EU F-Gas Regulation HFC Quota System and Charging Restrictions for Refrigerants
ENFORCEMENT TIMELINE
In force since March 11, 2024 (quota allocation rules apply from January 1, 2025)
Overview
This card focuses on the specific operational practice for the "quota system" and "equipment charge restrictions" for refrigerant HFCs (hydrofluorocarbons) under Articles 15 and 16 and related provisions of the EU F-Gas Regulation (Regulation (EU) 2024/573).
HFCs placed on the EU market (whether in containers or charged into refrigeration, air-conditioning, and heat pump equipment) are subject to a quota system with an annual cap set on a CO2-equivalent basis, progressively reduced from the 2015 baseline to zero by 2050 (full phase-out). Producers and importers must apply for quota allocations through the F-Gas Portal, with additional application windows offered by June 1, 2024, April 1, 2027, and at least every three years thereafter for businesses that produced HFCs in 2022. Recovered and reclaimed HFCs are not subject to the quota. Imports and exports of HFCs and HFC-containing products and equipment between countries that are not signatories to the Montreal Protocol are prohibited from January 1, 2028.
Enforcement Timeline
March 11, 2024: The EU F-Gas Regulation (Regulation (EU) 2024/573) enters into force, repealing the previous Regulation (EU) 517/2014.
January 1, 2025: Quota allocation rules and labelling and product information rules take effect.
2026–2032: Use of high-GWP refrigerants for servicing and maintenance is progressively banned (with application timing varying by use and GWP level).
January 1, 2028: Import and export of HFCs and HFC-containing products between non-Montreal Protocol signatory countries is prohibited.
2050: The HFC quota reaches zero, achieving full phase-out.
Business Impact
Refrigerant and HVAC equipment manufacturers and importers need to reliably complete quota applications and registration through the F-Gas Portal to secure the necessary refrigerant volumes. Given the annual quota reduction schedule, businesses need to incorporate a transition plan toward low-GWP and natural refrigerants into their medium- to long-term procurement strategy.
Servicing and maintenance operators need to accurately track the application timing of servicing-use restrictions, which vary by equipment type and refrigerant GWP level, and secure procurement routes for recovered and reclaimed refrigerant along with proper compliance documentation. Businesses trading with countries that are not signatories to the Montreal Protocol also need to review their supply chains ahead of the 2028 import/export ban.
