Description of required action(s)

1 Familiarising with the information obligation
2 Training members and employees about the information obligations
3 Retrieving relevant information from existing data
4 Adjusting existing data
5 Producing new data
6 Filling forms and tables
7 Holding meetings
8 Submitting the information (sending it to the designated recipient)
9 Filing forms and tables

10 Other

EN 

228 

EN 

 
  
 
7. 

• 

QUESTIONNAIRE ADDRESSING COMPANIES CURRENTLY FALLING UNDER REPORTING REQUIREMENT IN THE F-GAS REGULATION 

Annual report on the placing of F-Gases on the EU market 

Obligation option PD18

Annual companies' reports on the placing on the market of F-Gases

Addressed stakeholders:  Companies currently reporting under the F-Gas regulation

Answering entity based in: 

Frequency of obligation:  annually

Specific question:  What were your companies efforts for an (annual) report under the current F-Gas regulation?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

annually

annually

Remarks

No.

Description of required action(s)

1 Familiarising with the information obligation
2 Training members and employees about the information obligations
3 Retrieving relevant information from existing data
4 Adjusting existing data
5 Producing new data
7 Filling forms and tables
8 Holding meetings

11 Submitting the information (sending it to the designated recipient)
12 Filing the information
14 Other

EN 

229 

EN 

 
  
 
• 

Verification of a report on the placing of F-Gases on the EU market 

Obligation option PD19

Verification of a report on activity data in a given year

Addressed stakeholders:  Companies currently reporting under the F-Gas regulation

Answering entity based in: 

Frequency of obligation:  Annually

Specific question: 

How would you estimate your additional effort and cost to have your F-Gas report verified by an independent 
expert (e.g. by accounting consultants or EMAS verifier)?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

Annually

Annually

Annually

Remarks

No.

Description of required action(s)

1 Familiarising with the information obligation
2 Training members and employees about the information obligations
3 Retrieving relevant information from existing data
4 Filling forms and tables
5 Submitting the information (sending it to the designated recipient)
6 Other
7 - Expenses for external verifiers
8 - Assistance/support to external verifiers

EN 

230 

EN 

 
  
 
8. 

• 

QUESTIONNAIRE ADDRESSING TRADE ASSOCIATIONS EXPERIENCED WITH A VOLUNTARY AGREEMENT (VA) 

Annual monitoring report 

Obligation option VA04

Annual monitoring report

Addressed stakeholders:  Industry/trade associations experienced with a voluntary agreement (VA)

Answering entity based in: 

Frequency of obligation:  Annually

Specific question: 

What were your administrative efforts for an (annual) report to national or EU authorities under the voluntary 
agreement you have been involved in?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

Annually

Annually

Remarks

No.

Description of required action(s)

1 Familiarising with the information obligation
2 Training members and employees about the information obligations
3 Retrieving relevant information from existing data
4 Adjusting existing data
5 Producing new data
7 Filling forms and tables
8 Holding meetings

11 Submitting the information (sending it to the designated recipient)
12 Filing the information
14 Other

EN 

231 

EN 

 
  
 
• 

Communication with stakeholders 

Obligation option VA06

Communication with stakeholders

Addressed stakeholders:  Industry/trade associations experienced with a voluntary agreement (VA)

Answering entity based in: 

Frequency of obligation:  Annually  

Specific question: 

What were your administrative efforts per year for communication with stakeholders concerning the voluntary 
agreement you have been involved in?

Administrative burden per entity

Time 
(hours)

Equipment 
costs [€]

Outsourcing 
costs [€]

Annually  

Annually  

Remarks

No.

Description of required action(s)

1 Familiarising with the information obligation
2 Training members and employees about the information obligations
3 Retrieving relevant information from existing data
4 Adjusting existing data
5 Producing new data
6 Designing information material (leaflet conception…)
8 Holding meetings

10 Copying (reproducing reports, producing labels or leaflets)
11 Submitting the information (sending it to the designated recipient)
12 Filing the information
13 Buying (IT) equipment & supplies 
14 Other

EN 

232 

EN 

 
  
 
ANNEX XIV: Macroeconomic Analysis  of F-Gas Policies with GEM-E3  

1. 

METHODOLOGY 

The GEM-E3 model is an applied general equilibrium model99. The main feature of a general 
equilibrium model is capturing the price induced effects of policies, including substitution in 
commodity demand as well as shifts in trade behaviour. As GEM-E3 evaluates emissions of 
all Kyoto-gases including fluorinated greenhouse gass, and as it is allows imposing taxes on 
these  pollutants,  the  model  captures  the  interactions  between  the  economy,  energy  system, 
and interactions for the major world regions linked though endogenous bilateral trade flows. 
The current version of the model is based on the GTAP 7 database with the base year 2004. 
IPTS (JRC) performed the model calculations. The emissions follow historical paths up 2010 
(based  on  the  UNFCCC  inventory  of  EEA  of  2011).  For  fluorinated  greenhouse  gass  the 
baseline emission path is in line with the "with measures" (WM) scenario of Schwarz et al. 
(2011)9 after 2010 (option A). In GEM-E3 emissions of HFC are accounted in the production 
stage, i.e. are allocated to the producers of HFC which is mainly the chemical sector. As HFC 
emissions are allocated to this sector, the cost of employing abatement technologies also are 
allocated  to  these  sectors.  The  estimates  of  the  abatement  cost  functions  are  based  on  the 
IIASA database.100   

2. 

SCENARIOS  

The scenarios implement the reductions of HFC as a trading system over all emission sources. 
HFC  emissions  are  allocated  to  the  producers  of  HFC,  i.e.  mainly  the  chemical  sector. 
Therefore  the  scenarios  implement  emission  trading  at  upstream,  i.e.  production,  level.  The 
emission  reduction  targets  for  2030  are  given  in  the  Table  A_XIV-1  below.  The  scenarios 
differ  in  the  way  F-Gas  emission  rights  are  allocated:  for  free,  or  being  sold  through 
auctioning.  Impacts  would  also  depend  on  whether  the  non-European  countries  also  impose 
reduction targets on HFC, i.e. whether the European policy is unilateral or not. An overview 
over the scenario settings is given in the table below. The model assesses the impacts of the 
two  (strongest)  options,  D  (Phase  down)  and  option  E  (Ban),  with  the  strongest  impact  (in 
terms of emission reduction and costs). The emission reductions for 2030 are consistent with 
the expected reduction in emissions in 2030 of option D and E in the main text. 

Table A_XIV-1:    

HFC emission reduction targets compared to 2006  

EU-Option D 

EU-Option E 

2030 

62% 

45% 

99 
100 

For a detailed model description see: www.GEM-E3.net 
Hoglund-Isaksson et al. (2010). "Potentials and costs for mitigation of non-CO2 GHG emissions in the 
European  Union  until  2030." 
the  European  Commission. 
IIASA,  Laxenburg.  Report 
http://ec.europa.eu/clima/policies/package/docs/non_co2emissions_may2010_en.pdf 

to 

EN 

233 

   EN 

 
 
 
                                                 
Scenario 1 examines the case of allocation of permits with no passing on of the costs in the 
case of unilateral EU action. The scenario Group 1-W allows for costs pass-on, i.e. even if the 
permits  are  allocated  for  free,  firms  include  the  (market)  value  of  permits  into  the  output 
price. Group 2 implements full auctioning of F-Gas allocations (the right to place F-Gas on 
the  market).  In  the  full  auctioning  case,  the  income  of  auctioning  F-Gas  is  assumed  to  be 
recycled  into  the  economy  by  decreasing  social  security  contributions  paid  by  employers 
reducing labour costs. All cases are implemented for option D and E. 

Table A_XIV-2 

Scenario overview 

Group 

Unilateral 

EU 

1 

Allocation of permits 
(grandfathering) 

No passing on 

Non-EU  No actions 

EU 

1-W 

Allocation of permits 
(grandfathering) 

Passing on permit costs 

Non-EU  No actions 

EU 

Auctioning of permits 

2 

Non-EU  No actions 

EN 

234 

   EN 

 
 
 
3. 

DETAILED RESULTS  

The table A_XIV-3 below show the possible impacts on GDP in 2030 for options D and E. 
While the GDP impacts differ across scenarios and between options D and E, they are small 
in all cases.  

Table A_XIV-3 

GDP impacts in 2030 (% change compared to baseline) 

Allocation – no 
passing on 

Cost passing on 

Auctioning 

D 

E 

-0.006

-0.003 

-0.012

-0.008

-0.007 

-0.004 

In  case  emission  permits  are  allocated  for  free  and  their  value  is  not  included  in  the  output 
price  (Group  1),  the  GDP  loss  increases  with  the  emission  reductions.  The  GDP  impact  is 
therefore  bigger  in  option  D  than  E.  In  the  case  of  unilateral  European  policy  and  the 
(opportunity  costs  of)  grandfathered  permits  included  into  the  output  price  (cost  pass-
through), the GDP losses becomes more pronounced but are still small: As the value of the 
permits  further  increases  the  output  price,  the  loss  in  competitiveness  leads  to  an  further 
increase of imports and decrease of exports. The effect is smaller for option E since the permit 
price is lower. In case of full auctioning of HFC permits GDP losses are smaller than in the 
costs  pass-through  case.  If  these  revenues  are  used  to  decrease  social  security  contributions 
paid  by  employers  they  decrease  the  cost  of  labour.  This  exercises  a  positive  effect  on  the 
whole economy as labour prices decrease.  

The impacts on employment are shown in the following tables. Clearly, the impacts are small 
and either positive or negative. They would be the most negative in case the additional direct 
costs were passed through into higher prices. If permits to place F-Gases on the market would 
be auctioned and the revenues used to reduce labour costs the impact on employment would 
be  positive.  Note  that  the  table  does  not  take  into  account  that  importers  of  F-Gases  are 
affected  by  the  proposed  options  D  and  E  as  well.  As  a  result  the  negative  impacts  on  the 
number of jobs in the EU could be smaller (and less negative or even positive) as well since 
importers would also be faced with an increase in prices.  

EN 

235 

   EN 

 
 
 
 
Table A_XIV-4: 

Employment impacts in 2030 (number of jobs)  

D 

E 

No cost passing on 

-1.600

-1.000

Cost passing on 

-15.800

-11.600

Auctioning 

5.400

4.000

The impact on the level of production in the different sectors is shown in the Table A_XIV-5. 
As the abatement policy is implemented in an upstream manner, i.e. the producers of HFC are 
obliged  to  hold  emission  permits  for  HFCs  sold,  the  chemical  sector  which  is  the  main 
producers  of  HFC,  is  directly  affected  by  the  policy.  The  table  shows  the  change  in  the 
production  level  of  this  sector  compared  to  the  business-as-usual  (reflecting  current 
legislation,  option  A).  In  general  the  effects  on  production  are  small.  With  the  explanations 
given  above,  the  results  show  the  same  pattern  as  the  GDP  results.  Production  decreases  as 
domestic production is substituted by imports. In the case of auctioning the price of chemical 
products  further  increases  and,  thus,  production  decreases  further.  In  the  case  of  auctioning 
this effect is less pronounced (see i.e option D) since auctioning revenues are used to reduce 
labour costs. The double dividend of labour cost decrease also has a small positive effect on 
the chemical sector. The output losses might in reality be lower since importers of F-Gas (be 
it in bulk or included in products) are also affected to a certain degree by the options D & E 
since they are partially included. Modelling this would require detailed data on the production 
and trade flows of specific goods which is not available.  

Besides the effect that the price change of chemical products affects the whole economy via 
intermediate  demands,  sector  other  than  chemical  production  are  affected  mainly  by 
abatement  investment.  Table  A_XIV-5  shows  for  option  D  and  E  the  detailed  results 
indicating  that  in  particular  the  electric  goods,  transport  equipment,  other  equipment  and 
metals  sectors  would  see  an  increase  in  output.  For  option  E  similar  but  smaller  impacts 
occur. 

EN 

236 

   EN 

 
 
 
 
Table A_XIV-5  

Change in sectoral output in 2030 for option D and E (% change to baseline)  

  Option D 

Option E 

  No cost 
passing 
on 

Cost-
passing  
on 

Auction  No cost 
passing 
on 

Cost-
passing 
on 

Auction 

-0.13 

-0.01 

-0.01 

0.00 

0.00 

0.00 

0.00 

0.00 

0.01 

0.01 

0.01 

0.01 

0.02 

0.02 

0.02 

-0.35

-0.02

-0.01

0.00

0.00

0.00

0.00

0.00

0.02

0.02

0.01

0.04

0.04

0.05

0.04

-0.34

-0.02

-0.01

0.00

0.00

0.00

0.00

0.01

0.02

0.02

0.01

0.04

0.04

0.05

0.04

-0.06

-0.01

-0.01

0.00

0.00

0.00

0.00

0.00

0.00

0.01

0.00

0.00

0.01

0.02

0.01

-0.22 

-0.01 

-0.01 

0.00 

0.00 

0.00 

0.00 

0.00 

0.01 

0.01 

0.00 

0.02 

0.04 

0.02 

0.02 

-0.22

-0.01

-0.01

0.00

0.00

0.00

0.00

0.01

0.01

0.02

0.00

0.02

0.04

0.03

0.03

Chemical 

Electricity 

Coal 

Market services 

Non-market 
services 

Transport 

Oil 

Energy Intensive 

Consumer goods 

Agriculture 

Construction 

Gas 

Metals 

Other equipment 

Transport 
Equipment 

Electric Goods 

0.04 

0.06

0.07

0.02

0.04 

0.04

The implications for competiveness in terms of trade flows are shown in Table A_XIV-6 for 
the  exports  and  Table  A  XIV-7  for  the  imports.  Apart  from  the  chemical  sector,  which 
experiences a small reduction in exports of 0.16% to 0.43% in option D and -.07 to 0.27% in 
option  E,  the  impacts  on  exports  in  all  other  sectors  are  small,  but  positive.  The  auctioning 
tends  to  favour  more  labour-intensive  sectors  (e.g.  non-market  services)  since  auction 
revenues  are  assumed  to  be  used  to  reduce  labour  costs  but  the  effect  does  not  differ 
significantly from the cost passing on in terms of exports.  

EN 

237 

   EN 

 
 
 
 
 
 
Table A_XIV-6: 

Change in exports in 2030 in all sectors for options D and E (%   
change to baseline)).  

No cost 
passing 
on  

Option D 
Cost-
passing 
on 

Auction 

No cost 
passing 
on  

Option E 
Cost-
passing 
on 

Auction 

Chemical 
Electricity 
Energy Intensive 
Transport 
Construction 
Metals 
Consumer goods 
Market services 
Oil 
Transport 
Equipment 
Agriculture 
Electric Goods 
Non-market 
services 
Other equipment 
Gas 
Coal 

-0.16 
0.01 
0.01 
0.01 
0.01 
0.02 
0.02 
0.02 
0.02 
0.02 

0.03 
0.03 
0.03 

0.03 
0.05 
0.07 

-0.43
0.02
0.02
0.02
0.03
0.06
0.05
0.04
0.04
0.04

0.07
0.06
0.07

0.07
0.17
0.06

-0.43
0.01
0.03
0.03
0.03
0.06
0.05
0.04
0.04
0.05

0.07
0.06
0.07

0.07
0.15
0.06

-0.07
0.01
0.01
0.00
0.01
0.01
0.01
0.01
0.01
0.01

0.03
0.01
0.01

0.01
0.02
0.08

-0.27 
0.02 
0.01 
0.01 
0.02 
0.04 
0.03 
0.03 
0.03 
0.03 

0.04 
0.02 
0.04 

0.04 
0.10 
0.07 

-0.27
0.01
0.02
0.02
0.02
0.04
0.04
0.03
0.02
0.03

0.05
0.01
0.05

0.04
0.09
0.07

For the imports there is a more or less opposite trend compared to the exports, but impacts are 
much smaller. The chemical sector, construction, transport equipment and electric goods see 
an increase in imports.  In the chemical sector this is mainly due to the increase in production 
costs compared to the other countries. In the other sectors the increases might also be due to 
increase in domestic output. With cost passing on of the (implicit) F-gas price in output prices 
the effects are slightly higher. Note that this is also since GEM-E3 uses an upstream approach, 
i.e. energy, the chemical sector, are directly affected by the policy and in addition imports and 
export react to (production) price changes (see Annex XV for details). 

EN 

238 

   EN 

 
 
 
 
 
 
 
 
Table A_XIV-7  Change in imports in 2030 in all sectors for options D and E (% change to baseline 

(option A)) 

Option D 
No cost 
passing on  

Cost-
pass on 

Option E 

Auction  No cost 
passing 
on  

Cost-
pass on 

Auction 

Chemical 
Electricity 
Energy Intensive 
Transport 
Construction 
Metals 
Consumer goods 
Market services 
Oil 
Transport 
Equipment 
Agriculture 
Electric Goods 
Non-market 
services 
Other equipment 
Gas 
Coal 

0.01 
-0.01 
-0.01 
0.00 
0.01 
0.00 
-0.01 
-0.01 
-0.02 

0.01 
-0.01 
0.02 

0.00 
0.00 
-0.01 
-0.01 

0.01
-0.01
-0.02
-0.01
0.01
-0.01
-0.03
-0.03
-0.05

0.01
-0.02
0.01

0.00
-0.01
-0.03
-0.02

0.02
-0.01
0.02
0.00
0.01
0.01
-0.02
-0.02
-0.05

0.01
-0.02
0.02

0.00
0.01
-0.03
-0.02

0.00
0.00
-0.01
0.00
0.00
0.00
0.00
0.00
-0.01

0.01
0.00
0.01

0.00
0.00
-0.01
0.00

0.01 
-0.01 
0.00 
-0.01 
0.00 
-0.01 
-0.02 
-0.02 
-0.03 

0.00 
-0.01 
0.00 

0.00 
-0.01 
-0.02 
-0.01 

0.01
-0.01
-0.01
0.00
0.00
0.00
-0.01
-0.01
-0.03

0.01
-0.01
0.01

0.00
0.00
-0.02
-0.01

The  impact  on  the  consumer  price  index  is  given  in  the  following  table  for  the  various 
options. This is the median price effect across the EU countries included the model for 2030. 
The table shows that there is no significant impact across thee EU countries included in the 
model for 2030. This is true for option D and E quite irrespective of passing through of costs 
or auctioning of F-Gas rights. 

Table A_XIV-8  Change in market prices in 2030 for options D and E (% change to baseline). 

Option D 
No cost 
passing on  

Cost-
pass 

Option E 

Auction  No cost 
passing 
on  

Cost-
pass on 

Auction 

Market prices 

0.00 

-0.01

-0.01

0.00

0.00 

-0.01

EN 

239 

   EN 

 
 
 
 
 
 
 
 
ANNEX XV: Differences between the EmIO-F and the GEM-E3 model 

The  two  macro-economic  models,  EmIO-F  and  GEM-E3,  show  the  same  broad  picture:  the 
GDP,  output  as  well  employment  effects  of  the  proposed  measures  of  F-Gas  abatement  are 
small.  However,  the  model  results  differ  in  some  minor  points  due  to  the  different 
methodologies  used.  The  main  methodological  differences  relate  to  i)  the  model  type 
(Input/Output model vs. Computable General Equilibrium model) and thus different treatment 
of international trade as well as production and consumer behaviour, ii) the implementation of 
the policy scenarios as upstream or mid-stream shocks.  

More  explicitly,  some  of  the  minor  differences  can  be  explained  as  follows.  The  chemical 
sector  shows  slightly  positive  reactions  in  EmIO-F  for  option  D,  while  it  shows  somewhat 
much stronger reactions in GEM-E3, either positive or negative.  The different behaviour of 
the models is because EmIO-F uses a mid-stream approach to F-Gas abatement, i.e. the F-Gas 
content  of  products  is  directly  affected  by  the  policy.  This  implies  that  changes  in  F-Gas 
related policies affect all production activities that require F-Gases or replacement substances 
independent of whether F-Gases are actually emitted or contained and recycled or emitted at a 
later state. Thus a much larger spectrum of sectoral activities than just the chemicals sector is 
affected  by  the  policy  change.  EmIo-F  accounts  for  the  changes  in  investment  and  running 
costs  operators  of  equipment  containing  F-Gases  or  manufacturers  using  F-Gases  in  the 
production process phase. In contrast, GEM-E3 uses an upstream approach, i.e. the producers 
of F-Gases (the chemical sector) are directly affected by the policy.  

Moreover,  the  input-output  model  (EmIO-F)  assumes  fixed  coefficient  production  functions 
and  holds  the  share  between  imports  and  exports  for  production  and  consumption  constant 
across all simulations. In contrast, in GEM-E3 production functions are formulated in a more 
flexible way allowing for price-induced substitution away from products which have become 
more  expensive.  Furthermore,  imports  and  exports  are  also  price  sensitive  in  GEM-E3,  i.e. 
depend on the imposed policy measures. Thus the chemical sector is negatively affected in the 
unilateral case. In a multilateral case such as the one where importers were to be included in 
the  system  Europe  might  gain  competitiveness  compared  to  countries  outside  Europe  and, 
consequently, may increases production and exports.  

There  some  differences  in  the  impact  of  the  F-gas  policies  across  the  various  sectors  as 
obtained with the two models. General trends and magnitude of effects are however similar, 
e.g. the sectors that deliver machinery/equipment and their suppliers (metals, metal products) 
show positive impacts in both models.  A further difference between the models is the way in 
which government revenues of the imposed policy, i.e. the income of auctioning F-gas rights, 
is  recycled  (or  used).  In  EmIO-F  the  government  recycles  revenue  in  a  static  way  i.e. 
according  to  (historical)  spending  patterns  contained  in  the  Input-Output  table.  In  contrast, 
GEM-E3 recycles auction revenues by reducing social security costs paid by employers thus 
generating a dynamic employment effect since labour costs are reduced.   

EN 

240 

   EN 

 
 
 
 
 
 
Annex XVI: State and potential of technology in the different sectors 

This  annex  describes  the  technical  feasibility  of  using  replacement  substances  in  sectors 
currently relying on F-Gases. This analysis is based on Schwarz et al.9 and focuses on HFCs 
as the most important group of F-Gases and where most of the replacement potential is found. 

1. 

COMMON TECHNOLOGY BY SECTORS 

Common  technology  used  in  the  different  F-Gas  sectors  and  subsectors  at  global  scale  is 
listed in an overview table (Table A_XVI-1) and includes conventional F-Gas technology and 
established alternative (halogen-free) technology. 

HCFC  technology  listed  is  today  used  for  new  products  and  equipment  only  in  developing 
countries  and  servicing  of  existing  systems  in  developed  countries.  By  quantity,  the  most 
important  HCFC  used  today  is  HCFC-22  (GWP  1,810;  ODP  0.05).  HCFC  technology  still 
represents the state of technology of new and existing products and equipment in developing 
countries.  In  the  USA,  new  HCFC  equipment  was  sold  widely  until  the  end  of  2010.  In 
Europe, HCFC equipment is becoming more and more outdated technology but still exists to 
some extent. Only reclaimed HCFCs may be used for servicing needs of existing equipment 
and  new  virgin  HCFCs  must  not  be  placed  on  the  market  any  more  (Regulation  (EC)  No 
1005/2009).  

HFC technology is widely applied in all refrigeration, AC, foam, aerosol and fire protection 
subsectors  and  can  be  considered  state  of  technology  in  Europe  and  other  developed 
countries.  The  most  important  HFCs  used  today  include  HFC-134a  (GWP  1,430)  and  the 
blends R404A (GWP 3,922) and R410A (GWP 2,088).101  

Technologies not relying on HFCs, PFCs, or SF6 but on alternative substances with low GWP 
are  also  common  and  widely  used  in  some  sectors  and  subsectors  such  as  domestic 
refrigeration,  industrial  refrigeration,  certain  subsectors  of  commercial  refrigeration  and 
stationary AC, foams, aerosols, solvents as well as the fire protection sector.  

SF6  (GWP  22,800)  is  used,  amongst  others,  in  electrical  switchgear  and  non-ferrous  metal 
industry. SF6-free alternatives are used to some extent for medium-voltage switchgear. In the 
non-ferrous metal industry, which refers to the magnesium industry in EU-27, the use of SF6 
has been banned in large die casting facilities (annual SF6 quantities used >850 kg) by the F-
gas Regulation (Article 8). Small die casting facilities (annual SF6 quantities used <850 kg) 
today partly rely on SF6 but also introduced other technologies, such as the use of HFC-134a 
(GWP 1,430, which is considerably lower compared to the GWP of SF6) or SO2. 

101 If not otherwise stated, the GWP values in this report are from the 4th IPCC Assessment Report (2007). 

EN 

241 

   EN 

 
                                                 
Table A_XVI-1:  State of technology in F-Gas sectors (excluding unsaturated HFCs) 

Sector 

Conventional F-gas 
technology 

Established alternative technology 

-  HFC-134a 

-  HC-600a 

Domestic refrigeration 

Commercial refrigeration 

Centralized systems 

Condensing units 

Stand alone units 

Industrial refrigeration  

Transport refrigeration 

Reefer containers 

Road refrigerated 
transport  

Fishing vessels 

Stationary AC 

Mobile AC 

Road vehicles 

Ships and rail 

Foam 

Fire protection 

Aerosols; OCF 
(excl. MDI) 

Medium voltage 
secondary switchgear 

-  HCFC-22 
-  R404A, R407C 
-  HFC-134a  

-  HCFC-22 
-  R404A, R410A 
-  HFC-134a  
-  CFC-12  
-  HFC-134a 
-  R404A  

-  HCFC-22 
-  R404A, R407C 

-  HFC-134a  
-  R404A 
-  HFC-134a 
-  R404A, R410A, R407C 

-  HCFC-22 
-  R404A 
-  HCFC-22 
-  R410A, R407C 
-  HFC-134a (chillers) 
-  R404A (chillers) 

-  HFC-134a 
-  CFC-12 

-  HFC-134a 

- HFC-152a, HFC-134a 
- HFC-245fa 
- HFC-365mfc/227ea 
- HCFC-141b, HCFC-142b 
- HCFC-22 
-  HFC-227ea 
-  HFC-236fa 
-  HFC-23 
-  HFC-125 
-  HFC-152a 
-  HFC-134a 
-  SF6 

Non-ferrous 
industry  (Mg industry) 

metal 

-  SF6 
-  (HFC-134a) 

N.B. LT = Low Temperature; MT = Medium Temperature 

- R744 in LT-cascade systems 
- R744 for MT and LT 
- R290,  R1270  or  R717  with  secondary 

loop 

systems, sometimes R744 LT-cascade systems 

-  R744  for  a  ice  cream  freezers  and  beverage 

vending machines  

-  HC 

(hydrocarbon,  mainly  R290,  sometimes 

R600a) for bottle coolers and LT cabinets, etc. 

-  ammonia (R717) 
-  ammonia and CO2 cascade  

-  ammonia (R717) 
-  ammonia and CO2 cascade  

- R290 (room AC, chillers, heat pumps) 
- R717 (large chillers) 
- R744 (heat pumps) 

- hydrocarbons (service only) 

(R744 in prototypes) 

- hydrocarbons (pentanes) 

- organic solvents/CO2  

- water-CO2 

- water, water mist, dry chemical, foam aerosols;  
- CO2 
- inert gases 

- hydrocarbons 
- dimethylether 
-  solid insulation 

-  SO2 
- HFC-134a 

EN 

242 

   EN 

 
 
 
 
 
 
2. 

THE MARKET POTENTIAL OF ABATEMENT TECHNOLOGY 

2.1. 

Selection of sector abatement options 

For  each  sector  relying  on  HFCs  today,  cost-effective  and  technically  feasible  abatement 
solutions  were  identified  and  qualitatively  and  quantitatively  compared  to  the  sector-typical 
conventional HFC technology as reference.  

This comparative analysis was guided by the following main criteria:  

-  Energy consumption. 

-  Safety 

-  Maximum reduction potential of CO2-weighted HFC use and emissions. 

-  Cost effectiveness (expressed in abatement cost of €/t CO2 eq).  

2.2. 

Energy efficiency 

Energy  consumption  was  an  essential  selection  criterion.  After 
the  preliminary 
identification of alternative options only those options that show at least equivalent energy 
performance as the reference HFC technology were considered further. This criterion is 
important  because  additional  energy  consumption  would  negatively  impact  the  total  climate 
performance of a system (TEWI) up to the point where reductions of direct F-gas emissions 
by replacement of HFCs could be offset by additional CO2 emissions from energy production 
(indirect emissions).  

In several cases a standard abatement solution might not be able to achieve the same or better 
energy performance as the reference option in any climatic region due to low thermodynamic 
performance.  This  applies  e.g.  to  indirect  refrigeration  or  AC  systems  even  if  they  use 
efficient refrigerants such as propane (R-290) or unsaturated HFCs (HFC-1234yf). In some of 
those cases, the energy consumption of direct HFC systems can be matched with the indirect 
use  of  gases  if  additional  technical  measures  (e.g.  larger  heat  exchanger  surface)  are 
implemented.  Such  technical  optimisation  increases,  however,  the  investment  cost  of  the 
abatement  option.  In  the  foam  sector  poorer  insulation  performance  of  alternative  blowing 
agents  must  be  compensated  by  increased  foam  thickness,  which  likewise  raises  the  cost 
compared to HFC based technology. In those cases an abatement option is considered in the 
analysis but with the additional investment costs accounted. 

Therefore, the comparative analyses include only abatement options when these can, with 
or without technical optimisation, require equal or less energy for operation.  

2.3. 

The concept of penetration rates 

Existing  and  future  market  penetration  is  a  key  parameter  for  the  calculation  of  the 
consumption  and  emission  reduction  potential  of  any  technical  alternative  to  current  HFC 
technology.  

The penetration rate is defined as the maximum market potential of a technical choice 
(i.e.  abatement  option)  to  replace  new  products  or  equipment  relying  upon  HFCs  in  a 
particular  sector.  Penetration  rates  are  given  for  each  abatement  option  based  on  technical 
feasibility  to  replace  existing  HFC  technology  by  a  specific  alternative  technology.  A 

EN 

243 

   EN 

 
penetration rate of 30% in 2015 means that 30% of the new HFC units installed in 2015 could 
potentially be replaced by units of this particular abatement option.  

However, any abatement option is rarely universally applicable to a sector. Thus, maximum 
market  penetration  for  replacement  of  current  HFC  technology  in  a  specific  sector  in  2015, 
2020, 2025 or 2030 can only be met by aggregation of two or more abatement options.  

2.4. 

Constraints to market penetration 

Limitations  of  each  abatement  option  are  due  to  safety,  cost  and/or  efficiency  implications, 
and further parameters. It is therefore necessary to consider the use of each relevant abatement 
option for a specific sector within the context of the various limiting factors.  

– 

Safety constraints 

The application of refrigerants102 is generally controlled by national regulations, such as those 
dealing with the use of hazardous substances, buildings and so on. Generally such regulations 
are  non-specific  in  terms  of  how  refrigerants  can  be  applied  and  aim  towards  “safe  use”. 
However,  in  many  countries,  safety  standards  and  codes  of  practice  are  available  which  are 
more specific in the manner by which refrigerants are applied; noting also that such standards 
and codes are often not legally mandatory but are considered as “best practice”.  

Many of the currently used F-Gas refrigerants have a safety classification of lower-toxicity/no 
flame  propagation  (i.e.,  class  “A1”).  This  means  that  they  can  be  applied  within  most 
situations without consideration of quantity limitations. However, many abatement solutions 
are flammable or have higher toxicity or both (typically “A2”, “A3” and “B2” classifications), 
which results in limitations in terms of the quantity of refrigerant permitted within different 
locations. As such,  where  standards  specifically  limit  certain  technical  abatement options in 
particular locations, this can impact on the penetration rate.  

As  an  example,  R717  (class  B2)  is  not  permitted  to  be  used  in  direct  systems,  so  the 
maximum penetration for room air conditioners would be 0%, whilst R290 (class A3) can be 
used  in  direct  systems  provided  the  charge  size  is  below  a  certain  quantity.  Thus,  the 
penetration  would  be  more  than  0%  but  less  than  100%  because  it  would  not  ordinarily  be 
possible to use R290 in systems that require a large charge. 

Whilst safety standards may partially or wholly restrict certain abatement options from being 
used in certain locations, it is possible to redesign systems in order to ensure the refrigerant is 
kept within an alternative location or reduce the quantity of refrigerant in a system. This may 
be applicable where two refrigerant circuits are used instead of one, or an indirect system is 
employed instead of a direct system. 

– 

Efficiency constraints 

As  mentioned  above,  it  was  a  basic  principle  for  the  analysis  that  any  abatement  option 
considered  should  not  risk  offsetting  refrigerant-related  emissions  reduction  by  consuming 
more  energy.  Furthermore,  in  many  countries,  there  are  –  or  will  be  –  minimum  efficiency 
standards  for  e.g.  room  AC  systems.  Therefore  abatement  options  can  only  be  considered 

102 Penetration rates are assessed not only for refrigerant  using systems but also for fire protection equipment, 

foams, and aerosols. Refrigerants, however, are by far the largest application of HFCs.  

EN 

244 

   EN 

 
                                                 
where  systems  would  achieve  at  least  the  same  level  of  efficiency.  In  general,  most  of  the 
abatement  options  under  consideration  can  already  provide  at  least  the  same  level  of 
efficiency as the existing refrigerants.  

In cases, where abatement options have a poorer efficiency than the existing HFC technology 
when  used  in  comparable  systems,  additional  materials  and  components  may  be  required  to 
bring the efficiency up to the required level, and these may incur costs. In particular, where 
indirect systems are used instead of direct systems and the construction is such that efficiency 
may be lost, increases in exchanger surface areas, for example, may be necessary to achieve 
the target level. 

However, in some cases abatement options may not be able to achieve the required efficiency 
level (even with optimization), in which case the penetration rate would be limited.  

As an example, the abatement option transcritical use of CO2 (which is more energy efficient 
than  most  HFC  systems  in  geographical  zones  with  moderate  climate  could  be  used  in  AC 
systems  within  temperate  climates.  The  penetration  could  reach  100%  there,  but  in  hot 
climates  the  ideal  cycle  efficiency  of  CO2  (R744)  would  still  be  below  the  minimum 
efficiency of such air conditioners and therefore the penetration would be 0%. In the current 
analysis  the  penetration  rate  would  be  reduced  according  to  share  of  moderate  and  hot 
climates.  As  an  example,  for  Europe  the  penetration  rate  would  be  halved  compared  to  the 
technical  maximum  because  CO2  systems  are  energetically  superior  north  of  the  Alps  but 
inferior south of the Alps. 

– 

Cost constraints 

In  principle  any  technically  feasible  abatement  option  can  be  used  for  any  application, 
provided unlimited funds are available to implement it. However, the market may not accept 
products  at  considerably  higher  cost  (price)  than  existing  products.  The  cost  implication  of 
using  different  abatement  options  which  may  be  affected  by  several  different  parameters, 
including  safety  requirements,  desired  efficiency,  system  complexity  and  special  materials. 
Therefore  it  is  important  to  establish  situations  where  abatement  options  may  result  in 
excessively high cost such that the penetration potential of that abatement options would be 
limited.  

– 

Availability of materials and components 

Some parts are specific to certain refrigerants, e.g. compressors. Whilst it is feasible to use, 
e.g.  R744/CO2  in  rooftop  air  conditioners,  no  suitable  compressors  are  currently  available. 
Reciprocating  compressors normally used for commercial refrigeration could be applied but 
the  efficiency  would  be  much  lower  than  the  equivalent  (scroll)  compressors  that  an  R22 
system may use. Another example is electrical components for flammable refrigerant systems. 
HC chillers need to use “protected” electrical devices to avoid ignition of a leak but certain 
components  e.g.  low  flow  switches  are  not  available,  except  for  maybe  oil  rig  applications 
which would lead to overly high costs for use in refrigeration and AC applications. Today not 
every system could be build with each of the abatement options using “off the shelf” parts and 
the  systems  would  need  to  be  improvised,  which  could  lead  to  high  costs  and/or  low 
efficiency.   

EN 

245 

   EN 

 
 
– 

Availability of refrigerants and blowing agents 

Whilst  hydrocarbons,  CO2,  ammonia  or  water  are  available  in  sufficient  quantities,  newly 
developed unsaturated HFCs are not yet commercially available of the necessary scale today. 
However,  these  gases  show  promising  prospects  for  replacement  of conventional  HFCs  and 
hence  unsaturated  HFCs  are  included  in  the  comparative  analyses  in  this  study  wherever 
possible.  

This  applies  particularly  to  HFC-1234yf  (refrigerant)  and,  to  minor  extent,  HFC-1234ze103 
(foam  blowing  agent,  aerosol  propellant,  refrigerant).  The  penetration  rates  of  HFC-1234yf 
will  still  be  low  by  2015,  which  is  the  first  year  for  which  production  at  large  scale  is 
announced.  As  the  market  availability  can  be  assumed  to  develop  over  time,  the  accurate 
quantitative assessment of the penetration rates is key condition for the estimation of the HFC 
reduction potential in the period until 2030. 

– 

System complexity and design know-how  

Systems  running  on  ODS,  HFCs  and  HFC  blends  are  of  similar  complexity  and  design.  In 
contrast,  design  and  construction  of  a  refrigeration  or  AC  system  running  on  flammable 
refrigerants or transcritical CO2 systems require additional knowledge and training. Therefore, 
design  engineers  and  technicians  need  to  acquire  additional  know-how  in  order  to  install 
abatement technology properly.   

2.5. 

Determination of penetration rates 

In estimating the maximum potential penetration rate, several factors are considered. For each 
of the constraints considered above, the proportion ( χ ) for each constraint ( i ) – in terms of 
refrigerant  quantity,  not  necessarily  number  of  systems  –  of  the  sector  that  could  not 
accommodate the specific abatement option due to each is estimated.  

These  factors  are  estimated  for  the  year  2030,  which  should  therefore  account  for  both  (i) 
anticipated technical developments and (ii) market maturity. For example, where charge size 
limits are a limiting factor, it can be assumed that research and development efforts over the 
next 20 years will reduce specific charge sizes (kg/kW) to below today's lowest values, or that 
system components for certain abatement options are widely available such that the product 
development and small production scale costs have been eliminated from the purchase price. 

Thus, the overall maximum penetration rate is estimated from 1 – max{ iχ }.  

i.e.,  the  maximum  possible  penetration  under  business-as-usual  should  be  based  on  the 
maximum proportion of a sector unable to accommodate the abatement option for any of the 
given  constraints.  For  each  abatement  option  the  proportions  ( χ )  are  based  on  expert 
knowledge of the characteristics of the systems and equipment, system design characteristics, 
requirements  of  safety  standards,  technology  requirements,  etc.  and  coupling  these  with 
characteristics of the refrigerants under consideration. 

103 Honeywell, the manufacturer of HFC-1234ze, stated that in 2011 HFC-1234ze was “commercially available”. 
It should be noted that by May 2011 this unsaturated HFC was produced at a “small-scale production 
facility”. In May 2011 the company announced to triple the capacities (Honeywell News Release, May 
12, 2011).  

EN 

246 

   EN 

 
                                                 
Whilst the constraints detailed above are mechanistic, another constraint may be included to 
account for the “willingness” of the market to adopt a given abatement option, which may be 
a function of the additional considerations necessary to suitably apply a particular abatement 
option.  These  considerations  may  include  having  to  get  special  training  for  technicians, 
interpretation  of  complicated  standards  and  so  on.  Using  this  approach  the  maximum 
penetration rate could be scaled down. 

Whilst the maximum penetration rate detailed above represents the best estimate for 2030, the 
penetration  rates  for  the  intermediate  dates  –  2015,  2020  and  2025  –  are  obtained  from 
interpolation  between  the  current  status  (i.e.,  penetration  of  each  abatement  option  in  2010) 
and the 2030 penetration, but also accounting for the typical lifetime of the equipment within 
the sub sector. 

It must be noted here that there is no generally accepted methodology for the determination of 
penetration rates, and that the rates are subjective and with uncertainties. Evidently, nobody 
can  exactly  forecast  and  quantify  the  technical  development  in  the  coming  20  years.  The 
penetration rates for the numerous individual technical solutions rely on the best knowledge 
of the project experts. The assessment is inter alia a result of detailed literature study, and of 
intensive discussion with the industries concerned104.  

2.6. 

Combination of penetration rates (“penetration mix”)  

It should be pointed out that in reality a sector may comprise a number of different abatement 
options.  The  mix  of  different  technical  solutions  cannot  necessarily  be  represented  by  the 
maximum penetration values for each abatement option since the same constraints that apply 
to one abatement option may apply to another (for example, flammability, etc). Therefore the 
maximum  penetration  rate  of  each  abatement  option  for  any  one  sector  is  the  maximum 
penetration rate of any one of the abatement option within each of the groups listed in Table 
A_XVI-2  (refrigerants  only).  The  groups  represent  the  abatement  option  that  are  dominated 
by the same constraints and which are hence mutually exclusive.  

For  example,  the  penetration  rates  of  two  flammable  refrigerant  abatement  options  in  direct 
systems  cannot  be  added  since  flammability  is  the  same  limiting  factor.  However,  the 
penetration  rates  for  Group  1/2  and  Group  4  can  be  added  since  Group  4  abatement  option 
could be applied where it would be impossible to use Group 1 or 2.  

104  For  example  see  “Remark  on  the  replacement  potential  of  hydrocarbon  refrigerants  in  split  room  air 
conditioners”  following  the  Data  Input  Sheet  “Stationary  AC  –  single  split  type”  in  annex  IV  which 
explains  in  detail  the  penetration  rate  assessment  for  room  air  conditioners  with  R-290.  Room  air 
conditioners  with  R-290  are  the  abatement  technology  with  the  highest  individual  HFC  reduction 
potential in the study. It should be noted that the assumptions for the relevant variables of R-290 room 
air conditioners are in line with the draft Commission Regulation implementing Directive 2009/125/EC 
of  the  European  Parliament  and  of  the  Council  with  regard  to  ecodesign  requirements  for  air 
conditioners and comfort fans.  

EN 

247 

   EN 

 
                                                 
Table A_XVI-2:   Classification of abatement options by limiting factors  

Group 1 

Highly flammable 

Group 2 

Flammable 

Group 3 

Moderate ambient only 

Group 4 

Indirect operation 

Highly efficient 

Group 5 

Indirect operation 

Normal efficiency 

Group 6 

Poor performance, high cost 

R600a 

R290/R1270 

Unsaturated HFC 

R717 

R744 

R290/R1270 + R744 cascade 

R717 + R744 cascade 

HC + evaporation secondary (e.g. R744) 

Unsaturated HFC+ evaporation secondary (e.g. R744) 

HC + liquid secondary 

R717 + liquid secondary 

Unsaturated HFC+ liquid secondary 

Air cycle 

Liquid absorption 

Solid adsorption 

The first objective for each sector is the identification of those technically feasible alternative 
technologies that provide highest possible emission or demand reduction potential. The cost 
of  these  technologies  is  not  the  primary  but  the  secondary  selection  criterion,  which 
determines  the  order  of  different  alternative  options  in  the  mix.  From  this  it  follows  that 
abatement  options  relying  upon  low  or  no  GWP  technologies  are  the  preferred  choice. 
However, solutions with GWP which are lower than the ones used today, such as blends of 
HFCs  with  unsaturated  HFCs  (GWP  ~700)  or  substances  like  HFC-32  (GWP  675)  are  also 
considered for the assumed penetration mix, if such solutions, in a given year, are either the 
only  alternative  to  high-GWP  HFCs,  or  can  further  increase  the  reduction  potential  of  low-
GWP  options.  According  to  our  analysis,  only  in  few  sectors  (passenger  ship  air  AC,  room 
AC  <12  kW,  and  heat  pumps105)  inclusion  of  such  solutions  could  increase  the  reduction 
potential of the low-GWP options to achieve the highest possible reduction effect until 2030. 
In  all  other  sectors,  the  combination  of  low-GWP  solutions  alone  represented  the  highest 
possible reduction potential.  

105  In  the  sub  sectors  of  room  air  conditioners  <12  kW  (movable  and  single  split  systems)  the  additional 
reduction effect from inclusion of HFC-32 lasts only until 2029 because in 2020 the penetration mix of 
low-GWP technologies has reached 100% (lifetime 10 years).  

EN 

248 

   EN 

 
 
                                                 
2.7. 

Key abatement options by sectors 

– 

Refrigeration and AC subsectors 

In  most  refrigeration  subsectors  (Table  A_XVI-3)  the  penetration  mix  of  abatement  options 
can reach 100% in or before 2030. Exemptions include the industrial refrigeration sector and 
refrigeration in fishing vessels.  

Table A_XVI-3:   Key  abatement  options  in  the  refrigeration  sectors  and  their  aggregated  market 

penetration potential in 2030 

Refrigeration and AC 

Key abatement options 

Market penetration of abatement options 
(penetration mix) in 2030 (%) 

Domestic refrigeration 

R600a  

95(100*) 

CO2  (R744)  

R1234yf 

Commercial refrigeration 

Centralized systems 

R290 indirect + CO2 cascade 

R290 + CO2 + CO2 cascade 

CO2 

Condensing units 

R290 direct 

R290 indirect 

CO2  

Stand-alone units 

R290 direct 

Industrial refrigeration  

Small equipment 

Large equipment  

Transport refrigeration  

CO2  

NH3 

NH3 

Refrigerated trucks 

R290 direct 

Refrigerated vans 

CO2  

CO2  

HFC-1234yf 

Reefer containers 

CO2  

Fishing vessels 

NH3 + CO2 cascade 

5 

0 

90 

10 

0 

40 
30 
30 

85 
15 

95 

95 

80 
20 

50 

50 

100 

95 

* 100% market potential of hydrocarbon refrigerant (R-600a) is assumed already for 2015. 

In many AC subsectors (Table A_XVI-4), the penetration mix of abatement options can reach 
100% in or before 2030. 

EN 

249 

   EN 

 
Table A_XVI-4:   Key abatement options in the stationary and mobile AC sectors and their combined 

market penetration potential in 2030 

AC 

Key abatement options 

Market penetration of abatement options 
(penetration mix) in 2030 (%) 

Stationary AC 

Moveable AC 

Single split AC 

Multi split AC 

Rooftop AC 

R290 direct 

CO2  

HFC-1234yf 

R290 direct 

CO2  

HFC-1234yf 

R290 indirect 

CO2  

HFC-1234yf 

R290 indirect 

CO2  

R290 + evaporating secondary 
(CO2) 

Small chillers 

R290 direct 

CO2  

NH3 

Large chillers 

R290 direct 

Centrifugal chillers 

CO2  

NH3 

R718 

R290 

HFC-1234ze 

R718 

Heat pumps 

R290 direct 

CO2  

HFC-1234yf 

Mobile AC – road vehicles 

Passenger 
trucks) 

Buses 

cars 

(incl. 

HFC-1234yf 

R744 

HC indirect 

HFC-1234yf 

R744 

HC indirect 

40 

20 

40 

40 

15 

45 

70 

30 

0 

65 

35 

0 

60 

20 

20 

15 

0 

60 

25 

20 

50 

30 

60 

20 

20 

(100) 

(100) 

0 

100 

0 

0 

EN 

250 

   EN 

 
Mobile AC – ships and rail vehicles106 

Passenger ships  

Blends w unsat HFCs 

Cargo ships 

NH3-brine 

Blends w unsat HFCs 

Rail vehicles 

R744 

90 

90 

10 

60 

106 Abatement options for ships and rail vehicles have been assessed for Europe only but not for the remaining 

A2 countries and for A5 countries, due to very limited data availability.  

EN 

251 

   EN 

 
 
 
                                                 
– 

Foam subsectors 

In all foam subsectors (Table A_XVI-5), current HFC blowing agents could be substituted by 
abatement options in or before 2030.  

Table A_XVI-5:   Key  abatement  options  in  the  foam  subsectors  and  their  combined  market 

penetration potential in 2030 

Foam blowing agents 

Key abatement options 

Market penetration of abatement options 
(penetration mix) in 2030 (%) 

Insulation foams of PU and XPS for the construction sector  

Sandwich panels with 
metal facings, continuous 
(CME) 

HC 

Unsaturated HFC 

Sandwich panels with 
metal facings, 
discontinuous (DIP) 

Sandwich panels with 
flexible facings, 
boardstock (CFF) 

Spray foam (SPR) 

HC 

Unsaturated HFC 

HC 

Unsaturated HFC 

Unsaturated HFC 

H2O-CO2  

XPS Foam Boards (XPS) 

Unsaturated HFC 

HC incl. organic solvent+CO2  

PU Foam for refrigeration applications and integral skin 

Domestic refrigeration 
(DOR) 

Commercial refrigeration 
(COR) 

Refrigerated trucks, 
reefer containers (RTRU) 

Integral foams (INT) 

HC 

HC 

Unsaturated HFC 

HC 

Unsaturated HFC 

H2O 

Unsaturated HFC 

90 

10 

90 

10 

90 

10 

50 
50 

85 

15 

100 

50 

50 

90 

10 

50 

50 

EN 

252 

   EN 

 
 
 
– 

Fire protection and technical aerosols 

Table  A_XVI-6  includes  technical  aerosols107  (excluding  MDI108)  and  the  fire  protection 
sector. In fire protection, the key abatement option could fully substitute the use of HFC-23 
(GWP  14,800)  as  fire  extinguishing  agent  in  or  before  2030.  The  use  of  HFC-227ea,  in 
contrast, can be replaced in most but not all applications.  

With  regard  to  technical  aerosols,  it  is  estimated  that  the  market  penetration  potential  of 
unsaturated HFCs will cover 95% of the applications.  

Table A_XVI-6:   Key abatement options in the aerosol and fire protection sectors  and their market 

penetration potential in 2030 

Fire protection 

Key abatement options 

Technical aerosols 

Fire protection 

Equipment with HFC-
227ea 

FK 5-1-12 

Equipment with HFC-23 

FK 5-1-12 

Technical aerosols 

Unsaturated HFCs 

Market penetration of abatement options 
(penetration mix) in 2030 (%) 

90 

100 

95 

107  There  is  currently  no  definition  of  technical  aerosols  in  the  legal  text.  FEA  (Fédération  Européenne  des 
Aerosols)  suggests  the  following  definition:  Technical  aerosols  are  aerosol  dispensers  used  in 
maintenance,  repair,  cleaning,  testing,  disinsecting,  manufacturing,  installation  and  other  applications 
where a non-flammable formulation is required for safety reasons. (Communication to Öko-Recherche, 
15 May, 2011). This definition also separates novelty aerosols from “technical” aerosols. 

108 HFCs are used in Metered-Dose Inhalers for the treatment of asthma and other respiratory diseases. Health 
aspects related to the application of MDIs as compared to potential abatement technology need specific 
investigation.  

EN 

253 

   EN 

 
 
                                                 
– 

Electrical switchgear and magnesium die casting 

Since in magnesium die casting large facilities (SF6 use >850 kg/y) already were required to 
substitute the use of SF6, alternative options for small facilities are readily available and could 
reach full market penetration earlier than 2030. In the switchgear sector SF6 is currently the 
only technical solution for voltage >52 kV. Below 52 kV, for the so-called medium voltage, 
SF6  or  air  is  used  at  the  interface  between  high  and  medium  voltage  (primary  level);  at  the 
interface  between  medium  and  low  voltage  (secondary  level)  SF6  clearly  dominates  the 
market (ca. 98%) but solid insulation is technically possible today.   

Table A_XVI-7: Key abatement options in the electrical medium-voltage secondary switchgear and 

magnesium casting sectors and their market penetration potential in 2030  

Other sectors 

Key 

abatement options 

Market penetration of abatement 
options (penetration mix) in 2030 
(%) 

Medium voltage secondary switchgear 

Solid insulation

Magnesium die casting and recycling 

HFC-134a, SO2

40 

100 

EN 

254 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex XVII: Assessment of indirect impacts on sales  

Table A_XVII.1 Increase in sales compared to baseline (Investments) by subsector (million €/year) 

Domestic Refrigeration 
Commercial hermetics 
Condensing units 
Centralized systems 
Industrial Ref small 
Industrial Ref large 
Refrigerated Vans 
Refrigerated Trucks 

Fishing vessels 

Cargo ship AC 
Passenger ship AC 
Bus AC 
Truck AC 

Moveable AC systems 

Split AC systems 
Multi split AC systems 
Rooftop AC systems 
Chillers 
Centrifugal chillers 
Fire protection 227ea 
Fire protection 23 
Aerosols 
XPS-152a 
XPS-134a 
PU other 
HFC-23 by-product 
SUM 

B
0
81
753
774

0
0
0
0

0
0
0
0
0

0
0
0
0
0
0
0
0

0
3
0

0
0
1611

C
0
0
0
0
0
0
0
0

0

0
0
0
0

0

0
0
0
0
0
0
0
0
0
0
0
0
0

D
2
81
753
774
67
499
18
142

6
3
0
35

2

7

158
70
67
339
3
5
0
0
3
3
3
0
3039

E 
0 
71 
602 
714 
5 
39 
0 
17 

0 
0 
0 
0 
0 

7 
158 
61 
67 
339 
0 
0 
0 
0 
0 
0 
0 
0 
2080 

EN 

255 

   EN 

 
 
 
 
 
 
  
 
 
 
 
Table  A_XVII.2.  Change  in  sales  in  2030  if  increased  investment  costs  (and  other  costs)  are  fully 
passed on to consumers (%) 

Condensing units commercial refrigeration 
Centralized Systems Commercial Refrigeration 
BUS AC 
Trucks and trailers AC 
Single Split Room AC 
Multi split AC 
Industrial refrigeration large 
Chillers 

B 
0.3%
1.8%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%

C 
0.0% 
0.0% 
0.0% 
-0.4% 
0.0% 
0.0% 
0.0% 
0.0% 

D 
-0.3% 
-1.8% 
-0.8% 
-0.1% 
-0.6% 
-0.3% 
0.5% 
-0.1% 

E 
-0.3% 
-1.8% 
0.0% 
0.0% 
-0.6% 
0.0% 
0.5% 
-0.1% 

Table  A_XVII.3.  Reduction  in  sales  (investments)  compared  to  Table  A_XVII.1.  Second-order 
effects in million Euros. 

Domestic Refrigeration 
Commercial hermetics 
Condensing units 
Centralized systems 
Industrial Ref small 
Industrial Ref large 
Refrigerated Vans 
Refrigerated Trucks 

Fishing vessels 

Cargo ship AC 
Passenger ship AC 
Bus AC 
Truck AC 

Moveable AC systems 

Split AC systems 
Multi split AC systems 
Rooftop AC systems 
Chillers 
Centrifugal chillers 
Fire protection 227ea 
Fire protection 23 
Aerosols 
XPS-152a 
XPS-134a 
PU other 
HFC-23 by-product 
SUM 

Impact main sectors 

B

C

D

E

-2.44
-13.6

0.00
0.0

-2.44
-13.7

-1.91

-12.7

0.0

0.0

2.6

0.2

0.0
0.0

0.0
0.0

0.0

0.0
0.0

0.0
0.0

0.0

-0.3

0.0

-1.0
-0.2

-0.5

0.0
0.0

-1.0
0.0

-0.5

-16.0
-1.0%

0.0

-15.9
-15.5
0.0% -0.6% -0.8%

EN 

256 

   EN 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table  A_XVII.3  shows  the  reduction  in  sales.  E.g  for  option  D  sales  of  condensing  units 
would go up by 753 million per year in 2030 (Table A_XV.1). As a result of the increase in 
costs demand would be 2.44 million lower and the net increase in sales would be smaller (753 
minus 2.44 million €). The impact for the main sectors would be a second order reduction in 
the  increase  in  sales  of  1%  or  less.  The  sectors  represent  87  to  95%  of  the  total  change  in 
sales.  

EN 

257 

   EN