F-gases and ozone-depleting substances

Some common F-gases and their GWP values ​​are listed in the table below. Most of the substances are used as refrigerants, some also as extinguishing agents or propellants, for example. There are a large number of different mixtures and more are being developed.

*R = refrigerant, code XYZ: X = the number of carbon atoms – 1, Y = the number of hydrogen atoms + 1, Z = number of fluorine atoms, R-400- mixtures, R-700- inorganic compounds. 

**GWP-value is a Global Warming Potential index, that describes the climate warming effect of a substance compared to CO₂, which has a  GWP = 1. GWP-values are based on the estimates of the Intergovernmental Panel on Climate Change (IPCC). In the EU's F-gas regulation and the Kigali amendment of the Montreal Protocol, the GWP values ​​of the Fourth Assessment Report (AR4, IPCC 2007) are used, and they are applied in e.g. legislative restrictions. The values ​​in the table are AR4 GWP_100-values, i.e. they describe the warming effect over a period of one hundred years.

Leak checks need to be performed at regular intervals for equipment that contains F-gases such as stationary refrigeration, air-conditioning, heat pumps, fire protection equipment, all refrigerated transport vehicles including container and railcar cooling units, electrical switchgear and organic Rankine cycles (ORC). The obligation for leak checks for mobile equipment begins on March 12, 2027. The leak check obligation applies when the set HFC or HFO threshold value is exceeded. For mixtures, the HFC and HFO content must be taken into account.

Leak inspections do not apply to:

• Electrical switchgear if the leakage is no more than 0.1% per year, the equipment has a leak detection system, or the equipment contains less than 6 kg of F-gases listed in Annex I.
• Hermetically sealed equipment containing less than 3 kg of F-gases in residential buildings.
• Hermetically sealed equipment which has been labelled as hermetically sealed by the manufacturer and which contains less than 10 t CO₂-eq. of HFCs or less than 2 kg of HFOs.

Inspect leak detection system once a year. Electronic switchgear leak detection systems must be checked every 6 years.

Equipment containing at least 500 t CO₂ -eq. of HFCs. or at least 100 kg of HFOs need to be provided with a leakage detection system which alerts the operator or a service company of any leakage. 500 t CO₂-eq. is for example approx. 349 kg of R-134a and approx. 127 kg of R-404A. 

Keep records of maintenance and leak checks. Records need to contain the following information

• the quantity and type of F-gas in the equipment (kg and CO₂-eq.)
• the quantity and date of added or recovered f-gases
• data on whether the installed F-gases have been recycled or reclaimed, including the name, address and license number of the recycling or reclamation facility
• the results of the checks carried out and the identity and certificate number of the undertaking performing the task
• if the equipment was decommissioned, the measures taken to recover and dispose of the F-gases

The record must be shown to authorities upon request. The device owner and the maintenance company must keep the records for at least five years.

Equipment containing ozone-depleting substances

Refrigeration and air conditioning equipment, heat pumps and fire protection equipment containing substances that deplete the ozone layer may be used, but no refrigerant may be added to them in case of leakage or breakage. If such a device contains 3 - 30 kg of refrigerant, it must be checked for leaks every 12 months. The obligation does not apply to hermetically sealed equipment containing less than 6 kg of refrigerant. Equipment containing 3 to 300 kg of refrigerant must be inspected every 6 months, and equipment containing at least 300 kg must be inspected every 3 months.

The correct labelling of refrigerant bottle

• Gas bottle approval mark. π -symbol, identification number of the inspection body and date of manufacture. More information from tukes.fi/en
• Information about the F-gases contained in the product in finnish and swedish. The name of the gas, the amount (kg and CO₂-eq.) and GWP-value. In the case of regenerated gases, information on the batch number, the name and address of the facility in the Union, and in the case of recycled gases, information that the substance has been recycled. More information: F-gas Regulation and Regulation on labelling.
• Warning labels regarding the transport of hazardous substances. More information: tukes.fi/en and markings and warning labels.
• Gas bottle inspection stamp (VAK). More information: tukes.fi/en.
• The UN number (VAK) of the hazardous substance and its shipping name. More information: tukes.fi/en and markings and warning labels.
• Warning label according to the CLP -Regulation. More information: tukes.fi/en
• The name and address of the product manufacturer must be in the container, packaging or product document, and when importing from outside the EU, also the name and address of the importer.
• The labelling must be permanent.

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Labeling of equipment containing refrigerant

• Information about the F-gases contained in the product in finnish and swedish. The name of the gas, the amount (kg and CO₂-eq.) and GWP-value. More information: F-gas Regulation and Regulation on labelling.  
• The name and address of the product manufacturer must be in the container, packaging or product document, and when importing from outside the EU, also the name and address of the importer.
• The labelling must be permanent.

Other labeling requirements: Containers intended for disposal, direct export, use in defense equipment, semiconductor manufacturing, or raw material use must be labeled to indicate that they are for that specific purpose only. The label must also state, "exempt from quota under Regulation (EU) 2024/573 of the European Parliament and of the Council." Containers intended for the production of metered dose inhalers must be labeled to indicate that they are for that specific use only.

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Requirements of the EU F-gas regulation for placing on the market and import of metered dose inhalers containing HFC propellants

New requirements for placing metered dose inhalers containing HFC substances, such as norflurane or apaflurane as propellants on the EU market will apply from 1 January 2025. These are based on EU Regulation (2024/573) on fluorinated greenhouse gases (F-Gas Regulation), which came into force on 11 March 2024 and is directly applicable legislation in EU member states. The Finnish Environment Institute (Syke) is the national competent authority and market surveillance authority for the EU F-Gas Regulation. The Finnish Medicines Agency (Fimea) is responsible for licensing and supervisory tasks in the pharmaceutical sector.

Labelling requirements – additional time to update labels

New labelling requirements for the packaging of metered dose inhalers containing HFC substances (F-Gas Regulation Art 12 and Implementing Regulation on Labelling Art 1):

• From 1 January 2025, products placed on the market must include information that the product contains HFC substances, the name of the substance, the GWP value, and the quantity (weight and CO₂-eq.)
• For small products, the label may only be on the outer packaging, and it may be complemented by a digital label (e.g., QR code)

It has become apparent that meeting the new labelling requirements by 1 January 2025 is challenging. To ensure that the supply of medicines is not interrupted, the Finnish Environment Institute (Syke) and Fimea provide guidance on how to proceed:

Medicines may still be sold in old packaging after 1 January 2025, but an application for a change in packaging labelling in accordance with Article 61.3 of the Medicinal Products Directive (2001/83/EC) must be submitted to Fimea by 1 January 2025. Syke and Fimea require that changes to the packaging labelling be implemented in the next possible batch, and at the latest, the packaging labelling must comply with the EU F-Gas Regulation by 31 December 2025.

Quota System Introduced: Import of metered dose inhalers from outside the EU from 1 January 2025

The quantity of HFC substances imported from outside the EU and manufactured on the EU market is regulated by a quota system. From 1 January 2025, this also applies to metered dose inhalers containing HFC substances (F-Gas Regulation, Art 19) and HFC compounds manufactured or imported for the manufacture of metered dose inhalers (F-Gas Regulation, Art 16). Metered dose inhalers containing HFC substances imported from outside the EU (i.e., not imports from another EU country) must be included in the HFC quota system if the annual import is at least 10 tonnes CO₂-eq. This corresponds to, for example, 6.99 kg for norflurane and 3.11 kg for apaflurane.

Instructions for importing metered dose inhalers containing more than 10 tonnes CO₂-eq. HFC substances can be found on the environmental administration's website, under the section "Advice on importing equipment and products containing F-gases". If your company imports HFC substances for the manufacture of metered dose inhalers from outside the EU, instructions for complying with the legal requirements can be found under the section "Advice on importing F-gases as bulk". In addition, companies receiving HFC substances for the manufacture of metered dose inhalers must be registered in the F-gas portal (instructions and a step-by-step guide).

More information

About the F-Gas Regulation:

• Regulation (EU) 2024/573 of the European Parliament and of the Council on fluorinated greenhouse gases
• Environmental administration website: https://www.ymparisto.fi/en/permits-and-obligations/f-gases-and-ozone-depleting-substances
• EU Commission website
• Finnish Environment Institute: f-gas@syke.fi

About marketing authorisations for medicines:

• European Medicines Agency website
• Advice on change applications: Maria Pirinen (maria.pirinen@fimea.fi)

When selling F-gas refrigerants for installation and maintenance activities, you must: 

• ensure that the buyer is in Tukes' qualification register 
• keep records of sales (including the number of the person's or company's qualification certificate). The record must be shown to the authority upon request. 

Qualifications are not required for F-gases:

• for buying for resale (e.g. wholesalers),
• to sell,
• for collection, transport and delivery.

Refrigerants must be handled carefully and deliberate emissions into the atmosphere are prohibited.

F-gases may only be sold in refillable containers and their return for refilling must be arranged. The containers must have the correct labeling.

When selling devices containing F -gases, that require installation at the place of use (assembly of the refrigerant circuit):

• You must ensure and keep records that the installation is carried out by an entity on Tukes' qualification register. 

• the recommendation is to sell the device to consumers together with a qualified installation. 

  Recommendation for the sale of equipment containing F-gases with installation (pdf, 126 KB)

HFC, CFC and HCFC compounds as heat transfer agents or solvents in equipment, as well as halons in fire extinguishing equipment, must be recovered and delivered to be utilized or treated as waste in the manner required by the Waste Act, when the equipment is taken out of use or when the compounds are removed from the equipment during maintenance. 

From 1.1.2025 foam laminated boards and sandwich panels removed from buildings during repair and demolition work must be treated so that the ozone-depleting substances, as well as HFC and HFO compounds they contain, are recovered for regeneration or disposal. If the removal of the laminated boards is not technically possible, this must be documented in a certificate to be presented to the authorities upon request. To prevent emissions, the insulation should remain as intact as possible and must be collected separately. The insulation must be delivered to a facility with an environmental permit either for the recovery or disposal of gases, or for the disposal of insulation boards, for example, through an incineration process. The F-gas legislation does not prevent the reuse of intact insulation boards or products containing insulation, such as doors, at another site.

The full-time employee of a waste management operator must have a responsible person with technical training or basic training as a waste station operator. The person in charge must be familiar with the type of equipment to be handled, the equipment needed for work and the correct working methods, as well as health, safety and environmental protection obligations.

HFC-, CFC and HCFC-compounds;

• as cooling agents, solvents, foam propellants in class 14 06 01*
• in electrical and electronic equipment  (e.g. refrigerators and freezers) in categories 16 02 11* (equipment used professionally) and 20 01 23* (household equipment)
• in building insulations in class 17 06 03* (including CFC or HCFC compounds) or 17 06 04 (including HFC compounds)
• as laboratory chemicals in categories 16 05 06* and 14 06 02*
• in the insulation of decommissioned vehicles (including refrigerated transport) in class 16 01 21*

Halons

• in pressure packages and containers containing dangerous substances in class 16 05 04*
• Tetrachloromethane and 1,1,1-trichloroethane
• as a laboratory chemical in class 16 05 04*
• other halogenated solvents and solvent mixtures in class 14 06 02*

Methyl bromide

• agricultural chemical waste containing hazardous substances in category 02 01 08

Packages

• empty packaging of or contaminated by substances that deplete the ozone layer in class 15 01 10*

It is prohibited to place the products listed below on the EU market. Placing on the market refers to the import of products into the EU and the sale of products manufactured in the EU within the EU area. These bans apply to new products and devices and do not affect products or devices already in use. More information about other bans that have already entered into force can be found from F-gas Regulation Annex IV.

• Non-refillable containers for fluorinated greenhouse gases used to service, maintain or fill refrigeration, air-conditioning or heat-pump equipment, fire protection systems or switchgear, or for use as solvents
• One-component foams, that contain F-gases with GWP of 150 or more
• Fire protection equipment, that contain HFC-23
• Technical aerosols that contain HFCs with GWP of 150 or more
• Refrigerators and freezers for commercial use (hermetically sealed equipment), that contain HFCs with GWP of 150 or more 
• Stationary refrigeration equipment, that contains HFCs with GWP of 2 500 or more except equipment intended for application designed to cool products to temperatures below – 50 °C
• Multipack centralised refrigeration systems for commercial use with a rated capacity of 40 kW or more that contain F-gases with GWP of 150 or more, except in the primary refrigerant circuit of cascade systems where fluorinated greenhouse gases with a GWP of less than 1 500 may be used 
• Movable room air-conditioning equipment (hermetically sealed equipment which is movable between rooms by the end user) that contain HFCs with a GWP of 150 or more
• Single split air-conditioning systems containing less than 3 kg of F-gases, that contain F-gases with a GWP of 750 or more (e.g. heat pumps)- prohibited from 1.1.2025 
• Extruded polystyrene (XPS) and other foams that contain HFCs with a GWP of 150 or more

The placing on the market of the products, equipment, including parts thereof listed below will be prohibited after the specified date. The prohibitions do not apply to equipment that has been shown, in accordance with the ecodesign requirements adopted under Directive 2009/125/EC, to have lower lifecycle CO2 equivalent emissions than the equivalent equipment. The use, supply, availability, and export of equipment that has been illegally placed on the market are prohibited.

Split air-conditioning equipment and heat pumps:

• 2025: <3 kg of HFC-gases with a GWP of 750 or more
• 2027: ≤ 12 kW, with F-gases with a GWP of 150 or more (air-to-water)
• 2029: ≤ 12 kW, with F-gases with a GWP of 150 or more (air-to-air) and >12 kW, with F-gases with a
• GWP 750 or more
• 2033: > 12 kW, with F-gases with a GWP of 150 or more
• 2035: ≤ 12 kW, with F-gases

2025:  Refrigerators and freezers for commercial use with F-gas with a GWP of 150 or more

2025: Any self-contained refrigeration equipment, except chillers, with F-gas with a GWP of 150 or more

2025: fire protection equipment with F-gases

Refrigeration equipment, except chillers, self-contained refrigeration equipment and multipack centralised refrigeration systems for commercial use

• 2025: Fgases with a GWP of 2 500 or more, except intended to cool products to temperatures below -50 ºC
• 2030: F-gases with a GWP of 150 or more

Self-contained air-conditioning equipment and heat pumps

• 2027: ≤ 12 kW and 12-50 kW with F-gases with a GWP of 150 or more
• 2030: Other self-contained air-conditioning equipment and heat pumps with F-gases with a GWP of 150 or more
• 2032: ≤ 12 kW with F-gases

2025: Personal care products with F-gases

2025: Equipment used for cooling the skin with F-gases with a GWP of 150 or more

2026: Domestic refrigerators and freezers with F-gases

Chillers

• 2027: ≤ 12 kW, with F-gases with a GWP of 150 or more or >12 kW with F-gases with a GWP of 750
• 2032: ≤ 12 kW with F-gases

2030: Technical aerosols with F-gases

2033: Foams with F-gases

Prohibitions for putting into operation of electrical switchgear below. Exceptions in Article 13 of the F-gas Regulation.

• 2026: medium voltage electrical switchgear for primary and secondary distribution ≤ 24 kV with F-gases
• 2028: high voltage electrical switchgear of 52 -145 kV and including ≤ 50 kA short circuit current, with F-gases with a GWP of 1 or more
• 2030: medium voltage electrical switchgear for primary and secondary distribution of 24-52 kV with F-gases
• 2032: high voltage electrical switchgear of 145 kV and more than 50 kA short circuit current, with F-gases with a GWP of 1 or more

National defense supplies are outside the prohibitions. Possibility to deviate from the prohibitions based on safety or medical requirements.

Service and maintenance of all refrigeration equipment with F-gases with a GWP of 2500 or more is prohibited. From 2026 the ban will be extended to air conditioning equipment and heat pumps. The bans mean that no new refrigerant covered by the ban may be added to the equipment. Among the most common substances in use, the maintenance ban applies to e.g. R-404A (GWP=3922). 

The ban does not apply to reclaimed or recycled F-gases in the maintenance of refrigeration equipment until the end of 2029 and in the maintenance of air conditioning and heat pumps until the end of 2031. From 2032, stationary refrigeration equipment may not be serviced with refrigerants with a GWP exceeding 750. However, the use of regenerated and recycled substances in maintenance is permitted. Reclamation refers to the reprocessing of a recovered gas to the equivalent performance of a virgin substance. Recycled gases, may only be used by that maintenance company in their own maintenance sites or in other sites belonging to the company on whose behalf the refrigerant was recovered as part of maintenance or servicing.

An exception to the maintenance ban is allowed for substances intended for military equipment and for devices designed to cool products to temperatures below -50°C.

The maintenance ban should be taken into account when planning future equipment purchases. In the case of old devices, the service life and condition of the device as well as the purpose of use affect the solutions. Acquiring a new device or changing the refrigerant in an existing installation can be justified, for example, to improve energy efficiency. Professionals in the field are there to clarify the options for each device.

In order to protect the ozone layer the manufacturing, import, placing on the market, use and export of ozone-depleting substances and products that contain them is generally prohibited in Finland. The restrictions are based on the Montreal Protocol, which is an international environmental agreement to which all countries in the world are committed.

• The restrictions apply to both new, regenerated or recycled ozone-depleting substances and products containing them.
• Existing refrigeration and air conditioning equipment may be used, but in case of leakage or breakage, refrigerant may not be added to them.
• Equipment containing substances that deplete the ozone layer may not be exported.
• CFC refrigerants must be treated as hazardous waste.

Fire extinguishing equipment containing halons. Halons have a strong ability to deplete the ozone layer. They may only be used for a few critical uses listed in Commission Regulation 744/2010 (certain military uses and aircraft use), but dates have been set for prohibiting these uses also.

• The use of halons in critical applications must be reported annually to the Finnish Environment Institute, which further reports to the EU Commission. 
• The import and export of halons for critical uses requires an electronic import or export permit from the EU Commission. For airlines, it is possible to report all imports and exports during the same calendar year with one application. 

Necessary laboratory and analysis uses. Substances that deplete the ozone layer may be imported and used for essential laboratory and analysis purposes. In this case, both the company placing the substances on the market and the company using the substances must adhere to the accounting procedures outlined in the Ozone Regulation. This accounting procedure should include the company name, the quantity of substance supplied and used, the intended use, and a list of suppliers and buyers. The accounting records must be retained for a minimum of 5 years and must be presented upon request by the authorities or the commission. Use can only be considered necessary if there are no technically or economically feasible alternatives or environmentally and health-acceptable substitutes available. The annex to Commission Regulation (EC) 291/2011 lists the uses considered necessary. The annex to the regulation also contains a list of uses that are not considered necessary.

Instructions and additional information:

• ODS Licensing System - European Commission (europa.eu)

Some temporary derogations have been granted from the bans on placing on the market of equipment and products containing F-gases. The exemptions apply to the product group regardless of the manufacturer or brand and are valid in all EU countries. The EU Commission's implementing regulations on exemptions can be found on the EU Commission's website under the heading Derogations.

The F-gas regulation  includes restrictions on the putting into operation of new electrical switchgear (Article 13, paragraphs 9–18). Electrical switchgear is used, for example, in electricity production, transmission, and distribution. The aim of the legislation is to prevent greenhouse gas emissions into the atmosphere.

Putting into operation is considered to have taken place when the equipment has been handed over and put into use after installation and testing, i.e., the equipment has a user who is responsible for all the operator's obligations laid down in the regulation. The prohibitions do not apply to the transfer of existing equipment to another location or the extension of existing equipment if equipment containing lower global warming potential insulating or breaking gases is not compatible with the existing equipment.

Schedule for prohibitions on putting into operation of electrical switchgear

The schedules do not apply to orders placed before the regulation came into force on 11 March 2024. GWP (Global Warming Potential) is a metric that describes the climate impact of a substance compared to carbon dioxide, which has a GWP value of 1.

• From 2026, medium-voltage switchgear for primary or secondary distribution with a voltage of up to and including 24 kV may not contain F-gases, such as sulfur hexafluoride (SF6).
• From 2028, high-voltage electrical switchgear with a voltage of ≥ 52 kV and ≤ 145 kV and a short circuit current of up to and including 50 kA may not contain F-gases with a global warming potential (GWP) of 1 or more.
• From 2030, medium-voltage switchgear intended for primary or secondary distribution with a voltage of > 24 kV and ≤ 52 kV may not contain F-gases.
• From 2032, high-voltage electrical switchgear with a voltage of > 145 kV or a short-circuit current of > 50 kA may not contain F-gases a global warming potential (GWP) of 1 or more.

It is possible to derogate from the prohibitions in certain special cases

The procurement procedure considers the technical specificities of the equipment required for the specific use concerned. The F-gas regulation allows for derogations from the prohibitions if there are not sufficient alternatives available on the market yet. The criteria for derogation apply to the procurement procedure for equipment, and different criteria have been drawn up for a two-year transition period from the entry into force of the prohibitions and for the period thereafter. The text of the F-gas regulation is directly binding and quite detailed. To support compliance with the regulation, Syke has published a schedule of the prohibitions in the form of a diagram:

For two years from the entry into force of the prohibitions:

• If in the procurement procedure for medium-voltage switchgear no bids or only bids offering equipment from one manufacturer of switchgear not using F-gases are received, it is possible to put into operation equipment containing F-gases with a GWP of less than 1000. 
• If in the procurement procedure for high-voltage switchgear no bids or only bids offering equipment from one manufacturer of switchgear containing F-gases with a GWP of less than 1 are received, it is possible to put into operation equipment containing F-gases with a GWP of less than 1000.

After two years from the entry into force of the prohibitions:

• If no bids are received in the procurement procedure for medium-voltage switchgear from a manufacturer of switchgear not using F-gases, it is possible to put into operation equipment containing F-gases with a GWP of less than 1000. 
• If no bids are received in the procurement procedure for high-voltage switchgear from a manufacturer of switchgear containing F-gases with a GWP of less than 1, it is possible to put into operation equipment containing F-gases with a GWP of less than 1000.

It is possible to deviate from the prohibitions if no bids are received in the procurement procedure for equipment containing F-gases with a GWP of less than 1000.

The derogation in Article 13(13), which concerns the assessment of life-cycle carbon dioxide emissions in accordance with ecodesign requirements, cannot be applied until ecodesign requirements have been established for electrical switchgear. At present, the authorities have no information on the timetable for the possible preparation of these requirements, and the preparation is a process that takes several years. Other life-cycle emission calculations are not taken into account in the F-gas regulation.

If the above derogations are used in the procurement of switchgear, the operator of the equipment must notify the competent authority Syke in writing of the putting into operation at kirjaamo@syke.fi. The notification must include information on where and when the equipment was put into operation, what substance it contains, and a brief justification for the exception.

Syke may later provide more detailed instructions on the form of the notification. In addition, the operator of the equipment must keep documentation establishing the evidence for the derogation for at least 5 years and shall make it available, upon request, to the competent authority.

Leak prevention must be ensured

SF6, which is commonly used in electrical switchgear, is a very powerful greenhouse gas with a global warming potential (GWP) of 24,300. The intentional release of F-gases into the atmosphere is prohibited. Electrical switchgear containing at least 500 tons of CO2 equivalent F-gases, which means, for example, 48.6 kilograms of SF6 gas, must have a leakage detection system which alerts the operator or a service company of any leakage. The functioning of the leakage detector must be checked at least once every six years.

From 2035, the use of new SF6 in the maintenance or servicing of electrical switchgear is prohibited. The use of recycled or reclaimed SF6 is permitted. This does not apply to military equipment or situations where the use of recycled or reclaimed gas is not possible for technical reasons or is not available in a situation requiring urgent repair. The use of new SF6 must be justified to the competent authority upon request. 

The export of F-gases and products and equipment containing them requires a valid registration in the F-gas portal. Please see guidelines for registration of undertakings.

The restrictions on placing on the market of products and equipment containing F-gases in Annex IV of the F-gas regulation apply to the export of foams, technical aerosols, stationary refrigeration and stationary air conditioning equipment and stationary heat pumps equipment if the GWP of the F-gas contained in the equipment or product is 1000 or more. (F-gas Regulation Art 22(3)).    

The export of ozone depleting substances and products and equipment containing them is forbidden. The restriction does not apply to certain specific uses listed in Article 14 of the Ozone Regulation (EU Regulation 2024/590). 
 

Registration and reporting obligation annually by 31.3.:

• Feedstock use: over 1 000 t CO ₂ -eq. of F-gases in Annex I
• Destruction: 1 t or more of HFC-compounds or 100 t CO2-eq. of other F-gases.
• Reception: the disposal, raw material use, direct export, defense equipment use, semiconductor sector use, and production of metered dose inhalers with HFC-compounds
• Reclamation: More than 1 ton or 100 tons CO2 equivalent of F-gases per year.
   

To be added later