The short answer
Regulation (EU) 2024/573 uses four ideas that are constantly mixed up. They stack on top of one another, but none of them replaces another.
- F-gas Portal registration — the condition of access. Article 20(4) requires it before a listed set of activities, import and export among them. Without it you cannot start.
- The import or export licence — not a separate document. Article 20(5) states that a valid registration at the moment of import or export constitutes the licence required under Article 22.
- Quota — the quantitative right to place HFCs on the market, allocated by the Commission under Article 17(4). Article 16(1) forbids placing on the market beyond the quota available to you.
- Authorisation to use quota and quota transfer — two different ways of moving that right between undertakings, governed by Article 21(2) and Article 21(1) respectively.
The most expensive confusion is the first one: an approved registration is not an automatic, unlimited right to import. It opens the Portal to you; the quantity stays governed by quota or by an authorisation.
It does not walk you through the registration form — that is in the F-gas Portal registration guide. It does not repeat the import procedure either, which is covered in the HFC import procedure guide. It contains no prices, no market availability of quota and no estimate of what you might be allocated.
Registration and licence: the condition of access
Article 20(4) lists the activities for which a valid registration is required. It is an exhaustive list, not a general statement.
- The import or export of fluorinated greenhouse gases, and products and equipment containing them, except in the case of temporary storage as defined in Article 5, point (17), of Regulation (EU) No 952/2013 (point (a)).
- Submitting the reserve declaration referred to in Article 17(3) (point (b)).
- Receiving a quota allocation under Article 17(4), making or receiving a quota transfer under Article 21(1), making or receiving an authorisation to use quota under Article 21(2), or delegating that authorisation under Article 21(3) (point (c)).
- Supplying or receiving HFCs for the purposes listed in Article 16(2), points (a) to (e) (point (d)).
- Carrying out all other activities that require reporting under Article 26 (point (e)).
- Receiving production rights under Article 14, and making or receiving a transfer and an authorisation of production rights under Article 15 (point (f)).
- Verifying the reports referred to in Article 19(3) and Article 26(8) (point (g)).
Registration in the F-gas Portal shall be valid only once the Commission validates it and for as long as it is not suspended or revoked by the Commission or withdrawn by the undertaking.
In other words, the day you file is not the day you may operate. Implementing Regulation (EU) 2024/2473 sets out in Article 2 the information you must supply, and in Article 5 the grounds for refusal, suspension and cancellation: requirements not complied with, information inaccurate or incomplete, deliberately false information provided. Article 4 of the same Regulation requires you to update your data as soon as anything changes.
The licence. Article 22(1) requires a valid licence issued by the Commission to be presented to customs for the import and export of fluorinated greenhouse gases and of products and equipment containing them or whose functioning relies upon them, except in the case of temporary storage. Article 20(5) then states that a valid registration in the F-gas Portal at the moment of import or export constitutes the licence required under Article 22. You do not apply for a licence separately; you keep the registration valid.
Extra conditions for quota. Article 18(1) reserves quota allocation to producers and importers that have an establishment within the Union or that have appointed an only representative established in the Union. Article 18(3) requires a physical address from which the undertaking conducts its business and provides that only one undertaking shall be registered under the same physical address, while undertakings sharing the same beneficial owner are treated as a single undertaking for reference values and quota allocation.
Quota: who gets it and how it is calculated
Quota is a quantity expressed in tonnes of CO2 equivalent, not in kilograms and not per product. Article 16(1) states the base rule.
The placing on the market of hydrofluorocarbons shall be allowed only to the extent that producers and importers have been allocated quota by the Commission as set out in Article 17. Producers and importers placing hydrofluorocarbons on the market shall not exceed the quota available to them at the moment of placing on the market.
The exceptions are an exhaustive list in Article 16(2): HFCs imported into the Union for destruction; used by a producer as feedstock or supplied directly for use as feedstock; supplied directly for export out of the Union, not contained in products or equipment and not subsequently made available to anyone else in the Union before export; supplied directly for use in military equipment; and supplied directly to an undertaking using them for the etching of semiconductor material or the cleaning of chemical vapour deposition chambers in the semiconductor sector.
| Item | Rule | Basis |
|---|---|---|
| Reference value | Determined by the Commission for producers and importers that placed HFCs on the market in the previous 3 years, at least every 3 years | Article 17(1), Annex VII, point 4 |
| Reserve declaration | Made through the F-gas Portal at the dates in Article 17(3) | Article 17(3), Annex VIII, point 2 |
| Experience required | 3 consecutive years trading chemicals or servicing refrigeration, air-conditioning, heat pump or fire protection equipment | Article 18(2) |
| Annual allocation | Notified through the F-gas Portal, pursuant to Annex VIII | Article 17(4) |
| Price | EUR 3 for each tonne of CO2 equivalent of quota to be allocated | Article 17(5) |
| Rounding | Aggregated quantities expressed in tonnes of CO2 equivalent, rounded to the nearest tonne | Annex VII, point 3 |
| 2015 base value | 176 700 479 tonnes of CO2 equivalent | Annex VII, point 2 |
The maximum amount that may be placed on the Union market in a given year is fixed in the same Annex VII: 42 874 410 tonnes of CO2 equivalent for 2025-2026, 21 665 691 for 2027-2029, 9 132 097 for 2030-2032 and so on, down to zero from 2050. The allocation mechanism in Annex VIII, point 1(a), starts from 89 % of the reference value, multiplied by the maximum quantity for the year and divided by the base value.
Payment. Article 17(5) allows you to pay for only part of the calculated maximum allocation offered to you; you are then allocated the quota corresponding to the payment made by the deadline. Until 31 December 2027, quota left unpaid is redistributed free of charge to those who paid in full and made the Article 17(3) declaration. From 1 January 2028, quota for which payment has not been made by the deadline is cancelled.
The text of the Regulation contains no general quantity-based exemption from the quota requirement for bulk gas. The only exceptions are those listed in Article 16(2) above, plus the specific 10 tonnes of CO2 equivalent per year limit in Article 19(6), which concerns pre-charged equipment only and does not waive registration or the licence.
The quota transfer
A transfer actually moves quota from one undertaking to another, and the recipient uses it for its own placing on the market, bulk gas included.
Any producer or importer for whom a reference value has been determined under Article 17(1) may transfer in the F-gas Portal its quota allocation on the basis of Article 17(4), for all or any quantities, to another producer or importer in the Union or to another producer or importer represented in the Union by an only representative referred to in Article 18(1). Quota that is transferred shall not be transferred a second time.
- Who may transfer. The same condition as for authorising: a reference value determined under Article 17(1).
- To whom. Another producer or importer in the Union, or one represented in the Union by an only representative referred to in Article 18(1).
- One step only. Quota transferred once cannot be passed on again.
- Effect on reporting. Article 26(1) applies to all undertakings receiving quota under Article 21(1). If you received quota by transfer, you carry the reporting duty too, including the nil-report if you placed nothing on the market.
- Acceptance. Article 21(4) applies to transfers as well: without acceptance in the Portal there is no valid transfer.
Corrections. Article 20(8) allows information on transfers, authorisations and delegations to be corrected only with the consent of all undertakings involved in the transaction, without undue delay and at the latest by 31 March of the year following the year of the recording, and only on evidence that it concerns a clerical error. Requests that negatively affect the entitlements of other producers and importers not involved in the underlying transaction are refused.
The four concepts side by side
| Concept | Basis | What it gives you | What it does not give you |
|---|---|---|---|
| F-gas Portal registration | Article 20(4) | Access to the listed activities, import and export among them | No quantity at all. It is not quota and not an unlimited right to import |
| Licence | Article 22(1) with Article 20(5) | The document customs require, embodied in the valid registration | It does not cover the quota requirement in Article 16(1) |
| Quota | Articles 16 and 17, Annexes VII and VIII | The quantity of HFCs you may place on the market, in tonnes of CO2 equivalent | It does not automatically become a right to authorise somebody else |
| Authorisation to use quota | Article 21(2) and (3) | Another undertaking's right to import pre-charged equipment against your quota | It does not transfer quota and it does not serve bulk gas imports |
| Quota transfer | Article 21(1) | Moving quota to another producer or importer | It cannot be repeated: transferred quota is not transferred again |
At customs the difference becomes very concrete. Article 23(2) requires that, for release for free circulation, the undertaking holding the quota or the authorisations to use quota and registered in the F-gas Portal be the importer indicated in the customs declaration. A registration on its own does not get the goods through.
Transparency. Article 20(7) obliges the Commission to make publicly available, no later than 3 months after the allocation is completed for a given year, a list of quota holders and a list of the undertakings subject to the reporting requirements in Article 26. That is where you can check whether a counterparty is what it says it is.
What you need, depending on what you do
Importing bulk gas in cylinders
You need a valid registration (Article 20(4), point (a)) and either your own quota or quota received by transfer (Article 16(1), Article 17(4), Article 21(1)). An authorisation to use quota does not cover bulk gas.
Importing equipment that is already charged
You need a valid registration and an authorisation to use quota or a delegated authorisation (Article 19(1), Article 21(2) and (3)). You do not receive quota of your own for this.
Exporting gas or equipment
You need a valid registration, which constitutes the licence (Article 20(4), point (a), and Article 20(5)). Quota concerns placing on the market, not export.
Applying for quota from the reserve
You submit the declaration referred to in Article 17(3) through the F-gas Portal at the dates in that paragraph, and you must meet the experience condition in Article 18(2). If you are not registered yet, Article 2(4) of Implementing Regulation (EU) 2024/2473 requires the registration request by 1 February of the same year.
Passing quota to somebody else
First check whether you have a reference value determined under Article 17(1). Without one you can neither transfer (Article 21(1)) nor authorise (Article 21(2)).
Receiving an offer of quota or of an authorisation
Accept the transaction in the F-gas Portal, otherwise it is not valid (Article 21(4)). Then check the reporting duties that follow under Article 26(1).
Checklist
- The registration is validated, not merely submittedArticle 20(4), final subparagraph: valid only once the Commission validates it.
- The data in the Portal is currentArticle 4 of Implementing Regulation (EU) 2024/2473: update as soon as anything changes.
- You know whether you have a reference value or only reserve quotaArticle 17(1). Whether you may transfer or authorise depends on it.
- You have calculated your need in tonnes of CO2 equivalentAnnex VII, point 3, requires tonnes of CO2 equivalent rounded to the nearest tonne.
- The quota payment is made by the deadlineArticle 17(5): EUR 3 per tonne of CO2 equivalent; from 1 January 2028 unpaid quota is cancelled.
- You chose the right instrument for your goodsTransfer for bulk gas, authorisation for pre-charged equipment.
- The transaction was accepted in the Portal by the recipientArticle 21(4).
- The holder of the quota or authorisation is the one in the customs declarationArticle 23(2).
Frequently asked questions
Does an approved registration let me import as much as I want?
No. Registration is the access condition in Article 20(4) and, under Article 20(5), it constitutes the licence. The quantity remains governed by Article 16(1): hydrofluorocarbons may be placed on the market only to the extent of the quota available at the moment of placing on the market. Those are two separate filters.
What is the practical difference between a transfer and an authorisation?
A transfer under Article 21(1) moves quota to another producer or importer, who then uses it for its own placing on the market, bulk gas included. An authorisation under Article 21(2) leaves the quota with its holder and lets another undertaking import pre-charged equipment against it, the quantity being deemed placed on the market by the authorising party.
Can I pass on quota I received by transfer?
No. The second subparagraph of Article 21(1) says in terms that quota which has been transferred shall not be transferred a second time. The parallel rule for authorisations is in Article 21(3): a delegated authorisation shall not be delegated again.
What happens if I do not pay for all the quota offered?
Article 17(5) allows partial payment: you are allocated the quota corresponding to the payment made by the deadline. Until 31 December 2027, quota left unpaid is redistributed free of charge to those who paid in full and made the Article 17(3) declaration. From 1 January 2028 quota unpaid by the deadline is cancelled.
Can two companies with the same owner each receive quota?
No. The second subparagraph of Article 18(3) provides that all undertakings sharing the same beneficial owner are considered a single undertaking for the Article 17(3) declaration, for quota allocation and for determining reference values. Only that single undertaking, normally the one registered first, is entitled to a reference value and to an allocation.
What happens to quota if the registration is cancelled?
Article 5(5) of Implementing Regulation (EU) 2024/2473: where a registration is cancelled, any available quota and authorisations become void and activities for which registration was required may no longer be performed. Reporting duties for past activity remain with the undertaking.
Where can I check whether a counterparty really holds quota?
Article 20(7) obliges the Commission to publish, no later than 3 months after the allocation for that year is completed, a list of quota holders and a list of undertakings subject to Article 26 reporting. The Commission also points out that a registration in the F-gas Portal is not an assurance that a company will meet its contractual obligations towards private parties.
Official sources
Articles 16 to 23 and Annexes VII and VIII were read directly in the Official Journal text retrieved from the Publications Office CELLAR repository. The registration rules come from the implementing regulation dedicated to the Portal.
Currency of this page and limits of liability
This page explains the legal concepts and their basis. It is not an operating manual for the F-gas Portal, it contains no market figures and it cannot tell you whether you will receive an allocation. For the concrete steps use the Commission's official instructions and the text of the Regulation in force.
General information prepared by EgoLog from the Regulation and official European Commission material. It is not legal advice.
Import decisions should be taken after checking the official text and, where appropriate, with the support of your national competent authority. Handling the gases themselves remains reserved to competent personnel certified under Article 10.