Switchgear and ESPR: Aligning EU Policy with Industrial Leadership and Strategic Autonomy
The Alliance supports the overarching objectives of the Ecodesign for Sustainable Products Regulation (ESPR). Durability, repairability, recyclability, and resource efficiency are essential for building a competitive, resilient electricity network in Europe. For high and medium voltage switchgear, the ESPR’s objectives are already being delivered through the F-Gas Regulation (revised in 2024), which provides a clear, targeted framework for phasing out high GWP insulating F-gases and scaling proven, PFAS-free alternatives. The ESPR should complement, rather than duplicate these frameworks, and should not put delivery of circularity goals at risk. NOG technology is a European success story – developed, produced, and deployed at scale by multiple EU manufacturers and gas suppliers, without reliance on restricted patents or third country non-EU feedstock, and no risk to the environment. The F-Gas Regulation rightly focuses on climate impact and GWP reduction, and NOG technology addresses gaps related to circularity as these systems are inherently more durable and repairable. In this way, they advance ESPR’s goals more effectively than PFASdependent alternatives, without requiring additional legislation. Adding switchgear to ESPR at this stage risks not only duplicating existing environmental regulation but actively undermining European industrial innovation. Rather than supporting the scaling of proven EU-grown solutions, it introduces uncertainty and added costs that risk delaying or undermining the deployment of PFAS-free alternatives.
1. “Urgency” and regulatory certainty
The claim: Some stakeholders argue that without an ESPR delegated act, Article 13(13) of the F-Gas Regulation cannot be applied. They warn this could block certain technologies from the EU market in 2028–2032, leading to supply bottlenecks for grid operators. Our view: The F-Gas Regulation already ensures continuity through clear timelines and derogations. If less than two bids are submitted with solutions of GWP less than 1, grid operators can continue using insulating gases with higher GWP for up to two years after the phase out dates. This still gives some high voltage applications nine years from now to develop cleaner solutions. An ESPR delegated act would not accelerate deployment, but would create uncertainty in the application of phase out dates and derogations. For businesses investing in clean tech, this instability would discourage long-term planning, and slow deployment of scalable alternatives.
2. “Supply security” and technological diversity
The claim: ESPR is presented as a tool to preserve multiple technology pathways, avoiding dependence on a single supplier of natural-origin gas technology. Our view: The EU already has strong technological diversity in F-gas/PFAS-free switchgear. Multiple European manufacturers for both medium voltage and high voltage have developed and are successfully operating switchgear using F-gas free, natural-origin gas alternatives. Companies providing medium voltage switchgear include ABB; Schneider Electric; Siemens; Ormazabal, Nuventura. Companies providing high-voltage switchgear include Siemens Energy; Toshiba; Mitsubishi; Hitachi Energy; GE Vernova. This technology is tried and tested and in operation for over 10 years. Where there are remaining portfolio gaps, our companies are committed to closing these gaps in the upcoming years before the F-Gas Regulation’s proposed phase-out timelines (more information on market availabilities in annex). The actual supply risk lies with PFAS/F-gas mixtures such as fluoronitrile (C4-FN) (a PFAS insulating gas used in high-voltage switchgear). There is no C4-FN chemical manufacturer in Europe and the main global supplier in the US will cease production in 20251 . Inclusion of switchgear in the ESPR could therefore inadvertently embed dependence on a constrained, non-EU controlled supply chain at the expense of Europe’s strategic autonomy, rather than driving momentum away from PFAS mixtures towards natural-origin gases (NOG) technology based on a mix of nitrogen, oxygen and carbon dioxide, resulting in emissions which are harmless to the environment.
3. “Climate performance” and life cycle assessments (LCA)
The claim: Some claim C4-FN mixtures may have lower life cycle CO₂ emissions and argue for inclusion of switchgear in the ESPR to validate this under harmonised LCA standards. Our view: Current LCA comparisons are flawed and cannot justify regulatory or tender decisions. Existing technical specifications fail to account for PFAS toxicity and persistence, rely on unverifiable assumptions (e.g. leakage rates, material data), and offer too much flexibility in modelling tools and databases to ensure comparability. Even verified LCAs often lack transparency, with critical inputs withheld for competition reasons. Crucially, the IEC TS 62271-320:2025 technical specification itself states that “it is not possible to compare two similar high-voltage switchgear analysed in different contexts” due to variability in energy mix, system boundaries, durability, and other parameters. In short, the standard acknowledges that LCA is not a harmonised or comparable basis for regulation2 . Meanwhile, C4-FN mixtures have GWP values (>500) far above the EU Taxonomy threshold (GWP ≤10) for sustainable investment in switchgear. Leaked PFAS insulating F-gases like C5- FK (and possibly also C4-FN) are known to degrade into harmful substances like trifluoroacetic acid (TFA), raising further concerns about long-term environmental impact from PFAS-based switchgear. 1 3M to Exit PFAS Manufacturing by the End of 2025: https://news.3m.com/2022-12-20-3M-to-ExitPFAS-Manufacturing-by-the-End-of-2025 2 IEC TS 62271-320:2025; more information: https://www.iec.ch/publications/specifications The F-Gas Regulation already applies robust GWP limits, aligned with EU sustainable finance and industrial policy. Introducing parallel ESPR criteria based on weak LCA methods risks undermining this alignment and distorting policy signals.
4. “Industrial competitiveness” and grid expansion
The claim: The ESPR is positioned as a tool to protect EU industrial leadership and ensure grid expansion stays on track.
Our view: Competitiveness needs regulatory clarity, the F-Gas Regulation provides this.
• NOG technology is manufactured in EU plants, supports thousands of skilled jobs, and underpins Europe’s leadership in exporting this technology abroad.
• Since the F-Gas Regulation was agreed, original equipment manufacturers have made multi-hundred-million-euro investments in natural origin gas technology (with publicly disclosed investments exceeding €300m). Changing course would strand capital, put investments and jobs at risk and undermine European industrial competitiveness.
• NOG solutions have multiple secure EU-based supply chains, and there are no blocking patents, while PFAS blends risk locking Europe into vulnerable externally controlled inputs.
• Adding ESPR requirements now adds a second compliance track on top of the F-Gas Regulation, directly opposing the EU’s simplification agenda. Delegated acts and harmonised standards take years, while NOG technology is scaling now.
• Additional regulatory processes risk delaying procurement and slowing grid expansion at the very time when the EU depends on rapid deployment to secure its strategic autonomy and energy transition goals.
Conclusion
Our Alliance supports the ESPR’s principles and stands ready to contribute expertise on circularity, repairability, and end of life management of switchgear. Our signatories, with a total presence in all 27 EU Member States and representing over 250,000 jobs in the EU, are ready to do their part. However, adding high and medium voltage switchgear to the ESPR now risks creating regulatory uncertainty, undermining EU industrial competitiveness and strategic autonomy, delaying investment and undermining the position of EU manufacturers already delivering compliant technologies at scale. We call on policymakers to let the F-Gas Regulation deliver on climate and environmental impact, while industry-led innovation like NOG technology continues to advance durability, repairability, and circularity within that framework. This is how Europe leads, by aligning strong regulation with proven industrial capability.