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EU Climate Change: Commission Consults on the Revised Format of F-gas Labels

This blog was originally posted on 22nd May, 2024. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY DIEUDONNÉ YMEDJI, SENIOR REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

Introduction

On the basis of the new F-Gas Regulation (EU) 2024/57 which aims to further cut the emissions of F-gas in the EU, the European Commission launched on 07 May 2024, a public consultation on the adoption of the revised reporting format of the labels for certain products and equipment containing F-gases or whose functioning relies upon such gases.

The proposal is the first of several implementing acts to be enacted by the Commission in order to ensure uniform conditions for the implementation of the new F-gases Regulation across the Union.

The proposal is open to feedback until 04 June 2024 and will replace the existing Commission Implementing Regulation (EU) 2015/2068 on F-gas labeling format pursuant to Regulation (EU) No 517/2014.

Scope of the Revision

This Commission’s initiative sets specific provisions regarding the appearance of labels and the wording of information to be indicated on them as referred to in Article 12(3) and (5) of the new F-Gas Regulation.

The proposal further specifies measures to ensure the visibility and readability of such labels regarding their layout and placement and taking into account space constraints on certain types of products.

From 01 January 2025, a label on any product listed in Article 12 (1) that contains F-gases or whose functioning relies upon such gases shall:

Indicate that the equipment or product ‘contains fluorinated greenhouse gases’;
Include the quantity in weight and in CO2 equivalent, along with the GWP of the F-gas;
Be designed so as to ensure that it remains securely in place on the product or equipment; and
Be legible under normal operational conditions, at the time of the placing on the market and throughout the lifecycle of the product.

For refrigerating equipment, air conditioning and heat pumps insulated with foam blown with F-gases, the label must include the text: ‘Foam contains fluorinated greenhouse gases’ on the label.

Overall, the information on the label shall be legible, and stand out clearly from the background of the label. The label must be located where possible close to existing nameplates or product information labels of the product or equipment that contains the F-gas.

Compared to Regulation (EU) 2015/2068, the proposal provides for additional methods to present the required labeling information to users of small items falling within the scope of Article 12(1) of Regulation (EU) 2024/573. In this regard, the new Article 1(10) stipulates that, where the size of a product does not allow for the legibility of the full information referred to in Article 12(3), the text ‘Contains fluorinated greenhouse gases’ in the languages already used on the product may be conveyed by a digitally readable link.

A final innovative measure in the proposal is the introduction of new labeling provisions which require the placing on the outer packaging of metered dose inhalers or sale packaging of medical devices within the scope of Regulation 2017/745, of the indication ‘Contains fluorinated greenhouse gases’. This indication may be complemented by the statement ‘with reduced impact on the climate’, where such products contain fluorinated greenhouse gases with a global warming potential below 150.

What’s Next?

The proposal is planned for adoption by September 2024.

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