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REGULATORY UPDATE

European Commission Proposes HFC Phase-down

On November 7, 2012 the European Commission (EC) submitted the much anticipated proposal to replace the existing regulation on fluorinated greenhouse gases (F-gases) with the objective of significantly reducing emissions of the gases in the European Union (EU). The EU hopes to accelerate the adoption of more climate-friendly alternatives and to stimulate new global action to reduce F-gas emissions.

Why is this new proposal necessary?
By 2050, the EU must reduce its overall greenhouse gas emissions by 80-95% from a 1990 base. The European Commission's low carbon roadmap sets out a cost-efficient method to achieve this goal through contributions from all sectors and greenhouse gases (GHGs).

F-gases are increasingly used in the EU, and world-wide, in equipment for refrigeration and air conditioning, insulation foams, and fire extinguishers. F-gas emissions in the EU have risen by 60% since 1990 while all other greenhouse gases have been reduced. The growth of HFC concentrations in the atmosphere, including HFC-227ea, is accelerating.

What will the new regulation accomplish?
The proposed Regulation aims to reduce F-gas emissions by two-thirds of today's levels by 2030. The main new element is a phase-down measure that from 2015, limits the total amount of - Hydrofluorocarbons (HFCs) – that can be sold in the EU. HFC sales will be reduced to one fifth of today's sales by 2030. Producers and importers will initially be allocated rights to place HFCs on the market. The regulation also bans the use of F-gases in some new equipment, such as HFC-23 in fire suppression.

Recent studies show that there are a number of alternatives to the powerful climate warming F-gases that are technically sound, safe to use, and cost-efficient.

Impacts of the proposal on the fire suppression market

  1. HFC-227ea, is targeted in the overall scope of the regulation under the HFC phase-down.
  2. HFC-125 and HFC-236fa are also targeted in the overall scope of the regulation under the HFC phase down.
  3. HFC-23 will be prohibited from being placed on the market after Jan.1, 2015.
  4. FK-5-1-12 (3M™ Novec™ 1230 Fire Protection Fluid) is not subject to this regulation.

Under the cap and phase-down proposal, HFC-producers will be provided an established quota for HFCs and will have difficult decisions to make. The quota will be in CO2 equivalent and, therefore, manufacturing some HFCs will put a bigger dent in that quota than others. This framework does not favor HFCs in fire suppression because HFCs sold into fire suppression have higher global warming potentials than HFCs sold into large sectors such as foam blowing and refrigeration. For example, an HFC producer would consume the same percentage of a quota by making either one ton of HFC-227ea , three tons of HFC-245fa, five tons of HFC-32 or one-third ton of HFC-236fa. This dynamic will put a substantial amount of uncertainty on the future supply and cost of HFCs sold into fire suppression. Because the fire suppression market already has cost effective substitutes available, the transition away from HFCs will be more seamless than other sectors.

For additional information on Novec 1230 fluid or regulatory issues impacting the fire suppression market, please contact 3M.

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