F-gases in equipment and products

Key changes for equipment importers in the new regulation

Prior to the import

• An import licence (= valid registration as importer of pre-charged equipment/product in the F-gas Portal) is required for all customs procedures, except in case of temporary storage.  

Prohibitions

• New placing on the market prohibitions have been introduced, detailed in Article 13 and Annex IV. 

Customs declaration

• Information to be provided in the customs declaration is specified i.e. quantity in metric tonnes and in CO2 equivalent, F-gas Portal registration number (Article 23). 

Quota authorisations

• The placing on the market of metered dose inhalers pre-charged with HFCs is no longer exempted from the quota system but requires a declaration of conformity showing how the HFCs is covered under the quota system, e.g. covered by sufficient authorisations from a quota holder or delegations from an authorisation manager 
• New entrant bulk HFC importers that do not have a reference value are no longer permitted to authorise their quota to equipment importers or to authorisation managers. 
• The minimum HFC quantity in imported products/equipment that must be covered under the quota system has been reduced to 10t CO2eq (Article 19(6)). 

Reporting and verification

• From 2025, the new minimum thresholds for reporting are 10t CO2eq for HFCs and 100t CO2eq for other F-gases, due by 31 March (Article 26 (4) and Annex IX). For reporting on 2023 activities in 2024, the rules under Regulation (EU) 517/2014 remain applicable. 
• The threshold for submitting a verification report for import of pre-charged equipment that must be covered by the quota system has been set at 1000t CO2eq with a different deadline, due by 30 April from 2025 (Article 26(7)). 
• The independent auditor to verify the report must be registered in the F-gas Portal. 

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

Main obligations:

• Have an import license (=valid registration in the F-gas Portal as equipment importer) prior to the import. 
• Ensure that the HFCs are covered under the quota system, e.g. by having sufficient authorisations (or delegations) prior to release for free circulation and draw up a declaration of conformity prior to the placing on the market. 
• Ensure that prohibited equipment is not being placed on the market (Annex IV).  
• Ensure correct labelling of the pre-charged equipment (Article 12). 
• Provide the required information in the customs declaration document (Article 23).  

• Report on the F-gas related imports by 31 March for the previous year (Article 26 and Annex IX).  
• Have the report and the accuracy of the documentation verified by an independent auditor and, from 2025 onwards, reporting on the previous year’s activities, the auditor must be registered in the F-gas Portal and submit the verification report by 30 April through the reporting tool. 
• For reporting in 2024 on 2023 activities, the rules under Regulation (EU) 517/2014 remain applicable. 

Importer of other products and equipment containing F-gases not covered by Article 19

Main obligations:

• Have a license (=valid registration as equipment importer in the F-gas Portal) prior to the import, except for temporary storage. 
• Ensure that prohibited product/ equipment is not being placed on the market (Annex IV).  
• Ensure correct labelling of the pre-charged product/ equipment (Article 12). 
• Provide the required information in the customs declaration document (Article 23).  
• Report on F-gas related activities by 31 March for the previous year (Article 26 and Annex IX). From 2025 on 2024 reporting, or products and equipment containing HFCs the minimum threshold is 10t CO2eq or more and for other F-gases it is 100t CO2eq or more.  
• For reporting in 2024 on 2023 activities, the rules under Regulation (EU) 517/2014 remain applicable.  

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

Main obligations:

• Be registered in the F-gas Portal.  
• Ensure that delegations of quota authorisations are introduced and accepted in the F-gas Portal. 

EU-manufacturers of equipment containing F-gases

Main obligations:

• Avoid emissions. 
• Ensure that prohibited equipment is not being placed on the market (Annex IV).  
• Ensure correct labelling of the equipment (Article 12). 
• 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.  

Distributors of equipment containing F-gases

Main obligations:

• Avoid emissions. 
• Keep evidence of lawful placing on the market if the placing on the market of that equipment has been prohibited for 6 months or more. 

Operator of equipment containing F-gases

Main obligations:

• Avoid emissions. 
• When installing equipment, take into account 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. 
• 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. 
• Respect leak check requirements for the different F-gas covered, if applicable.
• Keep for at least 5 years the F-gas records relating to the installation and servicing of the equipment, 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. 
• Ensure that F-gases from decommissioned equipment are recovered, recycled, reclaimed, or destroyed. 
• Respect the restrictions on using highly warming F-gases to service the equipment.  

The following equipment have to be checked for leaks depending on the F-gas used:

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. 
• The relevant equipment, overall, is 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. 
• Certification and training must also cover handling alternatives to F-gases, and knowledge must be refreshed. 

F-gases in the health sector

Main obligations:

• Avoid emissions. 
• 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.
• Importer and producer: Starting in 2025, the supply of HFCs to metered dose inhalers will be covered by the quota system. Consequently, all HFCs are still allowed, but over time, manufacturers of metered dose inhalers will gradually shift to more climate-friendly propellants.  
• 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)).