EU strengthens controls of fluorinated gases in international trade operations

As of 15 January 2025, the European Union (EU) has updated the control measures on fluorinated greenhouse gases with the entry into force of Regulation (EU) 2024/573. The regulation affects the import, export, introduction, production, supply and use of these gases, as well as products and equipment containing or relying on them. 

The most important innovation is the introduction of more stringent controls on the import and export of fluorinated gases. Economic operators who wish to carry out one of the above-mentioned operations will have to comply with several requirements which are detailed in the Regulation. 

Requirements 

Valid licence 

To comply with the regulations, operators must be in possession of a valid licence. A valid registration on the EU F-Gas Portal constitutes a valid licence to operate.  

The European Commission may grant exceptions to the export ban in exceptional cases. 

Any export that is granted an exception must follow the importing countries laws. 

Quota or quota use authorisation

Hydrofluorocarbons (HFC) 

To place hydrofluorocarbons (HFCs) on the EU market, a quota or an authorization to use a quota must be allocated to producers or importers.  

However, for certain uses that are considered essential, the EU Commission has established the following quota exemptions: 

• HFCs imported for destruction,  
• HFCs used as feedstocks in industrial processes 
• HFCs for export outside the EU  
• HFCs used in military equipment and  
• HFCs used in the semiconductor manufacturing sector. 

HFC pre-filled products or appliances 

The sale of the following products containing the gases listed in Section 1 of Annex I to Regulation (EU) 2024/573 is prohibited, unless the quantities of these gases are accounted for within the established quota system:  

• refrigeration appliances,  
• air conditioning   
• heat pumps 
• metered dose inhalers 

The allocation of HFC quotas will be subject to the payment of 3 euros for each tonne of CO2 equivalent to be allocated. The EU Commission will notify, via the F-Gas portal, the total amount due and the deadline for completing the payment to producers and importers, who will have the option to pay only a part of the maximum quota offered and be allocated the quota corresponding to the payment made. 

Until 31 December 2027, unpaid quota will be redistributed free of charge among companies that have paid their full allowance. From 1 January 2028, any quota that have not been paid on time will be cancelled 

The EU Commission may adjust the allocation of quotas, by reducing the maximum amount or by allocating additional quotas, as contingency for possible implementation issues. 

Labelling and information 

From 1 January 2025, the European Union has introduced stricter and more detailed labelling requirements for products and equipment containing fluorinated greenhouse gases in Commission Implementing Regulation (EU) 2024/2174.  

The main objective is to ensure that the information is: 

• clearly legible, as labels must contain information that stands out clearly from the bottom, with appropriate size and spacing to make it easy to read; and 
• indelible, as labels must remain attached and legible for the lifetime of the product. 

The following products and equipment that contain HFC or whose functioning relies upon those gases shall only be placed on the market, subsequently supplied or made available to any other person, if they are labelled as:  

• refrigeration appliances 
• air conditioning  
• heat pumps,  
• firefighting equipment,  
• Switches  
• aerosols, including metered inhalers, 
• F-gas containers,  
• fluorinated gas-based solvents and  
• organic Rankine cycles. 

The mandatory information that must be included on the label are: 

• an indication that the product ‘contains fluorinated greenhouse gases’,  
• the industrial designation of the gas or, if not available, the chemical name of the gas, and, 
• the quantity expressed in weight (in kilograms or grams) and CO2 equivalent (in tonnes) of the HFC contained in the equipment or, in the absence thereof, for which it is designed, using the global warming potential values for HFC given in the ‘GWP’ column of Annexes I, II and III to Regulation (EU) 2024/573.  

The label must indicate whether the equipment is hermetically sealed or if it has a low leakage rate, as appropriate. 

Where relevant, refilled containers containing fluorinated greenhouse gases shall be relabelled with updated information. 

Export prohibition  

From 12 March 2025, the EU prohibits the export of specific products (listed in Annex IV) containing F-gases with a global warming potential (GWP) of 1,000 or more, such as: 

• foams,  
• technical aerosols,  
• stationary refrigeration,  
• air-conditioning, and  
• heat pump equipment.  

This ban does not include military equipment or products allowed to be sold within the EU.  

Document codes to be declared 

The codes to be indicated in the customs declarations will depend on the operation being carried out (import or export), having registered two TARIC measures by the EU Commission: 

• 724 - Control of imports of fluorinated greenhouse gases 
• 765 - Control of exports of fluorinated greenhouse gases 

For these measures, the codes of the certificates to be declared as supporting documents are specified in the EU online tariff database (EU Taric) where the two tables below are displayed to indicate the document to be declared in each flow (Taric code 8424.10.00.80 has been used as an example): 

National Contact Points  

Member States and Norther Ireland contact points can be found here.  

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Further Information:

• Fluorinated greenhouse gases
• EU F-Gas Portal  
• FAQ on F-gases – DG CLIMA