EPEE and Eurovent would first like to emphasise the need to consider the incompatibility of the proposed Ecodesign requirements and the upcoming revision of the F-gas regulation which creates uncertainty for manufacturers. If a ban or phase down of HFC is enforced, all or most of the product ranges will need to be re-designed. For example, it is currently uncertain if the proposed energy efficiencies and required safety can be achieved with alternative refrigerants.
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