Joint industry letter on pre-charged equipment exports

All signing Industry Associations have been supportive of the EU HFC phase-down from the beginning and they have continuously worked to ensure its success. For instance, the EPEE Gapometer project shows that the phase-down is ambitious but feasible, as long as the market moves away from high global warming potential (GWP) refrigerants as a matter of priority. However, despite these efforts, we believe that the effects of the phase down on the market are very serious. We would like to raise your attention on the Article 15 of Regulation (EU 517/2014), its interpretation and application by DG CLIMA, as well as on the consequences that it entails. This interpretation requires the use of HFC quota for exports of equipment produced in the EU and pre-filled with HFCs (so-called ‘precharged’ equipment).