The short answer
The whole quota system works in one unit: the tonne of CO2 equivalent. Article 3, point (3), defines it as the product of the weight of the greenhouse gases in metric tonnes and their global warming potential. In practice, for quantities given in kilograms:
kilograms x GWP / 1000 = tonnes of CO2 equivalent. The GWP is the Annex I value for pure substances and the value calculated under Annex VI for blends.
Three decisions turn the formula into a correct figure: you pick the right Annex I column, you calculate the blend GWP separately if your gas is a blend, and you add up per calendar year rather than per shipment.
For a quick check you can use the F-gas calculator, but the figure stays yours: always verify the GWP it used against the official text.
No quota availability figures, no prices and no allocation estimates. It also does not cover the leak-check thresholds in Article 5 — those are also expressed in tonnes of CO2 equivalent but answer a different question and are handled in the leak check frequency guide. The blend GWPs shown here are calculated, not taken from Annex I, because Annex I does not list blends.
The formula and where it comes from
Two points of Article 3 contain everything you need.
Global warming potential, or GWP, means the climatic warming potential of a greenhouse gas relative to that of carbon dioxide, calculated in terms of the 100-year global warming potential, unless otherwise specified, of one kilogram of a greenhouse gas relative to one kilogram of CO2, as set out in Annexes I, II, III and VI or, in the case of mixtures, calculated in accordance with Annex VI.
Tonne of CO2 equivalent means a quantity of greenhouse gases expressed as the product of the weight of the greenhouse gases in metric tonnes and of their global warming potential.
From this follows the discipline of the calculation:
- You start from the net mass of gas, not from the gross weight of the cylinder. Article 23(3), point (c), requires the net mass of bulk gases and of gases contained in products and equipment to be declared.
- You convert to metric tonnes, that is, you divide the kilograms by 1 000.
- You multiply by the applicable GWP.
- For quota, you express the aggregated result in tonnes of CO2 equivalent rounded to the nearest tonne, as Annex VII, point 3, requires.
Mathematically the order does not matter; what matters is not mixing the units. A result of 810 with no unit means nothing: 810 kg and 810 t CO2e are entirely different things.
Annex I has two columns. Only one is binding
This is the mistake with the largest financial impact. The Annex I table carries a GWP column and a column headed 20 years-GWP, for information purposes only. Quota arithmetic uses the first one.
| Substance | Binding GWP (Annex I) | 20-year column (information only) |
|---|---|---|
| HFC-23 | 14 800 | 12 400 |
| HFC-32 (R-32) | 675 | 2 690 |
| HFC-125 | 3 500 | 6 740 |
| HFC-134a (R-134a) | 1 430 | 4 140 |
| HFC-143a | 4 470 | 7 840 |
| HFC-152a | 124 | 591 |
| HFC-227ea | 3 220 | 5 850 |
The difference is not cosmetic. For R-32 the information column is roughly four times the binding one. A calculation on the wrong column inflates the quota you think you need and can turn a perfectly lawful import into a pointless refusal or, the other way round, hide a real overrun.
If the value you are using for R-32 is not 675, stop and check which column you took it from.
Worked examples: pure substance and blend
Example 1 — pure gas. You import 1 200 kg of R-32. The Annex I GWP is 675.
- 1 200 x 675 = 810 000
- 810 000 / 1 000 = 810 tonnes of CO2 equivalent
Example 2 — a blend. Blends are not listed individually in Annex I. Annex VI gives the method: a weighted average, derived from the sum of the weight fractions of the individual substances multiplied by their GWP, including substances that are not fluorinated greenhouse gases, with a weight tolerance of plus or minus 1 %. Substances not listed in that annex take a default value of 0, and only emissible components fulfilling broadly the same function are relevant.
For R-410A, composed by mass of 50 % R-32 and 50 % R-125:
| Component | Mass fraction | GWP (Annex I) | Contribution |
|---|---|---|---|
| R-32 | 50 % | 675 | 337.5 |
| R-125 | 50 % | 3 500 | 1 750 |
| Calculated blend GWP | 2 087.5 | ||
For 500 kg of R-410A: 500 x 2 087.5 / 1 000 = 1 043.75 t CO2e. For quota, Annex VII, point 3, requires rounding to the nearest tonne: 1 044 t CO2e.
The same method for R-404A, composed of 52 % R-143a, 44 % R-125 and 4 % R-134a: (0.52 x 4 470) + (0.44 x 3 500) + (0.04 x 1 430) = 2 324.4 + 1 540 + 57.2 = 3 921.6 calculated GWP.
The Regulation gives its own example: a mixture of 60 % dimethyl ether, 10 % HFC-152a and 30 % isobutane. The calculation is (60 % x 1) + (10 % x 124) + (30 % x 0), for a total GWP of 13.0. Note that dimethyl ether counts although it is not a fluorinated gas, and that isobutane enters with a value of 0.
If you use the GWP calculated by the manufacturer and shown on the label required by Article 12(3) and by Implementing Regulation (EU) 2024/2174, check which composition it was derived from. Slightly different compositions give slightly different GWPs, and the Annex VI tolerance is plus or minus 1 % on the mass fraction.
A worked example with pre-charged equipment
For equipment the gas is counted the same way, but you start from the factory charge of each unit and add up across the year.
Example 3. You import 300 heat pumps, each holding 1.8 kg of R-32.
- Total quantity: 300 x 1.8 = 540 kg of R-32
- 540 x 675 / 1 000 = 364.5 tonnes of CO2 equivalent
That quantity has to be accounted for within the quota system under Article 19(1), through the authorisation to use quota described in the pre-charged equipment import guide.
Where the Article 19(6) limit sits. Article 19 does not apply to undertakings placing on the market less than 10 tonnes of CO2 equivalent per year contained in such products or equipment. Converted into kilograms of gas, that limit depends on the refrigerant:
| Refrigerant | GWP used | Quantity reaching 10 t CO2e |
|---|---|---|
| R-32 | 675 (Annex I) | about 14.8 kg per year |
| R-410A | 2 087.5 (calculated) | about 4.8 kg per year |
| R-134a | 1 430 (Annex I) | about 7.0 kg per year |
| R-404A | 3 921.6 (calculated) | about 2.5 kg per year |
In other words, in the example above the limit is passed at the ninth unit. The Commission describes this threshold in its own material as the minimum HFC quantity in imported products and equipment that must be covered by the quota system.
Which quantities count and which do not
Not everything that crosses the border enters the quota arithmetic, and what does is counted per calendar year.
- Counted: hydrofluorocarbons placed on the market, that is, released for free circulation in the Union or supplied or made available to another person in the Union for the first time, as defined in Article 3, point (6).
- Outside the quota requirement, under Article 16(2): HFCs imported for destruction; used or supplied directly as feedstock; supplied directly for export out of the Union, not contained in products or equipment and not made available to anyone else in the Union in the meantime; supplied directly for use in military equipment; supplied directly for the etching of semiconductor material or the cleaning of chemical vapour deposition chambers.
- Declared to customs regardless: Article 23(3) requires the net mass and the tonnes of CO2 equivalent, for bulk gas as well as for gas contained in products and equipment and in parts thereof.
- Rounding: Annex VII, point 3, requires reference values and quota to be calculated as the aggregated quantities of all hydrofluorocarbons, expressed in tonnes of CO2 equivalent rounded to the nearest tonne.
Reporting uses its own thresholds. Article 26(1) ties annual reporting to producers, importers and exporters of hydrofluorocarbons and, for other fluorinated greenhouse gases, to quantities exceeding one metric tonne or 100 tonnes of CO2 equivalent. Article 26(4) uses a threshold of 10 tonnes of CO2 equivalent of hydrofluorocarbons contained in products and equipment. Read the text of Article 26 for your own case, because the thresholds differ between categories.
The mistakes that keep recurring
| Mistake | What happens | Correct approach |
|---|---|---|
| Using the 20-year column of Annex I | The figure inflates several times over | The binding column, the 100-year GWP (Article 3, point (1)) |
| Treating a blend as a pure substance | A GWP that is not in Annex I, or taken from elsewhere | The weighted-average method in Annex VI |
| Using the gross weight of the cylinder | You declare more gas than exists | The net mass, Article 23(3), point (c) |
| Calculating per shipment | Annual thresholds look untouched | Add up per calendar year |
| Confusing the Article 5 thresholds with quota | Two different sets of duties get mixed | Article 5 concerns leak checks on installed equipment |
| Ignoring non-fluorinated components of a blend | The blend GWP comes out wrong | Annex VI requires them to be included, at the values in that annex or 0 |
One last useful check: recalculate with the F-gas calculator and compare. If the two figures differ, one of them is using a different GWP, and the gap tells you exactly where to look.
Checklist for the calculation
- You identified the exact refrigerant, not just its familyR-32 and R-410A are not calculated the same way, although both contain difluoromethane.
- The GWP comes from the binding column of Annex IFor R-32 the value is 675. The 20-year column is marked as information only.
- For blends you applied the Annex VI methodThe weighted average of the mass fractions, non-fluorinated components included.
- The composition you used matches the actual productAnnex VI allows a weight tolerance of plus or minus 1 %.
- You started from the net massArticle 23(3), point (c), requires the net mass of the gases.
- You divided the kilograms by 1 000 before multiplyingArticle 3, point (3), works in metric tonnes.
- You added up every shipment in the calendar yearThe thresholds in Article 19(6) and Article 26 are annual.
- You rounded to the nearest tonne for quotaAnnex VII, point 3.
- You separately checked whether the equipment is allowed under Annex IVThe quota arithmetic says nothing about placing-on-the-market prohibitions.
- You kept the calculation with the source of each figureIt serves you at an inspection and in the documentation required by Article 19(2).
Frequently asked questions
Why can I not find R-410A in Annex I?
Because Annex I lists substances, and R-410A is a mixture. Article 3, point (1), refers expressly to Annex VI for mixtures, and Annex VI gives the weighted-average method. The resulting GWP is calculated, not quoted from a legal table.
Can I use the GWP printed on the cylinder label?
Yes, if it comes from the same method. Article 12(3) requires the label to show the quantity by weight and in CO2 equivalent as well as the GWP. Still check which composition it was calculated from, because Annex VI allows a tolerance of plus or minus 1 % on the mass fractions.
What is the 20-year column in Annex I for?
For information. The column heading says so in terms. Article 3, point (1), defines GWP as the 100-year potential unless otherwise specified, so quota, labelling and threshold calculations use the first column.
How do I count a mixed consignment of cylinders and equipment?
Separately, then together for reporting. Bulk gas falls under the quota requirement in Article 16(1); gas inside equipment falls under Article 19(1) and is covered by an authorisation to use quota. Article 23(3) requires the net mass and the tonnes of CO2 equivalent to be declared to customs for both categories.
Do I round up, or to the nearest tonne?
Annex VII, point 3, says rounded to the nearest tonne, so ordinary rounding rather than rounding up. The rounding applies to reference values and quota, that is, to the aggregated figures, not to every intermediate line of the calculation.
Does it matter whether the gas is reclaimed or recycled?
For the formula, no: mass multiplied by GWP stays the same. For the duties that attach, yes, because the Regulation treats reclaimed and recycled gas separately in several places. Check the applicable regime before assuming that an identical calculation means identical obligations.
Does the site calculator replace checking the text?
No. The F-gas calculator applies the same formula and the same values, but responsibility for the figure you declare stays with you. Use it as a cross-check, not as a source of law.
Official sources
Article 3, Articles 16, 19, 23 and 26 and Annexes I, VI and VII were read directly in the Official Journal text retrieved from the Publications Office CELLAR repository. The GWP values quoted above come from the binding column of Annex I.
Currency of this page and limits of liability
The examples are illustrative and use typical compositions. The real composition of your product comes from its technical data sheet and the cylinder label. GWP values can be amended by delegated act; check Annex I in the version in force on the date of your calculation.
General information prepared by EgoLog from the Regulation and official European Commission material. It is not legal advice and it does not replace checking the official text.
The figure declared to customs and in the annual report remains the responsibility of the declaring undertaking. The gases themselves are handled by competent personnel certified under Article 10.