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European F-Gas Regulation and Medical Applications

The proposed Regulation includes measures to limit the total amount of HFCs that can be placed on the market (the quota) and the requirement to pay an "allocation fee", a de facto tax, in order to make use of that quota. Medical applications of Zephex 134a and of Zephex 227ea, including metered dose inhalers (MDIs) are treated in the same way as industrial uses of HFCs, the main focus of the Regulation, with no recognition of the unique nature of these applications.

If implemented, these provisions will:

  • Disproportionately drive up the cost of metered dose inhalers (MDIs) putting pressure on the finances of national European governments
  • Restrict access to these life saving devices
  • Result in significant business uncertainty going forward

Medical applications represent only a small fraction of the total HFC consumption in the European market. For example a recent publication by the Danish Ministry of Environment on HFC usage in the year 2010 , where industrial HFC usage has been subject to taxation and use-bans for a number of years, shows that less than 1.2% of the GWP-weighted consumption of HFCs is attributable to the use of HFCs in MDIs.

It is our understanding that HFCs for use in MDIs are exempt from the Danish Tax on HFCs and Mexichem strongly supports exemption of HFCs for medical applications from the proposed Regulation or, at the very least, a regime whereby HFCs for medical uses should not be subject to the HFC quota or to any fee or tax. To this end, Mexichem is engaging with a number of stakeholders in the regulatory process to gain recognition for this critical use that has a direct bearing on people’s health and quality of life.

If you would like further information or would like to help to influence the development of the Regulation, please contact Stuart Corr or Tim Noakes.