15. Recommendations

15.1 Recommendations for the Nordic Council of Ministers

• Initiate an information campaign to create awareness of the detrimental environmental impacts when fluorinated refrigerants are emitted instead of being correctly recovered and disposed of accordingly, as well as any potential health risks from direct exposure.
  • Consider making the campaign threefold. The first should focus on the practitioners and ensure they are aware of the environmental impacts of improper disposal as well as any potential health risks.
  • The second part of the campaign should target private citizens to discourage the unauthorised handling of domestic RACHP appliances.
  • The third part of the campaign should target practitioners in other sectors to raise awareness of the necessity of ensuring qualified and educated personnel are involved in the process and ensuring that they are responsible for the recovery of refrigerants, e.g., in demolition and renovation projects.  
• Encourage development and implementation of a voluntary labelling scheme to explain and raise awareness about HFOs and HFCs being PFAS. Introducing a voluntary labelling scheme that informs consumers and industry stakeholders about the PFAS content in HFOs and HFCs is a significant step towards promoting transparency, informed decision-making, and responsible product usage. The scheme can encourage manufacturers and suppliers to provide detailed information about the presence of PFAS in their products, allowing end-users to make more sustainable choices.
  • The Nordic countries can collaborate with experts, industry representatives, and environmental organisations to develop comprehensive labelling guidelines that accurately reflect PFAS content in HFOs. In the engagement with relevant industries, positive impacts on market reputation and consumer trust can be emphasised to encourage participation. By working together to establish and promote the labelling scheme, Nordic countries can set a positive example for international collaboration on addressing the challenges of HFOs.

• Commission a study to examine ultra-short PFAS, such as TFA, to increase the knowledge of environmental and health exposure risks associated with these substances. Ultra-short PFAS has not yet been well studied and is accumulating in water bodies while the consumption of HFOs is continuously increasing. The study can provide valuable insights into the sources, distribution, and accumulation patterns of ultra-short PFAS, enabling informed decisions about their management and providing a foundation for effective policy-making and proactive measures to mitigate the potential risks associated with these substances. Moreover, by undertaking this research, the Nordic countries can assume a leadership role in addressing a knowledge gap that has implications beyond our region, influencing global research priorities and fostering international cooperation.

EU Perspective

• Await upcoming EU legislation and ensure knowledge sharing concerning implementation practices across Nordic countries. This will also provide an opportunity to align our national frameworks with these regulations and engage in collaborative efforts that bolster the understanding, strategies, and solutions related to these substances. A consistent approach will help prevent regulatory arbitrage and ensure a level playing field for industries.
• Consider unifying the term for HFOs with what the EU legislation applies to ensure better transparency and consistency, so instead of Hydrofluoroolefins/HFOs, they are termed unsaturated hydrocarbons/ uHFCs. This will also make it more transparent that HFO technically is an HFC. Unifying the terminology ensures a uniform understanding of the substances in question. A consistent term enhances stakeholder communication, ranging from policymakers and industries to researchers and consumers.

15.2 Recommendations for the Nordic countries respectively

Operational

• In line with the Nordic countries’ stance on climate-friendly refrigerants, look into whether safety codes and existing restrictions on flammable refrigerants are updated accordingly with technological progress.

• Ensure adequate information and guidelines on climate-friendly refrigerants are readily available for practitioners. This can be inspired by the Danish Environmental Agency’s establishment of a knowledge centre for Climate-Friendly Refrigerants (Videncenter for Klimavenlige Kølemidler) or through encouragement of stakeholders such as industry associations and manufacturers to create industry initiatives, e.g., guidelines and best practices specifically focusing on HFOs.

Map the use of HFOs

• Encourage branch organisations to conduct member surveys to uncover which types of refrigerants are being used on the market and in which kind of appliances. This can be based on the Swedish Refrigeration & Heat Pump Association’s survey on the type of heat pumps their members install and which refrigerant type they use.
• Consider lowering the threshold value for reporting requirements to cover low GWP substances better. The Swedish Refrigeration and Heat Pump Association has recommended setting this value to 3 kg CO₂e instead.

  Svenska Kyl- & varmepumpforeningen (2023)

Include HFOs in current policies and systems

• Realign HFOs with current systems for HFCs to ensure no extra costs are associated with handing in recovered HFOs.
  • Consider including HFOs in current take-back schemes if they are currently exempt.
  • If the refund share is based on GWP, consider other parameters to ensure that there is economic incitement to recover and hand in recovered HFO instead of releasing it to the environment.
• Clarify the current waste status of HFOs and encourage including HFOs in the list of hazardous wastes. Furthermore, the Nordic countries can jointly encourage HFOs to be explicitly included in the EU list for hazardous waste to ensure a uniform understanding and approach across the EU. 
• Apply a combination of voluntary and mandatory measures to ensure that HFOs are recovered and collected for proper waste handling.
  • Voluntary Measures. Promote Take-Back schemes in collaboration with manufacturers, retailers and service providers. A partnership-based approach encourages industry players to actively participate in the responsible disposal of HFOs.
  • Consider financial incentives or rewards for actors who hand HFOs for proper disposal. Financial incentives acknowledge the potential cost and effort associated with proper disposal. By offsetting these costs, individuals and businesses are more likely to opt for responsible disposal methods rather than engaging in improper disposal practices.
  • Develop labels or certifications that can be earned when participating in organised end-of-life treatment programs.
  • Engage retailers to ensure proper disposal by providing collection points at their facilities or providing information on authorised disposal facilities.
  • Mandatory Measures. EPR legislation that explicitly includes HFOs (combined take-back and deposit-refund system).
  • Require that servicing, refilling, recovery and decommissioning are journaled and reported. If not already, then consider establishing a national database for recording. Transparent record-keeping ensures traceability and enables regulatory bodies to monitor compliance effectively.
  • Consider establishing a centralised national database for recording HFO-related activities. This database would provide a comprehensive overview of HFO waste management efforts, aiding in assessing the effectiveness of strategies and identifying areas for improvement.
  • Collaborate with waste management companies to establish the necessary infrastructure for proper collection, transportation and disposal and make sure that collection points are easily accessible on a nationwide scale.