F-gases in equipment and products

DISCLAIMER: The information in these webpages is intended to contribute to a better understanding of the EU F-gas rules. The guidance provided here is not complete and does not create any enforceable right or expectation. It does not replace the F-gas Regulation 2024/573 which is the only text with legal force, and only the Court of Justice of the European Union can make binding interpretation of EU legislation.

Key changes for equipment importers in the new regulation

Click on the + signs for more information on each category

Importer of refrigeration, air-conditioning, heat pump equipment or metered dose inhalers containing HFCs (equipment listed in Article 19)

Note: Annex I, Section 1 of Regulation (EU) 2024/573

Main obligations

• Have an import license, which is a valid registration in the F-gas Portal as equipment importer, prior to the import except for temporary storage: business specification in the F-gas Portal “Are you importing any of the following products or types of equipment (including in automotives e.g. cars) containing fluorinated greenhouse gases listed in Annex I, II or III” )(Article 20, 22 and 23, F-gas Portal Implementing Act, registration guidelines).
• Ensure that the HFCs are covered under the quota system,  in particular, by having sufficient authorisations, or delegated authorisations,  prior to release for free circulation (FAQ on authorisations).
• Ensure that compliance with the quota system is fully documented and draw up a declaration to be submitted to the customs authorities at the time of release for free circulation, in accordance with (Article 19, FAQ).
• Provide the required information in the customs declaration document (Article 23).
• Comply with the placing on the market prohibitions in Article 11 and Annex IV to the F-gas Regulation.
• Ensure correct labelling of the  equipment listed in Article 12 of the F-gas Regulation in accordance with the Labelling Implementing Act
• Report on the F-gas related imports by 31 March every year for the previous year’s activities Article 26 and Annex IX of the F-gas Regulation (Reporting Implementing act, and reporting FAQ).
• Have the report and the accuracy of the documentation verified by an independent auditor, due by 30 April every year. The independent auditor verifying the report must be registered in the F-gas Portal (Article 20) and the verification report submitted through the F-gas Portal (Article 26, please find more information here: Help and registration guidelines for auditors).

Importer of HFCs pre-charged in other products and equipment.

Note: Not covered in Article 19 of the F-gas Regulation.

Main obligations

• Have an import license, which is a valid registration as equipment importer in the F-gas Portal prior to the import, except for temporary storage: business specification in the F-gas Portal “Are you importing any of the following products or types of equipment (including in automotives e.g. cars) containing fluorinated greenhouse gases listed in Annex I, II or III” and the sub-category “Automotives (e.g. cars) with R1234yf, other products and equipment” (Articles 20 and 22, F-gas Portal Implementing Act, Registration guidelines).
• Comply with the placing on the market prohibitions in Article 11 and Annex IV to the F-gas Regulation).
• Ensure correct labelling of pre-charged products or equipment listed in Article 12 of the F-gas Regulation in accordance with the Labelling Implementing Act.
• Provide the required information in the customs declaration document (Article 23).
• Report on F-gas related activities by 31 March yearly, for the previous year’s activities (for non-HFCs, the reporting threshold is 100 tonnes CO2 eq and more per year). (Reporting Implementing act, and reporting FAQ).

Exporter of products and equipment (incl. automotives/ cars) containing HFCs and non-HFCs

Note: Annex I, II, or III of Regulation (EU) 2024/573

Main obligations

• Avoid emissions (Article 4).
• Have an export license, which is a valid registration as equipment exporter in the F-gas Portal prior to the export: business specification in the F-gas Portal “Are you exporting products and equipment (including in automotives e.g. cars) containing fluorinated greenhouse gases listed in Annex I, II or III” (Articles 20 and 22, F-gas Portal Implementing Act, Registration guidelines).
• Respect export prohibitions of certain equipment with highly warming F-gases and to states that have not ratified the Montreal Protocol by 2028 (Articles 22 and 25).
• Provide the required information in the customs declaration document (Article 23).
• No reporting obligations under Article 26 of the F-gas Regulation. 

Importer of products containing F-gases which are non-HFCs, like R1234yf

Note: Refrigeration, air conditioning (incl. in automotives e.g. cars), heat pump equipment or metered dose inhalers not covered under Article 19 of the F-gas Regulation.

Main obligations

• Have an import license, which is a valid registration as equipment importer in the F-gas Portal prior to the import, except for temporary storage: business specification in the F-gas Portal “Are you importing any of the following products or types of equipment (including in automotives e.g. cars) containing fluorinated greenhouse gases listed in Annex I, II or III” and the sub-category “Automotives (e.g. cars) with R1234yf, other products and equipment” ((Articles 20 and 22, F-gas Portal Implementing Act, and registration guidelines).
• Comply with the placing on the market prohibitions in Article 11 and Annex IV to the F-gas Regulation).
• Ensure correct labelling of pre-charged products or equipment (Article 12 and Labelling Implementing Act).
• Provide the required information in the customs declaration document (Article 23).
• Report on F-gas related activities by 31 March yearly, for the previous year’s activities (for non-HFCs, the reporting threshold is 100 tonnes CO₂ equivalent and more per year). Reporting Implementing Act, and Reporting FAQ).

Manager of authorisations for importers of refrigeration, air-conditioning, heat pump equipment or metered dose inhalers containing HFCs listed in Annex I, section 1 to the F-gas Regulation

Note: Annex I, Section 1 of Regulation (EU) 2024/573. Refrigeration, air-conditioning equipment (including in automotives e.g. cars), heat pumps or metered dose inhalers

Main obligations 

• Be registered in the F-gas Portal: business specification in the F-gas Portal “Are you managing authorisations for importers of refrigeration, air-conditioning, heat pump equipment or metered dose inhalers containing HFCs” (Articles 20 and 22, F-gas Portal Implementing Act, Registration guidelines).
• No reporting obligations under Article 26 of the F-gas Regulation. 

Distributors of equipment containing F-gases

Main obligations

• Avoid emissions (Article 4).
• Keep evidence of lawful placing on the market if the placing on the market of that equipment has been prohibited for one year or more (Article 11).
• No obligation to register in the F-gas Portal or to report under Article 26 of the F-gas Regulation.

Technician dealing with F-gases in equipment

Main obligations

• Obtain the F-gas certificate or training attestation needed to install, maintain, service, repair, decommission, leak check and/or recover gases from diverse types of equipment (Article 10 and relevant Implementing Acts)
• The relevant equipment, overall, includes stationary refrigeration equipment, air-conditioning equipment, heat pumps, fire protection equipment, organic Rankine cycle and electrical switchgear, refrigeration of refrigerated trucks and refrigerated trailers, refrigeration of refrigerated light-duty vehicles, intermodal containers (incl. reefers, train wagons), air-conditioners and heat pumps in heavy-duty vehicles, vans, non-road mobile machinery used in agriculture, mining and construction operations, trains, metros, trams, and aircraft (Article 10).   
• Certification and training must also cover handling alternatives to F-gases, and knowledge must be refreshed (Article 10).

Health sector equipment containing F-gases

Main obligations 

• Avoid emissions (Article 4).
• Consider that desflurane can only be used as an anaesthetic if there are medical reasons why other anaesthetics are not as good for the patient, which needs to be documented – no prior authorisation is needed (Recital 27, Article 13(8)).
• Importer and producer: Metered dose inhalers must be labelled from 1 January 2025 (Article 12, Labelling Implementing Act). However, enforcement authorities should take into consideration the regulatory process for changing existing labelling requirements or the process of re-labelling those that have already been placed on the market, see guidance to customs.
• Importer and manufacturer: Placing skin cooling equipment on the market is prohibited from 1 January 2025 unless it is to be used for medical applications (Annex IV (21)).

Operator of equipment containing F-gases

Main obligations

• Avoid emissions (Article 4).
• When installing equipment, consider the prohibitions outlined in Annex IV. Additionally, if you plan to install equipment labelled as requiring installation solely for compliance purposes (regarding exemptions due to safety requirements), ensure that this is indeed the case and that equipment adhering to F-gas regulations in Annex IV wouldn't compromise safety requirements (Articles 12(15) and 13).
• When planning the installation of new switchgear, consider the new prohibitions on installing highly warming F-gases such as SF6 and ensure that the derogations are only used in duly justified cases (Article 13).     
• Only use certified or appropriately qualified persons to install, service, maintain, repair, and decommission the equipment (Articles 4, 8 and 10).
• Respect leak check requirements for the different F-gas covered, if applicable (Articles 5 and 6).
• Keep the F-gas records relating to the installation and servicing of the equipment for at least 5 years, including for equipment with a label indicating that it may only be installed where needed to comply with safety requirements or be subject to other exemptions. This includes evidence documenting the site-specific reasons (Article 7).
• Ensure that F-gases from decommissioned equipment are recovered, recycled, reclaimed, or destroyed (Article 8).
• Respect the restrictions on using highly warming F-gases to service the equipment (Article 13).
• No obligation to register in the F-gas Portal or to report under Article 26 of the F-gas Regulation.

EU-manufacturers of equipment containing F-gases

Main obligations

• Avoid emissions (Article 4).
• Ensure that prohibited equipment is not being placed on the market (Annex IV).
• Ensure correct labelling of the equipment prior to placing on the market, supplying or making available (Article 12, Labelling Implementing Act).
• Ensure the HFCs in refrigeration, air conditioners, heat pumps and metered dose inhalers are covered by the quota system and draw up a declaration of conformity prior to the placing on the market (Article 19).
• Respect leak check requirements for the different F-gas covered, if applicable (Articles 5 and 6).

Equipment subject to leak checks

Main obligations

• Stationary equipment: refrigeration, air-conditioners, heat pumps, fire protection, organic Rankine cycles, electrical switchgear (Articles 5 and 6).
• Mobile equipment: refrigeration of refrigerated trucks and refrigerated trailers; refrigeration of refrigerated light-duty vehicles, intermodal containers (including reefers, train wagons); air conditioners and heat pumps in heavy-duty vehicles, vans, non-road mobile machinery used in agriculture, mining and construction operations, trains, metros, trams, and aircraft (Articles 5 and 6).