15.We found that progress on reducing use of F-gases was mixed. F-gas emissions are covered by two policy frameworks: the EU’s HFC Quota, and the UK’s carbon budgets, which are legislated for under the Climate Change Act 2008. One of the key EU measures we looked at is based on reducing the amount of HFCs on the EU market—i.e. the HFC Quota. The UK measures we considered concern estimated F-gas emission reductions and the role they play in reducing the UK’s overall GHG emissions. We also explored several areas where the UK could go further and faster in switching to lower GWP alternatives. In this section we explore EU-wide progress reducing F-gas emissions against EU targets, and the UK’s progress against the UK’s legally binding carbon budgets.
16.In 2017 the European Environment Agency (EEA) reported the first EU-wide decline (4%) of F-gases in 15 years. However, the main emphasis of the EU’s approach has been a phase-down in the availability of HFCs, which are the most widely used F-gases, predominantly found in applications such as refrigeration and air conditioning. The phase-down started in 2015 and was implemented through an EU quota system and HFC registry. The targets setfor this phase-down and the progress so far are set out in Box 4.
Box 4: The EU’s HFC Phase-down
17.The European Environment Agency (EEA), has reported modest reductions in HFCs. The EU Quota system set a baseline for 2015, based on an average estimate of HFC demand between 2009 and 2012 and then decreasing market limits for HFCs placed on the market for subsequent years. In 2015, the EU over-achieved, with a reduction of 8% below the market limit. In 2016, when a small cut was applied to the HFC quota, there was a reduction 4% below the market limit. The Minister also told us that since 2010, there had been an overall reduction in HFC supply of 18%. However, we were told by the Chair of the Committee on Climate Change, Lord Deben, that this reflected a lack of ambition by the EU in setting more demanding targets, while it was also suggested that the reductions in 2015 and 2016 might have been partly as a result of HFC stockpiling before the quota was introduced. While industry maintained that some sectors in the UK were making progress on reducing reliance on high GWP refrigerants, there was an acknowledgement that these cuts had occurred in advance of bigger and more challenging cuts due in 2018 and 2021. It therefore remains to be seen if the EU will make these deeper cuts.
18.Witnesses agreed that the Quota system was working and driving up the prices of high GWP refrigerants. However, they had concerns as to whether such price rises, and a contraction in available refrigerants, might drive illegal sourcing of high GWP refrigerants outside of the HFC Quota, or the dangerous retrofitting of systems to take lower cost refrigerants. They were particularly concerned that, although the Government and trade associations have run campaigns about the need to prepare for reductions in availability, some UK SMEs might not have got this message and made the necessary preparations. This also needs to be considered alongside witnesses’ concerns about the resourcing of the Environment Agency and its ability to ensure compliance.
19.We welcome the fact that the EU overachieved the 2015 and 2016 HFC Quota targets and that there is evidence of price rises for higher GWP refrigerants as their availability is restricted. However, the targets were fairly unambitious and it remains to be seen whether UK companies, especially SMEs, are prepared for the big cuts required in 2018 and 2021. There is a danger this year that some businesses will find that they will not be able to access the refrigerants that they need and may be tempted to acquire them illegally. This would pose a challenge for the Environment Agency in monitoring and enforcing compliance. We are concerned that the Environment Agency may lack the resources it will need to police and enforce F-gas regulations, especially when it is also preparing to take on new responsibilities as the UK leaves the EU. If the UK can meet the steeper cuts in 2018 and 2021, the Government should find ways to cut F-gas emissions even further.
20.At a UK level, reductions in F-gas emissions contribute to meeting overall UK GHG emissions reductions targets under the Climate Change Act 2008. The UK is currently set to miss its Fourth and Fifth Carbon Budgets, which cover the period 2023–27, and 2027–32 respectively. The CCC has set out a pathway for reducing F-gases at least cost as part of the overall reductions in GHG emissions, recommending that the UK should go further than the EU’s 2015 F-gas Regulation and introduce stronger enforcement. The CCC’s analysis published in July 2017 and the evidence provided by its Chair, suggests that there is a danger that the UK is moving away from its suggested, cost-effective pathway, which could have a negative effect on the UK’s overall GHG emissions strategy. In its 2017 Progress Report to Parliament, the CCC concluded “the broad trend in emissions since 2007 has been upwards and needs to be reversed. The rate of emissions reductions now needed to meet the indicator trajectory is quite steep, so considerable further progress is needed.” The CCC Chairman also told us that the UK is not maximising opportunities to move to lower GWP alternatives where they exist and could be introduced relatively easily. This was supported by others who put forward options such as additional taxes, green procurement, funding for lower GWP alternatives and correcting contradictory policies such as high GWP refrigerants in Government subsidised renewable heat pumps.
21.Industry representatives told us that the current F-gas regime, if enforced correctly, is already challenging and that obstacles remain, and that lower GWP refrigerants risked trade-offs with safety and energy efficiency. The Minister agreed that taxes would push up the prices of high GWP HFCs but was not convinced that they were necessary as the current market was already leading to people switching to lower GWP HFCs. Defra stated that they thought that the UK’s current balance struck the right balance between environmental ambition and what was technically feasible and reasonable for businesses.
22.We are concerned that, despite the EU exceeding the 2015 and 2016 HFC Quota targets, the UK is in danger of moving away from the least-cost pathway that the Committee on Climate Change mapped out as part of the UK’s overall efforts to reduce GHGs. While the market-based approach adopted by the EU is making progress, the Government should be prepared to consider other measures to help get the UK back on track to hit the Fourth and Fifth Carbon Budgets. As discussed in the following sections we believe that the Government can take further action to make more progress in reducing F-gases and particularly HFCs.
23.We considered several areas where the Government could introduce alternative low GWP refrigerants relatively easily and where the Government could use policy levers to support the conversion to such refrigerants and propellants.
24.We took evidence on metered dose inhalers (MDIs), which are used for respiratory diseases, and typically use high GWP propellants and constitute the majority of inhalers prescribed in the UK. The told us that MDIs represent 3.5% of the NHS’s greenhouse gas emissions, and estimate that about 70% of inhalers dispensed in England are MDIs and just under 30% are Dry Powder inhalers (DPIs). They also estimate that over 35 million MDI inhalers are dispensed each year compared to 15 million DPIs. The majority of MDIs use HFA 134a as a propellant, which has a GWP of 1,480, while a small minority use HFA 227, which has a GWP of 2,800. MDIs have been identified as a ‘carbon hotspot’ within the NHS. MDIs are currently exempted from the EU’s F-gas Regulation. We heard that there are low GWP alternatives—dry powder inhalers (DPIs) which other countries, such as Sweden, prescribe in the majority of cases. GlaxoSmithKline told us: “It is not just Sweden; it is across most of Europe that the dry powder inhaler is the predominant inhaler.” The evidence we took suggested that on balance DPIs if administered correctly deliver better clinical outcomes for many patients. The NHS Sustainable Development Unit told us:
“The error rate with a metered dose inhaler in clinical practice is that about 50% of patients cannot use them properly, whereas with the modern dry powder inhalers the error rate is down at about 10% or 20%. […] the number of errors you make correlate with outcome. In other words, if you use an inhaler with a low error rate, even though in head-to-head clinical trials where they are used perfectly, there is no difference, in clinical practice you get a better outcome, for instance, better symptom control, less exacerbations of disease.”
25.There was a consensus that DPIs may not be appropriate for certain groups, such as the elderly and the very young. The witnesses did note that successful clinical outcomes for inhalers were also dependent on medical practitioner and patient education, so that the right technique was used. We heard that the low take-up of DPIs was, in part, down to low awareness of DPIs as an alternative among patients and clinicians and the higher costs of DPIs. However, there were opportunities to raise greater awareness of DPIs and allow clinicians and patients to make informed choices, including the environmental impact of those choices. This included engagement with organisations such as the Royal College of GPs, the British Thoracic Society and NICE and promoting the NHS Sustainable Development Strategy, which had identified MDIs as a ‘carbon hotspot’. We were told that the higher costs of DPIs could be offset by their greater efficiency, while greater uptake of DPIs would reduce their costs in the longer term. Research is ongoing to produce low GWP MDIs, though they are still several years from being introduced, and that there are efforts to make MDIs more efficient.
26.We were also told that out of the tens of millions of MDIs that are prescribed in England, only a small proportion are collected to recycle. The NHS told us: “… we have calculated that about 0.5% have come back through the scheme.” This raises the prospect of millions of MDIs ending up in landfill each year, where, over time, they will release residual high GWP HFCs into the atmosphere. We also heard that these residual HFCs could be reclaimed and reused for other purposes, as reused HFCs are outside of the HFC Quota.
27.We recommend that low GWP inhalers should be promoted within the NHS unless there are specific medical reasons for not doing so. Promotion should include raising awareness of low GWP inhalers and training amongst NICE, the medical community and patients. The NHS should set a target that by 2022 at least 50% of prescribed inhalers are low GWP. It should publish annual progress reports. We were disappointed to find that so few MDIs are disposed of responsibly. We therefore recommend that the Government should work with medical professionals, pharmacists, the pharmaceutical industry and patients to significantly improve the recycling of MDIs; this makes both environmental and economic sense. The Government should ensure that by 2020, at least 50% of MDIs are recycled. The Government should publish annual data showing progress in reaching and exceeding this target. It should also consider medical waste, such as MDIs, in its waste strategy.
28.We heard from the CCC and others about concerns that heat pumps, which are promoted as a way of reducing carbon emissions and supported through the Government’s Renewable Heat Incentive, typically use high GWP refrigerants. The Government has also identified heat pumps as having the potential to help deliver its Clean Growth Strategy. The EU’s F-gas Regulation does not include a ban on the use of high GWP refrigerants in heat pumps. It seems paradoxical to us that a taxpayer-supported initiative aimed at reducing carbon emissions should rely on substances that, if released, would increase such emissions. We acknowledge that there is a trade-off between the use of high GWP refrigerants and the energy efficiency of the units they service. However, we feel that there is an opportunity to reduce reliance on such substances and improve energy efficiency at the same time. Defra told us that they have funded a range of information sheets to promote heat pump equipment that uses lower GWP HFCs. However, we are not convinced by the Government’s stance that the phase-down will naturally lead to reduced reliance on such gases in heat pumps.
29.The Government should ensure that heat pumps use low GWP refrigerants. The Government should reform the Renewable Heat Incentive schemes so that they encourage the deployment of heat pumps that use low GWP refrigerants, and that by 2020 all publicly-funded heat pump projects use low GWP refrigerants. It should publish annual data indicating which gases are being used in heat pumps so that Parliament and the Committee on Climate Change can track performance in this area.
30.Several witnesses suggested that the Government could use its considerable procurement power (over £276bn in 2016–17), to help create a market for appliances which use low GWP refrigerants.. The Minister noted that the Government’s Buying Standards ban the purchase of refrigeration and air conditioning units using high GWP refrigerants. This Committee has carried out sustainability audits of several government departments. Its most recent audit looked at the Ministry of Justice, including how it manages its sizeable estate, building new prisons, refurbishment projects, and the closure of older prisons and courts. These audits have looked at a range of indicators that the Government is using, including its Greening Commitments, to cut GHG emissions. These indicators do not split out the progress that the Government is making on reducing the use of high GWP refrigerants.
31.Government departments should lead from the front on reducing their environmental impact. The Greening Commitments set targets and measures for GHG emission reductions: We recommend that they should be amended include targets for departments to reduce their consumption of products containing high GWP F-gases.
38 EEA, Fluorinated greenhouse gases 2017, (2017) p 5. The EEA note that there has been decline in the EU supply of higher GWP HFCs, replaced by lower GWP HFCs, and a reduction in very high GWP F-gases such as SF6, which were slightly offset an increase in NF3, which has a high GWP.
39 The HFC quota system applies to companies across the EU and not pro-rata by member state. Only companies with an HFC quota received from the European Commission are permitted to produce a specified amount of HFCs or import them into the EU. Most of the quotas were given to ‘incumbent companies’ that produced HFCs during the period 2009 to 2012 and are based on a company’s previous activity. A small proportion (11%) is allocated to ‘new entrants’ and quotas allocated to incumbents can be sold. Quota sizes fall every three years to deliver the phase-down. See: European Commission, , (accessed 8 February 2018) and Gluckman Consulting, , (2015).
40 EEA, , (2017), p 6.
41 Dr Thérèse Coffey (Parliamentary Under-Secretary of State, Department for Environment, Food and Rural Affairs).
42 Lord Deben (Committee on Climate Change).
43 Clare Perry (Environmental Investigation Agency).
44 Graeme Fox (REFCOM). He noted that larger supermarkets in the UK were making the move to lower CO2 (GWP 1) refrigerants. See also and Martyn Cooper (Federation of Environmental Trade Associations); (Environmental Investigation Agency); (DEFRA).
45 Clare Perry (Environmental Investigation Agency); Martyn Cooper (Federation of Environmental Trade Associations). (Environmental Investigation Agency).
46 See: Andrew Gaved, , MultiBriefs, (February 2018). He notes growing concern across Europe about a growing crisis over the contraction in, and attendant price rises for, key HFCs, such as R410A and R404A, which are widely used high GWP refrigerants.
47 Martyn Cooper (Federation of Environmental Trade Associations). He noted that the most used high-GWP refrigerant had increased by about 700% since the HFC Quota had been introduced. See also: European Commission, , COM(2017) 377 final, (July 2017); Cooling Post, , (March 2017); Carel, , (March 2017). Andrew Gaved (see above) notes that one impact of the increase in the price of higher GWP refrigerants has been a move by key representative industry bodies in Europe to call upon European installers to stop using such refrigerants.
48 Clare Perry (Environmental Investigation Agency). She noted that there was no real-time quota information to track quotas, especially in relation to imports, and that China and other countries were stockpiling high GWP refrigerants, which could lead to an illegal trade that could mirror the trade in illegal CFCs in the 1980s. Graeme Fox (REFCOM) and Martyn Cooper (Federation of Environmental Trade Associations). See also: (Air Conditioning and Refrigeration Industry Board) and (REFCOM). Both ACRIB and REFCOM pointed to a number of potential loopholes with UK F-gas regulations, including a lack of mandatory record keeping for several aspects of the regulations and a poorly resourced Environmental Agency to ensure compliance.
49 Graeme Fox (REFCOM).
50 Clare Perry (Environmental Investigation Agency); Martyn Cooper (Federation of Environmental Trade Associations).
51 Martyn Cooper (Federation of Environmental Trade Associations). Lord Deben (Committee on Climate Change) argued that the Environment Agency was not properly resourced more generally, currently and historically See also: (Air Conditioning and Refrigeration Industry Board) and (REFCOM).
52 The CCC published in January 2018. It found significant gaps in the Government’s policies to meet the targets set for the Carbon Budgets, including targets agreed by the Paris Agreement: See also: Grantham Research Institute on Climate Change and the Environment, , (January 2018); Carbon Brief, , (January 2018). For an overview of the Carbon Budgets, the role of the Committee on Climate Change and progress so far see: House of Commons Library, , (December 2017).
53 CCC, , (2015), p 213.
54 CCC, , (2016), pp 214–225. The CCC called upon the Government to look a low GWP alternatives for a range of applications and noted that several EU countries had gone further than the UK, including the use of taxes, additional bans or funding for research and deployment of low GWP alternatives. The CCC was concerned firstly that the UK should make more progress but also that progress was not based on ‘soft’ policies that might not deliver the targets sets by the EU.
55 CCC, , (July 2017), p 165.
56 Lord Deben (Committee on Climate Change).
57 CCC, Meeting Carbon Budgets: Closing the policy gap 2017 Report to Parliament, (July 2017), p.170.
58 and Lord Deben (Committee on Climate Change).
59 Clare Perry (Environmental Investigation Agency); (Environmental Investigation Agency). The EIA noted that the review of the EU’s F-gas Regulation in 2022 was the ideal point at which more stringent restrictions of high GWP HFCs could be introduced because the step downs in 2018 and 2022 represented significant cuts to HFC consumption to which industry needed to adjust.
60 Martyn Cooper (Federation of Environmental Trade Associations). He was concerned that if the UK went further than the EU Phase-down it risked greater non-compliance. He also noted that there were problems with some alternatives in terms of flammability and toxicity, which required new systems to accommodate them. See also: Martyn Cooper (Federation of Environmental Trade Associations); (REFCOM); (Air Conditioning and Refrigeration Industry Board); (Airedale International Air Conditioning).
61 to Mike Nankivell (Air Conditioning and Refrigeration Industry Board); Martyn Cooper (Federation of Environmental Trade Associations).
62 Q186 to Q188 Dr Thérèse Coffey (Parliamentary Under Secretary of State, Department for Environment, Food and Rural Affairs). See also RFG009. Defra’s submission stated that the UK had a large pool of expertise upon which to draw if the Government needed to assess new reduction measures and new low GWP alternatives, while the EU’s phase-down was encouraging industry to undertake its own research and development of alternatives.
63 RFG0009 (Defra).
65 Information supplied by the NHS Sustainable Development Unit.
66 NHS Sustainable Development Unit, , (January 2016), p 2–3. The SDU estimate MDI inhalers account for 3.5% of all NHS Emissions.
67 Q 273 Jerome Bradley (NHS Sustainable Development Unit); (GlaxoSmithKline). See also: Toby Hillman et al., ‘Inhaled drugs and global warming: time to shift to dry powder inhalers’, British Medical Journal, Vol 346, (May 2013); British Thoracic Society, , (January 2017); Lavorini, F et al, Retail sales of inhalation devices in European Countries: So much for a global policy, Respiratory Medicine, Vol 105, (2011), pp 1099–1103.
68 Q266 to Q267 Neil Barnes (GlaxoSmithKline) and Q278 Jerome Bradley (NHS Sustainable Development Unit) argued that there was a lower error rate with DPIs. Q278 to 279 and Q265 Stuart Corr (Mexichem) stated that DPIs did not have a 100% success rate and argued that decisions over DPIs and MDIs also had to take patient preference into account. He also pointed to evidence which suggested that patient choice and continuity could lead to improved clinical outcomes - see: Leif Bjermer, The Importance of Continuity in Inhaler Device Choice for Asthma and Chronic Obstructive Pulmonary Disease, Respiration Vol 88, (2014), pp 346–352. Dr Duncan Keeley () maintained that some of the error rates associated with MDIs could be overcome by using MDIs with spacers. Chiesel (RG0016) argued that improvements in MDI technology were improving their effectiveness, which was leading to less propellant gas being lost to the atmosphere.
69 For instance, NICE has set out on the use of MDIs and DPI for under-fives with chronic asthma, which states that clinical decisions should be based on the needs of individual needs of patients and their costs. NICE for older children states that a range of inhalers can be considered based on the needs of the individual child. See also ( (GlaxoSmithKline); Q279 Stuart Corr (Mexichem). Dr Duncan Keeley () noted that MDIs were the most effective treatment for patients with exacerbations of asthma or COPD that required substantially higher doses of inhaled bronchodilators. Dr Keeley also noted that MDIs were also more effectively used with spacers to improve the efficiency of delivery. Chiesi (RG0016) also stated that groups of patients were not able to generate the required level of inspiratory flow required to use DPIs. They also maintained that MDIs needed to remain a treatment option for asthma and COPD patients and in some cases the only option for some asthma and COPD patients.
70 Q267 and Q281-Q282 Neil Barnes (GlaxoSmithKline); Q279 Jerome Bradley (NHS Sustainable Development Unit). The issue of using the correct technique has been raised for both types of inhalers. For example, see: Joaquin Sanchis et al, , Respiratory Care, Vol 150, No 2, (2016), pp. 394–406; BBC News, , (December 2014); The Inhaler Error Steering Committee, , Respiratory Medicine, Vol 107, (2013), pp 37–46.
71 Q259 and Q281 to Q282 Neil Barnes (GlaxoSmithKline); Q268 and Q273 Jerome Bradley (NHS Sustainable Development Unit).
72 Q273 Stuart Corr (Mexichem). Some indication of the price difference between MDIs and DPIs can be found in: Regional Drug and Therapeutics Centre (Newcastle), , (October 2017), Table 3.2, p 20. Dr Duncan Keeley () provided evidence that the cost of DPI delivery could be 2–4 times the cost of MDI delivery for one key short acting bronchodilator ( SABA) salbutamol which was used for relieving symptom of wheezing for both asthma and COPD. He noted that DPIs were currently more expensive for the delivery of other medications, though for others the cost differential was less. Chiesi (RG0016) also highlighted the challenges of current higher prices for many DPIs and also the costs associated with ensuring that medical staff were properly trained to show how DPIs could be used effectively and safely by patients. They too highlighted higher costs associated with the use of salbutomol (SABA) in DPIs versus MDIs.
73 Q283 to Q286 Jerome Bradley (NHS Sustainable Development Unit). See: NHS Sustainable Development Unit, Carbon Hotspots update for the health and care sector in England 2015, (January 2016), p 2–3
74 Q276 Jerome Bradley (NHS Sustainable Development Unit) stated that because DPIs were more efficient, initial greater costs for DPIs could be offset by the need for fewer inhalers and hospital admissions.
75 Q266 Stuart Corr (Mexichem) noted that Mexichem was developing an MDI using HFC 152a, which has a GWP of 120 and which he thought would be available from 2021. See also (Mexichem). Similar work on lower GWP MDIs is also being carried out by AstraZeneca. Chiesi (RG0016) also noted that replacing propellants in MDIs was a complex process, such as issues over toxicity, adaptation of hardware delivery systems and increased costs. It is investing in this area but acknowledged it would take time for these innovations to appear on the market.
76 Q269 Stuart Corr (Mexichem).
77 Q297 Jerome Bradley (NHS Sustainable Development Unit) stated that the NHS SDU estimated that only about 0.5% were collected. Q291 to Q296 Neil Barnes (GlaxoSmithKline) noted that it ran the only collection and recycling scheme and had recycled 1 million MDIs over a five-year period.
78 Q303 Stuart Corr (Mexichem) noted that reclaimed HFCs could for instance be reused as a refrigerant. Chiesi (RG0016) noted in its evidence that it was assessing how it could support waste management initiatives.
79 CCC, , p 169. The Committee noted its concerns that uptake of heat pumps, if they continued to use high GWP refrigerants could lead to “significant increases in F-gas emissions. See also Q99 Clare Perry (Environmental Investigation Agency). See also Ecologist, , (2010). For information on the Renewable Energy Initiative see: Energy Saving Trust, , (accessed 10 February 2018). For an overview of heat pump technology see: Parliamentary Office of Science and Technology, , (2013). Defra supplied us with information which indicates that the most widely used refrigerant HFC410A has a GWP of 2088. Other refrigerants include: HFC-134a (GWP 1,430); R-404A (GWP 3,922) and R-407C (GWP 1,774). Alternatives include R32 (GWP 675).
80 BEIS, , (October 2017), p 75. See also Carbon Brief, (October 2017)
81 Q99 Clare Perry (Environmental Investigation Agency). See Defra, , (accessed 17 February 2018).
82 Q97–98 Mike Nankivell (Air Conditioning and Refrigeration Industry Board).
83 Q210 to Q211 Davinder Lail (DEFRA); Q99 Clare Perry (Environmental Investigation Agency).
84 Information provided by Defra.
85 Q183 Dr Thérèse Coffey (Parliamentary Under Secretary of State, Department for Environment, Food and Rural Affairs). See also Q99 Graeme Fox (REFCOM). He argued that a reduction in the supply of the main refrigerant used in heat pumps—HF 410A (GWP 2088), because of the Phase-Down would lead to higher prices and a switch to R-32 (GWP 675).
86 See HM Treasury, , (November 2017), Table 11, p 22.
87 Q93 Clare Perry (Environmental Investigation Agency). See also (Environmental Investigation Agency).
88 Q190 Dr Thérèse Coffey (Parliamentary Under-Secretary of State, Department for Environment, Food and Rural Affairs). For details of the Government Buying Standards see: DEFRA, , (accessed 12 February 2018).
89 The audits include: ; ; ; .
90 EAC, , (HC 545; February 2018)
91 See DEFRA and Cabinet Office, , (December 2016) and DEFRA and Cabinet Office, , April 2016 to March 2017, (February 2018).
Published: 25 April 2018