AREA has replied to a public consultation on the review of the Ozone-Depleting (ODS) Regulation. AREA is generally supportive of the Regulation, which has proven to be efficient in reducing consumption of ozone-depleting substances and encouraging their replacement by alternatives (HFCs and natural refrigerants).
AREA however points out that the situation is not uniform across the EU, notably as regards recovery & destruction. Some countries are also more exposed to refrigerant smuggling, a issue that is becoming increasingly of a concern in the context of the HFC phase-down too.