F-gases in business

This page covers the use of F-gases in equipment and products, as well as their manufacture, import, installation and maintenance.

The quota system

(Companies importing annually more than 100 t CO2-eq. of bulk F-gases from outside the EU)

The quota system influences the amount of F-gases and their mixtures placed on the market each year. Quotas take into account the global warming potential of different HFCs relative to carbon dioxide (GWP)- the lower the HFCs GWP, the more kilograms can be imported or produced. Here are some of the most common refrigerants and their GWP values.

The quota system applies to companies that produce or place on the EU market more than 100 t CO2-eq. HFC compounds or mixtures containing them per year. Quotas are free of charge and need to be applied for in the spring of the previous year. Guidance on how to make a quota declaration can be found here (pdf). New entrants are allocated a fixed amount of quota and companies that have been over 3 years in the system, on the basis of past imports and manufacturing data. The quotas are annual and company-specific. Quotas can be trasfered to another company in the EU and the companies able to do so between 2021-2023 can be found here (pdf).More information and guidance on quota system can be found here (pdf). Imports from outside the EU without adequate quota (applies to more than 100 t CO2-eg.) is punishable under the Environmental Protection Act (527/2014). In addition, the EU Commission will reduce 200% of the amount by which the quota was exceeded from the following quota allocations.

When placing F-gases or Annex II gases on the F-gas Regulation on the market, the producer or importer must demonstrate that trifluoromethane (HFC-23) produced as a by-product during the manufacturing process has been disposed of or recovered according to best available techniques. This applies i.e. to the import of R32, R407, R410A and R404A. Guidance on the certificate of disposal or recovery of the HFC-23 by-product can be found here (pdf).

The quota system is managed by the EU Commission and governed by Articles 15-18 of the F-gas Regulation.

Great-Britain (Brexit)

Britain's withdrawal from the EU has changed the country's status to a third county. After the end of the transition period from 1st of January 2021, UK will no longer be part of EU*s quota system but will have its own system in place. Annual imports of over 100 t CO2-eq. of F-gases from outside the EU (such as the UK) require a quota and registration in the EU F-gas registry. Companies that export F-gases over 100 t CO2-eq. per year, from the EU to the UK, must be part of UK's own quota system.  

Checklist of legal requirements for importing over 100 t CO2-eq. of F-gases in bulk:

Before import

After importation

  •  Report information on imported F-gases via F-gas register on annual basis. The deadline for reporting the previous year is the 31st of March. The origin of imports must be indicated from 2020 onwards. Guidance (pdf).
  •  The report needs to be verified by an independent auditor before 30.6. if the reported amount of F-gases exceeds 10 000 t CO2-eq. The document must be kept for 5 years. More information (pdf).
  •  F-gases supplied by the procuder or the importer for direct export from the EU must also be verified (companies need to be registered). This obligation applies to all imports. 

Import of equipment pre-charged with F-gases

(Companies importing annually equipment containing more than 100 t CO2-eq. of F-gases from outside the EU)

heat pump
@ Ulla Schildt.

F-gases imported in pre-charged equipment from outside the EU (over 100 t CO2-eq. annually) are included in the quota system and authorization to use the quotas is needed. 

Checklist of legal requirements for importing over 100 t CO2-eq. of F-gases in pre-charged equipment:

Before import

After importation

  • The declaration of conformity and other documentation need to be verified by an independent auditor where the equipment is pre-charged with F-gases not counted in the quota system prior charging. The verification report (pdf) needs to be uploaded into F-gas registry annually by 31.3. when the imported amount exceeds 100 t CO2-eq.
  • When the imported amount exceeds 500 t CO2 -eq. this needs to be reported (pdf) to F-gas registry annually by 31.3.

Other activities with obligations:

  • Export: Register and report by 31.3. when exporting more than 100 t CO 2 -eq. annually in bulk.
  • Destruction:  A company is obliged to report when annual destruction of F-gases exceeds 1 000 t CO 2 -eq. by 31.3. 
  • Equipment manufacturers: A company must draw up a declaration of conformity for equipment manufactured and to be sold in the EU. The equipment must be properly labeled according to Regulation 2017/2068.
  • Feedstock use: A company is obliged to report over 1 000 t CO 2 -eq. of F-gases used as feedstock annually by 31.3. Companies need to be registered. 
  • Reporting: Each producer and importer that places on the market F-gases to be used in producing metered dose inhalers for the delivery of pharmaceutical ingredients, in military equipment or in the etching of semiconductor material or the cleaning of chemical vapour deposition chambers within the semiconductor manufacturing sector.  

Importing F-gases below 100 t CO2-eq. a year

If the total amount of imports both as bulk and in pre-charged equipment is less than 100 t CO2-eq. per year, the imports are not part of the quota system and thus the company's are not obliged to register in the F-gas registry. The imports of prohibited products, i.e. F-gases in disposable cylinders is prohibited. The products need to have correct labelling.  

The selling of equipment containing F-gases

Non- hermetically sealed equipment charged with F-gases shall only be sold to the end user where evidence is provided that the installation is to be carried out by an undertaking certified in accordance with Article 10. The registry of certified undertakings is maintained by Tukes and the information can be checked from their website easily.  

The selling of F-gases in bulk

F-gases and their mixtures may only be sold to certified persons or companies for the uses covered by the qualification requirements (eg. installation and maintenance). Companies must keep records, which provide the name and the certificate number of the purchaser, the substance sold and the sold quantity, in relation to all their sales. The records must be kept for five years and shall be made available to the authorities upon request. There is no obligation to keep records of the sales to a company that transports or supplies F-gases. Refrigerants must be handled with care and intentional releases to the atmosphere are prohibited. F-gases may only be sold in refillable cylinders and return for refilling must be arranged. 

Certification requirement of persons carrying out installation and maintenance

Equipment containing F-gases may only be installed, serviced, maintained or repaired by companies with appropriate certificates. Information on institutions providing qualification training can be found on the website of Finnish Safety and Chamicals Agency (Tukes). Tukes also maintains a registry of qualified personnel.

The use of F-gases with GWP of 2500 or more in equipment maintenance

From 1.1.2020 the use of F-gases with a GWP of 2500 or more used for the maintenance  or servicing of existing refrigeration equipment with a charge size of 40 tonnes of CO2-eq. or more, has been prohibited. This does not apply to military equipment or equipment intended for applications designed to cool products to below -50 ºC. However, reclaimed or recycled substances may be used until 2030.  

Reporting obligation to Finnish authorities

Upon request, users of F-gases must report annually to the Finnish Environment Institute (SYKE) information on the use, import, export and disposal of F-gases for the greenhouse gas inventory. SYKE asks companies to reply to the refrigerant survey at the beginning of the year.

Published 2020-08-24 at 9:13, updated 2021-06-21 at 9:56