F-gases in bulk - Fluorinated Greenhouse Gases – Climate Action
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Climate Action

F-gases in bulk

Importers, producers, exporters, distributors, industrial users, reclamation, and destruction facilities.

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 importers and producers in the new regulation

Click on the + signs for more information on each category

Importer of bulk HFCs using the customs procedure "release for free circulation"

Importers banners - F-gas

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

Main obligations
  • Avoid emissions (Article 4).
  • Have an import license, which is a valid registration as bulk HFC importer in the F-gas Portal prior to the import: business specification in the F-gas Portal “Are you a producer/importer/exporter of HFCs in bulk” and the sub-category “Importer using the customs procedure release for free circulation or producer” (Articles 20 and 22, F-gas Portal Implementing Act, registration guidelines Guidance - European Commission).
  • Have sufficient HFC quota in the F-gas Portal prior to release for free circulation (HFC quota system Article 16 to 19, Article 21 and Annexes VII and VIII, FAQ).
  • Draw up a declaration of conformity which includes evidence confirming the binding arrangements for the return of the container for the purpose of refilling (Article 11). Note that non-refillable containers cannot be imported under any customs procedure, including under temporary storage, exported, used or transported except for laboratory uses.
  • Draw up a declaration of conformity with additional supporting documents proving that any R23 (trifluoromethane) by-production has been destroyed or recovered using the best available technologies (Article 4).
  • Ensure correct labelling of the F-gas container (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 for the previous year (Article 26 and Annex IX, Reporting Implementing Act, Reporting FAQ). No minimum threshold for importers of HFCs, whereas thresholds apply for other F-gases. For reporting on 2023 activities in 2024, the rules under Regulation (EU) 517/2014 remain applicable with the exemption that quota holders that have not placed HFCs on the market in 2023 must submit a nil report 2024.
  • Have an independent verification report submitted by an auditor in case the placing on the market of HFCs amounts to 1000t CO2eq or more for the previous year, due by 30 April from 2025.  The independent auditor verifying the report must be registered in the F-gas Portal and the auditor must submit the verified report through the reporting tool (Article 26, please find more information here: Help and registration guidelines for auditors).

 

Importer of bulk HFCs using another customs procedure

Important: Goods under temporary storage are not covered, unless it concerns non-refillable cylinders that are prohibited even in that case. Non-refillable containers cannot be imported under any customs procedure, including under temporary storage, exported, used or transported except for laboratory uses.

Note: Annex I, Section 1 of Regulation (EU) 2024/573. A special customs procedure (transit, customs warehousing, inward/outward processing etc.) and not release for free circulation.

Main obligations
  • Avoid emissions (Article 4).
  • Have an import license, which is a valid registration as a bulk HFC importer in the F-gas Portal, prior to the import: business specification in the F-gas Portal “Are you a producer / importer / exporter of HFCs in bulk” and the sub-category “Importer using other customs procedures” (Article 20 and 22, F-gas Portal Implementing Act, registration guidelines).
  • Ensure correct labelling of the F-gas container (Article 12 and Labelling Implementing Act). For the purpose of imports other than release for free circulation, the undertaking registered in the F-gas Portal pursuant to Article 20 of the F-gas Regulation shall be the declarant indicated in the customs declaration who is the holder of the authorisation for a special procedure other than transit, unless there is a transfer of rights and obligations pursuant to Article 21 of Regulation (EU) No 952/2013 to allow another person to be the declarant. In the case of transit procedure, the undertaking holding quota or authorisations to use quota as required under this Regulation shall be the holder of the procedure (Article 23).
  • Provide the required information in the customs declaration document (Article 23).
  • Report on F-gas-related activities by 31 March every year, for the previous year’s activities. There is no minimum threshold for importers of HFCs, whereas a minimum threshold of 100t CO2 equivalent applies to other F-gases. (Article 26 and Annex IX, Reporting Implementing Act and Reporting FAQ).  

Producer of bulk F-gases, incl. HFCs

Producers HFCs - F-gas in bulk

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

Main obligations
  • Avoid emissions (Article 4).
  • Be registered as producer in the F-gas Portal. (Article 20)
  • Have sufficient production rights from the Commission, starting from 2025 (Articles 14, 15  and Annex V).
  • Ensure correct labelling of container (Article 12).
  • Ensure that all HFCs are covered by sufficient HFC quota in the F-gas Portal when placing them on the EU market (HFC quota system Article 16 to 19, Article 21 and Annexes VII and VIII).
  • Draw up a declaration of conformity which includes evidence confirming the pre-established binding arrangements for the return of the container for the purpose of refilling (Article 11). Non-refillable containers cannot be imported, except for laboratory uses.
  • Draw up a declaration of conformity with additional supporting documents proving that any R23 (trifluoromethane) by-production has been destroyed or recovered using best available technologies (Article 4).
  • From 2025 report on F-gas related activities by 31 March for the previous year (Article 26 and Annex IX). There is no threshold for HFCs, whereas a minimum threshold of 100t CO2eq applies for other F-gases. In 2024, for reporting on 2023 activities, the rules under Regulation (EU) 517/2014 remain applicable with the exception that quota holders that have not placed HFCs on the market in 2023 must submit a nil report in 2024.

Exporter of bulk HFCs

Important: Non-refillable containers cannot be exported (Article 11), including under transit or temporary storage.

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

 Main obligations
  • Avoid emissions (Article 4).
  • Have an export license (=valid registration as bulk exporter in the F-gas Portal) prior to the export (Articles 20 and 22, F-gas Portal Implementing Act, Registration guidelines).
  • Ensure correct labelling of container (Article 12).
  • May not export non-refillable containers (Article 11).
  • Respect export prohibitions 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).
  • Report on the F-gas related activities by 31 March for the previous year (Article 26, Annex IX, Reporting Implementing Act, and Reporting FAQ). The minimum threshold for reporting on HFCs will no longer apply from 2025, meaning that all quantities must be reported. For other F-gases, the threshold remains at 100t CO2eq. For reporting in 2024 on 2023 activities, the rules under Regulation (EU) 517/2014 remain applicable. 

Importers, Producers, or exporters of other F-gases in bulk (non-HFCs)

 Note: Annex I (Section 2 and 3), II, or III of Regulation (EU) 2024/573.

  • Avoid emissions (Article 4).
  • Have an import license, which is a valid registration as an F-gas (non-HFC) bulk importer in the F-gas Portal prior to the import (business specification in the F-gas Portal: “Are you a Producer / Importer / Exporter of other fluorinated greenhouse gases (non-HFCs) in bulk listed in Annex I, II or III” )(Article 20, 22 and 23, F-gas Portal Implementing Act, registration guidelines).
  • Draw up a declaration of conformity which includes evidence confirming the binding arrangements for the return of the container for the purpose of refilling (Article 11). Note that non-refillable containers cannot be imported under any customs procedure, including under temporary storage, exported, used or transported except for laboratory uses.
  • Draw up a declaration of conformity with additional supporting documents proving that any R23 (trifluoromethane) by-production has been destroyed or recovered using the best available technologies (Article 4).
  • Ensure correct labelling of the F-gas container prior to placing on the market, supplying or making available to others (Article 12 of the F-gas Regulation and Labelling Implementing Act).
  • Provide the required information in the customs declaration document (Article 23).
  • Report on F-gas-related activities by 31 March every year for the previous year’s activities. There is no minimum threshold for producers, importers and exporters of HFCs, whereas am minimum threshold of 100t CO2 equivalent applies to other F-gases (Article 26 and Annex IX of the F-gas Regulation, Reporting Implementing Act, and Reporting FAQ).
  • Have an independent verification report submitted by an auditor in case the placing on the market of HFCs amounts to 1000t CO2equivalent or more for the previous year’s activities, 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 at Help and registration guidelines for auditors.

Undertakings receiving HFCs in bulk exempted from quota requirements directly from an importer or producer of HFCs for:

Companies - F-gas in bulk
  • Destruction.
  • Feedstock applications.
  • Direct export of bulk gases.
  • Military equipment.
  • Etching of semiconductor material or the cleaning of chemicals vapour deposition chambers within the semiconductor manufacturing sector.
Main obligations

Undertakings receiving HFCs directly from an importer or producer of HFCs for producing MDIs for pharmaceutical products

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

Main obligations

Undertakings destroying or reclaiming fluorinated greenhouse gases (HFCs and non-HFCs) (listed in Annex I, II, or III to the F-gas Regulation

Destroying - F-gas in bulk
Main obligations
  • Avoid emissions (Article 4).
  • Be registered in the F-gas Portal: business specification in the F-gas portal for destruction “Are you an undertaking destroying fluorinated greenhouse gases listed in Annex I, II or III”; or for reclamation “Are you an undertaking reclaiming fluorinated greenhouse gases listed in Annex I, II or III” (Article 20, F-gas Portal Implementing Act, and registration guidelines)
  • Ensure that HFCs are destroyed in accordance with approved methods under the Montreal Protocol (Article 4).
  • Report on destroyed HFCs and on reclaimed quantities exceeding 1 metric tonne or 100t of CO2eq of F-gases by 31 March for the previous year in accordance with Article 26 and Annex IX of the F-gas Regulation (Reporting Implementing act, and reporting FAQ).

Undertakings using F-gases (HFCs and non-HFCs) as feedstock.

Feedstock  - F-gases in bulk

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

Main obligations

Distributor of bulk F-gases

Main obligations
  • Avoid emissions (Article 4).
  • Keep evidence of the return arrangements for refillable F-gas containers (Article 11).
  • May sell exclusively to undertakings holding an F-gas certificate or a training attestation, as relevant.
  • No obligation to register in the F-gas Portal or to report under Article 26 of the F-gas Regulation.