Updates on the amendment to the F-Gas Regulation

The amendment to Regulation (EU) 2024/573, which entered into force on 11 March 2024, aims to accelerate the EU's phase-out of emissions from fluorinated greenhouse gases. The rules governing the import and export of fluorinated greenhouse gases have therefore been tightened. Companies that import or export fluorinated greenhouse gases to or from the EU must now register in the newly established F-Gas Portal to obtain a valid license. The beginning of 2025 brought further dynamic developments: New regulations on labeling requirements and the allocation of quotas, which are subject to fees, have been applicable since 1 January 2025. Furthermore, supplementary implementing regulations and EU Commission guidelines for registration in the F-Gas Portal were published in March 2025, providing valuable assistance. The Regulation (EU) 2024/573 (hereinafter referred to as the "F-Gas Regulation") entered into force on 11 March 2024, replacing Regulation 517/2014, which had been in force since 1 January 2015. Several implementing regulations also exist that supplement the provisions of the F-Gas Regulation. Since 1 January 2025, the new rules on labeling requirements and the rules on the modalities of quota allocation for placing hydrofluorocarbons on the market have been applicable. Furthermore, since January 1, 2025, bans have been in place on placing on the market products containing fluorinated greenhouse gases with a particularly high global warming potential. Additional regulations concerning the use of the "F-Gas Portal" have been in effect since March 3, 2025.

The F-Gas Regulation as a building block of the European Green Deal

With the revision of the F-Gas Regulation, the EU Commission is advancing the goal set by the European Green Deal of making Europe the first climate-neutral continent by 2050. The EU is pursuing the ambitious goal of reducing emissions of fluorinated greenhouse gases to "zero" by 2050. Fluorinated greenhouse gases are artificially produced chemicals that are very potent greenhouse gases, often thousands of times more powerful than carbon dioxide (CO2). The regulation applies to the fluorinated greenhouse gases and mixtures listed in Annexes I to III of the regulation. They are considered particularly harmful to the climate; however, they are still used in certain industries. In particular, refrigeration systems, air conditioning systems, and heat pumps rely on fluorinated greenhouse gases due to the use of chemical substances. The EU aims to create incentives by tightening the F-Gas regulation to switch to already available alternatives with lower climate impacts or to develop innovative new solutions. Key Changes: The provisions of the previous Regulation (EU) 517/2014 already resulted in a gradual reduction of EU-wide emissions of fluorinated greenhouse gases. The revised F-Gas Regulation now aims for a faster EU phase-out of fluorinated greenhouse gas emissions. This applies to the import and export as well as the production and use of these greenhouse gases within the Union. The bans on placing certain products on the market and using them have been amended and expanded. Registration in the F-Gas Portal: Importers and exporters of fluorinated greenhouse gases, as well as equipment and products containing them, will in future be required to register in advance in the electronic F-Gas Portal and present valid licenses to customs authorities before importing or exporting. The F-Gas Portal replaces the electronic register previously maintained by the EU. The F-Gas Portal will be linked to the EU's Single Window environment for customs once it is established, enabling customs authorities to handle the implementation of import and export regulations. The regulation further reduces the quantities of hydrofluorocarbons (HFCs) available annually in the EU by 2050. The production of HFCs within the Union will only be permitted after the allocation of quantitative production rights. As with the previous regulation, manufacturers and importers of HFCs must apply for quota allocations before placing them on the market. However, the allocation of quotas will now be subject to a fee of €3 per tonne of CO2 equivalent allocated. Manufacturers and importers have the option of paying only a portion of their allocated quota, thereby reducing their allowance according to their needs. Until 2028, any unused quotas will be distributed free of charge. From 2028 onwards, unused quotas will be canceled. Furthermore, the rules for transferring quotas have been tightened. Allocated quotas may now only be transferred once. Outlook and Challenges: Companies that import or export fluorinated greenhouse gases into or from the Union must register on the F-Gas Portal and obtain a license. Since January 1, 2025, the ban on placing these gases on the market has also been applied, for example, to additional refrigeration equipment, refrigeration systems, fire protection equipment, and personal care products. Furthermore, the list of prohibited products containing fluorinated greenhouse gases, as well as restrictions on their use, is continuously being expanded. Since January 1, 2025, a ban has also been in effect for metered-dose aerosols filled with the hydrofluorocarbons listed in Annex I, Group 1. From March 3, 2025, the F-Gas Portal will be linked to the customs authorities' currently inactive single-window environment. The European Commission has already published and integrated the corresponding TARIC codes. The European Commission also successively publishes exemptions from the regulation for specific goods. For example, on December 16, 2024, exemptions were published for blood transport boxes, blood plasma contact shock freezers, and mechanical cryogenic freezers with a temperature of -150 degrees Celsius. The European Commission also published guidelines for registration in the F-Gas Portal on March 17, 2025. On March 31, 2025, implementing regulations concerning certificates for solvent recovery and work on fire protection systems and electrical switchgear were also published. The Commission's communications should therefore be monitored.