The Commission applies the principle of technology neutrality. It is for the industry to choose which gas to use in order to comply with Directive 2006/40/EC. The Commission is not aware of any vehicle manufacturers using a refrigerant other than HFO-1234yf for the purposes of Directive 2006/40/EC.

HFO-1234yf has been classified by the producers as flammable gas, Category C, in accordance with Regulation (EC) No 1272/2008 and has not been classified as hazardous to the environment. According to the information contained in the Material Safety Data Sheet, the flammability risk of HFO-1234fy is significantly less than the flammability risk associated with the use of gasoline. There are also estimates that HFO-1234yf may form dangerous hydrogen fluoride (HF) under certain conditions. Studies have been conducted by car manufacturers on the probabilities of an engine compartment leakage from a leak or crash resulting in ignition from HFO-1234yf and in both tests no fires occurred and no toxic substances were released.

MAC systems are also subject to the Pressure Equipment Directive 97/23/EC (PED). In particular, the levels of flammability and toxicity of its refrigerant determine the stringency of the conformity assessment procedures applied to the MAC systems.

HFO-1234yf has been registered by two legal entities in accordance with Regulation (EC) No 1907/2006 (‘REACH’). Registration under REACH requires registrants to implement risk management measures.

The Commission believes that the combined effect of these different aspects of the EU legislation ensure a high level of safety for the citizens and for the environment, while supporting the goals of fighting climate change.