F-Gas Regulation

Regulation scope

The Regulation applies to the fluorinated greenhouse gases whether alone or as mixtures listed in

• Annex I – HFCs, PFCs, SF6 and Iso-C3F7CN
• Annex II – Unsaturated hydro(chloro)fluorocarbons (HFOs and HCFOs), HFEs used as anaesthetics, NF3 and SOF2
• Annex III – Fluorinated ethers (HFEs), ketones and alcohols, and other specified fluorinated compounds

It applies to products and equipment, and parts thereof, containing fluorinated greenhouse gases or whose functioning relies upon those gases.

 In this summary the term HFCs refers to those HFCs listed in Annex I Section 1. The terms HFO and HCFOs used it refer to those substances listed in Annex II section 1.

Key measures of the new F-gas Regulation are:

• Applies to an expanded range of fluorinated gases including HFOs and HCFOs
• HFOs and HCFOs are subject to measures including containment and product prohibitions (under the previous F-regulation they were subject to reporting requirements only).
• Reduces hydrofluorocarbons consumption and emissions. The quota system for HFCs has a steeper reduction in the quantities that importers and producers may place on the EU market, and in 2050, HFCs will be phased out in the EU. The HFC phase down is only applicable to virgin HFCs. It is not applicable to HFCs, which were recovered and recycled or reclaimed in the EU , or to HFOs and HCFOs. In case recycled or reclaimed HFCs are imported into the EU from outside the EU, the HFC phase down applies to them as well.
• An expanding quota system includes HFCs used in metered dose inhalers from 1st Jan. 2025.
• The allocation of quota is subject to the payment of the amount due which equals 3 Euro for each tonne of CO2eq of quota to be allocated from 1st Jan. 2026.
• Additional prohibitions on F-gas equipment, products and use of F-gases are included.
• Stricter rules to prevent emissions by covering additional equipment and gases, expanding measures to prevent leakage during transportation, installation, servicing, and disposal of equipment, products and certain building foams.
• Combat illegal trade (illegal imports of HFCs), with enhanced enforcement and monitoring in the Member States by more digitalisation and electronic automation of custom control.
• Production of HFCs in the EU is capped and starting in 2025 producers receive rights equivalent to 60% of their average annual production from 2011 to 2013. This rate will decline to 15% by 2036.
• Ensure compliance with the Montreal Protocol.

HFC Phase Down under Regulation 2024/573 (Articles 16 & 17)

• The HFC phase down is only applicable to HFCs placed on the EU market for the first time. It is not applicable to HFCs, which were recovered and then either recycled or reclaimed in the EU (recycled or reclaimed HFCs imported from outside the EU are subject to the phase-down). HFCs used as feedstock or etching and cleaning in the semiconductor manufacturing sector are exempted from the quota use
• F-gas Regulation 2024/573 includes the MDI sector from 2025 (excluded in the previous regulation) which effectively results in a steeper reduction.
• Steeper reductions occur in 2027 compared to the previous regulation and the reduced quantity also includes HFCs used for MDIs.
• The Regulation allows for reviews of the impact of the HFC phase-down on the heat pump market, with regard to the attainment of the REPowerEU heat pump deployment targets, with the option, dependant on the review outcome, of allowing limited additional quota in 2025-2026 (up to about 10.3% of maximum quantity) and 2027-2029 (up to about 6.6% of maximum quantity). Article 17 (7).
• The previous regulation effectively did not look beyond 2030 with the review including a forecast of the continued demand for hydrofluorocarbons up to and beyond 2030. The new regulation phases out virgin HFCs in 2050.
• Before 1 January 2040, the Commission shall review the needs for hydrofluorocarbons in the sectors where they are still used and the phase-out of HFC quota set out in Annex VII for the year 2050 (Article 35)

Requirements for refillable containers for HFCs, HFOs and HCFOs

• Like HFCs, it is prohibited to supply HFOs or HCFOs in non-refillable containers. These are defined as containers which cannot be refilled without being adapted for that purpose; and containers which could be refilled but are imported or placed on the market without provision having been made for their return for refilling. This does not apply to containers for laboratory or analytical uses of fluorinated greenhouse gases. Article 11(3).
• Undertakings which place fluorinated greenhouse gases in refillable containers on the market  (including HFCs, HFOs and HCFOs) shall produce a declaration of conformity at the moment of release for free circulation that includes evidence confirming that there are binding arrangements in place for the return of those containers for the purpose of refilling, in particular identifying the relevant actors, their obligatory commitments and the relevant logistical arrangements. Those arrangements shall be made binding on the distributors of the refillable containers for fluorinated greenhouse gases to the end user. Article 11(4).

HFOs, HCFOs and Regulation 2024/573- key measures

• The phase-down of HFCs does not apply to HFOs and HCFOs.
• Placing on the market prohibitions that refer to fluorinated gases other fluorinated gases apply to HFOs and HCFOs whether alone or in mixtures. See market prohibitions table showing where HFOs and HCFOs are included. Article 11(1) and Annex IV. 
• Refrigerants blends that contain HFCs, HFOs and/or HCFOs are subject to the HFC phase-down and market prohibitions that apply to HFCs.  See market prohibitions table showing where HFCs, HFOs and HCFOs are included. Article 11(1) and Annex IV.
• Containment measures apply to HFOs and HCFOs (Chapter II). The charge quantities that determine leak check requirements and leak detection systems are defined by weight for HFOs and HCFOs (due to their ultra-low GWPs), whereas for HFCs the quantity is defined as CO2e tonnes. For refrigerant blends containing HFCs, HFOs and/or HCFOs both requirements would need to be considered. Article 5 and 6.
• Recovery measures (including subsequent recycling, reclamation or destruction) apply to HFOs and HCFOs. (see Article 8)
• Labelling and product and equipment information applies to HFOs and HCFOs. Article 12 

Placing on the Market Product Bans (Article 11 & Annex IV)

• Applies to HFCs, HFOs and HCFOs as shown in the table adapted from Annex IV
• Repair and servicing of existing equipment listed in Annex IV is allowed, subject to restrictions. Article 11 (1) and Article 13.
• The prohibitions listed in Annex IV, shall not apply to equipment for which it has been established, pursuant to ecodesign requirements adopted under Directive 2009/125/EC, that its lifecycle CO2 equivalent emissions would be lower than those of equivalent equipment which meets those relevant ecodesign requirements.
• As part of a review required by 2030 the Commissions shall evaluate whether cost-effective, technically feasible, energy-efficient, sufficiently available and reliable alternatives exist, which make the replacement of fluorinated greenhouse gases possible in the products and equipment listed in Annex IV covered by prohibitions that have not yet become applicable at the time of the evaluation, especially products and equipment subject to full fluorinated greenhouse gas prohibitions, including ‘split’ air conditioners and heat pumps (Article 35 (5a);
• Following entry into force of Regulation 2024/573, four derogations have been published providing time limited exemptions for the use of fluorinated gases in certain equipment – see https://climate.ec.europa.eu/eu-action/fluorinated-greenhouse-gases/f-gas-legislation/f-gas-legislation_en

Placing on the market prohibitions for HFCs, HFOs and HCFOs (adapted from Annex IV)

This table does not take account of derogations

Emissions Avoidance

• Containment measures apply to HFCs, HFOs and HCFOs (Chapter II). The charge quantities that determine leak check requirements and leak detection systems are defined by weight for HFOs and HCFOs (due to their ultra-low GWPs), whereas for HFCs the quantity is defined as CO2e tonnes. For refrigerant blends containing HFCs, HFOs and/or HCFOs both requirements would need to be considered. Article 5 and 6.
• Operators of specified equipment that contain fluorinated greenhouse gases (including HFCs, HFOs and HCFOs), not contained in foams, shall ensure that those substances are recovered, and after the decommissioning of the equipment, they are recycled, reclaimed or destroyed. Article 8.
• Recovery and destruction requirements apply to HFOs, HCFOs, as well as HFCs. Article 8
• Any recovered fluorinated greenhouse gases listed in Annex I and in Section 1 of Annex II (includes HFCs, HFOs and HCFOs) shall not be used for filling or refilling equipment unless the gas has been recycled or reclaimed. Article 8.
• Prior to container disposal the recovery of any residual gases is required to make sure they are recycled, reclaimed or destroyed. Article 8.
• From 1 January 2025, defined building foams containing HFOs, HCFOs (and HFCs) during renovation, refurbishing or demolition activities, emissions are avoided to the extent possible by handling the foams or the gases contained therein in a way that ensures the destruction of those gases. In the case of recovery of those gases, the recovery shall be carried out only by appropriately qualified natural persons. Article 8 (8 &9). For defined building foams where removal is not technically feasible, documentation shall be prepared. Article 8 (9).

Labelling (Article 12)

The new labelling requirements entered into force on 1 January 2025. These apply to fluorinated gases including HFCs, HFOs and HCFOs. This affects product labels, manuals, relevant advertising, and websites. HFCs listed in Annex I section 1 still use AR4 (Fourth Assessment Report of

UNEP) for GWP values which aligns with the Montreal Protocol. GWP values for HFOs, HCFOs listed in Annex II section 1 are based on AR6 values where available, and non-fluorinated gases listed in Annex VI are from a number of sources. This means that GWP values for some refrigerant blends and other blends may have changed, requiring information to be reviewed and if necessary updated for labels.

Download a spreadsheet containing compositions, GWP-100s and safety classifications for all refrigerant blends subject to the F-gas Regulation 2024/573.

Labelling requirements apply to a wide range of products and equipment and where exemptions apply.  See in particular Article 12(1) and Commission Implementing Regulation (EU) 2024/2174 of 2 September 2024 laying down rules for the application of Regulation (EU) 2024/573 of the European Parliament and of the Council as regards the format of the labels for certain products and equipment containing fluorinated greenhouse gases and repealing Commission Implementing Regulation (EU) 2015/2068 available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AL_202402174

Producers, importers and distributors

The supply chain providing fluorinated gases to the market shall also take measures to minimise emissions, in addition to measures that apply to containers.

• During the production, storage, transport and transfer of fluorinated greenhouse gases from one container or system to another, to equipment or to a facility, the undertaking concerned shall take all necessary precautions to limit release of fluorinated greenhouse gases to the greatest extent possible. This paragraph shall also apply where fluorinated greenhouse gases are produced as by-products. Article 4 (4).
• Without prejudice to Article 11(1), first subparagraph (Restrictions on placing on the market and sale), the placing on the market of fluorinated greenhouse gases shall be prohibited, unless producers or importers provide evidence to the competent authority of a Member State at the time of such placing on the market, that any trifluoromethane {HFC-23], produced as a by-product during the production process of the fluorinated greenhouse gases, including during the production of feedstock for the production of those gases, has been destroyed or recovered for subsequent use, using best available techniques.

For the purpose of providing that evidence, producers and importers shall draw up a declaration of conformity, accompanied by supporting documentation:

(a) establishing the origin of the fluorinated greenhouse gases to be placed on the market;

(b) identifying the production facility of origin of the fluorinated greenhouse gases to be placed on the market, including an identification of those facilities of origin of any precursor substances that involve the generation of chlorodifluoromethane (R-22) as part of the production process to produce the fluorinated greenhouse gases to be placed on the market;

(c) proving the availability and operation of the abatement technology at the facilities of origin equivalent to UNFCCC- approved baseline methodology AM0001 for incineration of trifluoromethane waste streams or proving the capture and destruction methodology that ensured that emissions of trifluoromethane are destroyed in accordance with the requirements under the Protocol;

(d) on any additional information facilitating the tracking of the fluorinated greenhouse gas prior to import.

Producers and importers shall keep the declaration of conformity and supporting documentation for a period of at least 5 years from the placing on the market and make them available, upon request, to the competent authority of the Member State concerned or to the Commission.

The Commission may, by means of implementing acts, determine the detailed arrangements relating to the declaration of conformity and supporting documentation. Article 4(6).