The forthcoming F-GAS Regulation review: counterproposals

The forthcoming F-GAS Regulation has been drafted and published, however it has created several questions in the Industries affected (Chemicals / HVAC-R)) whether its application is enforceable as it is. I have ideas to share in this regard.

Description

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Speaker

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Video

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When & Where

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Wed, 12.10.2022, 12:00 – 12:20

Details

Format: Lecture

Language: English

Description

The presentation will be about the F-GAS Regulation (AS is vs. Revision Proposal) and how other EU Environmental Regulations (i.e. REACH) overlap.
A detailed analysis of the existing F-GAS Regulation, including its shortcoming in terms of Customs Controls which generated the widely spread illegal trade of Refrigerants, the journey to bring the adequate level of Customs Controls to edge the illegal trade and a step by step guide to the proposal made by DG Clima in the forthcoming review.
Even more so, it is important to also assess how other EU Environmental Regulations overlap and sometimes diverge in terms of application: as an example, the requirement under the existing F-GAS Regulation for Non-EU undertakings to have an EU EORI number, thus becoming the IoR (Importer of Record) under the CCU (Customs Code of the Union).
This is creating a lot of confusion as under REACH Regulation, a NON-EU Undertaking can not be the IoR. And the list goes on.
The most important take away is that the Regulatory Body in the EU sometimes lacks in co-ordination and also practical know-how.
What the presentation aims to achieve is to bring awareness of the practical aspects of the EU Regulation and to direct this awareness as a unified message from the industry to the EU Commission. In other words: a more restrictive F-GAS Regulation is welcome as long as it is implemented learning from the problems caused in the past. I am making some proposals which should be taken into account in the forthcoming EU Regulation and shared within the Industry, so that they can be taken into account. My personal position is not to oppose to the Proposal as such, however it is important that it is carried forward with the adequate understanding of the "as is" business. in UK I have seen Court Cases where the Judge needed to admit that the Regulation was not easily accessible. This is another key topic which is important. If the legislation is not easily accessible, the Customs has a specific role in its enforcement.

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Speaker

Davide Palumbo

Managing Director

NAVIS INTERNATIONAL TRADE & CONSULTING

Tim Vink

Independent Consultant

NAVIS INTERNATIONAL TRADE & CONSULTING