Art. 15 : Reduction of the quantity of HFCs placed on the market (phase-down)

Art. 15-18: General overview of Chapter IV, dealing with the phase down & quota system

  • Articles 15 to 18 only cover HFCs listed in Annex I of the F-Gas Regulation
    • HFOs are not covered (Annex II)
  • Articles 15 to 18 only cover HFCs placed on the EU Market
    • do not control the production of HFCs
    • there are some Exempted uses
  • The quota allocation system is Market Based, allowances are transferable
    • Use it or Lose it principle, allowances cannot be moved forward/backward
    • Three year cycle for baseline determination
    • 11% reserved for “New Entrants”
  • The phase down consists of a progressive reduction according to the following schedule:
Years Percentage to calculate the maximum quantity of hydrofluorocarbons to be placed on the market and corresponding quotas
2015 100%
2016-17 93%
2018-20 63%’
2021-23 45%
2024-26 31%
2027-29 24%
2030 21%
  • Baseline and allowances are expressed in tonnes of CO2 equivalent
    • baseline = 183 million tonnes CO2 equivalent
    • Not substance specific
  • An EU-wide Electronic Registry has been created

Art. 15: Reduction of the quantity of HFCs

Article 15 lays down the general principles of the reduction of the quantity of hydrofluorocarbons placed on the market. New!

In addition to the measures to control emissions and some uses of fluorinated greenhouse gases that were implemented in the previous Regulation, the cap and reduction of HFCs limits the quantity of HFCs that can be placed on the market on a CO2 equivalent basis.

Each producer and importer meeting the requirements set out in Article 16 (quota allocation) receives a quota each year. The quotas are calculated in accordance with Annex V (see below).

Producers and importers that import less that 100 tonnes of CO2 equivalent of HFCs per year are exempt. This equates to about 70 kg of HFC 134a.

There are a number of uses that are excluded from the placing on the market quota.
  • Destruction: HFCs imported into the Union for destruction;
  • Feedstock: HFCs used by a producer in feedstock applications or supplied directly by a producer or an importer to undertakings for use in feedstock applications;
  • Export: HFCs supplied directly by a producer or an importer to undertakings, for export out of the Union, where those HFCs are not subsequently made available to any other party within the Union, prior to export;
  • Military equipment: HFCs supplied directly by a producer or an importer for use in military equipment;
  • Semiconductor use: HFCs supplied directly by a producer or an importer to an undertaking using it for the etching of semiconductor material or the cleaning of chemicals vapour deposition chambers within the semiconductor manufacturing sector;
  • Metered dose inhalers (MDIs): from 1 January 2018 onwards, HFCs supplied directly by a producer or an importer to an undertaking producing MDIs for the delivery of pharmaceutical ingredients.
Specifically included in the quota
  • Pre-blended polyols: HFCs contained in pre-blended polyols.
  • Pre-charged equipment: From 1 January 2017 HFCs contained in pre-charged equipment must be accounted for within the quota system (see Article 14).
Exemption from the quota

Article 15 para 4 sets out the possibility of an exemption from the quota where certain exacting conditions are met.

Hardship Clause

If no alternatives are available and supply can only be assured at disproportionate cost.

Note on Annex V of the FGas Regulation, referred to in Article 15




The maximum initial quantity for each issued quota is the annual average of the quantity in CO2 equivalent tonnes placed on the market into the Union during the period from 2009 to 2012 (the baseline period). This baseline quantity is 183 million tonnes of CO2 equivalent, with an average GWP for the HFCs placed on the market during this period of approximately 2175.

The corresponding approximate annual average quantity of HFCs in metric tonnes placed on the market during the baseline period was about 83000 tonnes. The breakdown of this roughly corresponds to:

HFC-134a -> 50%
HFC-410A -> 12%
HFC-404A -> 23%
Other HFCs -> 15%

HFC reduction schedule

The maximum quantity that can be placed on the market and the individual quotas are a percentage of the baseline quantity of 183 million tonnes of CO2 equivalent.

2015 2016-17 2018-20 2021-23 2024-26 2027-29 2030
100% 93% 63% 45% 31% 24% 21%

Reduction schedule implications

The steep decline in HFC availability in 2018 due to the large quota reduction will require a major increase in the use of lower GWP HFCs and HFC containing mixtures in order to meet the expected market demand. Assuming that the market demand is similar in 2018 to the baseline quantity then the average GWP for HFCs placed on the market would need to reduce significantly.

Average Baseline GWP for HFCs placed on the market approximately: 2175
Required average GWP in 2018 for the same market supply in tonnes: 1370
In order to achieve such a reduction and maintain supply, if demand remains similar, higher GWP refrigerants in particular HFC-404A will need to be replaced by lower GWP options.

EPEE information on phase-down:
Reference to Gapometer (EPEE website):

Additional references

DG CLIMA Guidance documents for F-Gas Regulation

  • Guidance document: Information for technicians and users of refrigeration, air conditioning and heat pump equipment containing fluorinated greenhouse gases

Gluckman Consulting EU F-Gas Regulation Information Sheets

  • Information Sheet 28: The Phase Down Process