Importing HFCs into the EU: licence, quota, customs and paperwork

Quick answer

Importing hydrofluorocarbons into the EU is not one permission but a chain of them, and the chain has to be complete before the goods reach the border.

In short: you need a valid registration in the F-gas Portal, which is what serves as your import licence. If you are bringing in bulk HFCs you also need quota. If you are bringing in equipment already charged with HFCs you instead need an authorisation to use someone's quota, plus a declaration of conformity. At the border, the registered undertaking holding that quota or authorisation has to be the one named on the customs declaration. After the import, labelling, records and annual reporting apply.

Registration is your licence

Article 20(4) of Regulation (EU) 2024/573 requires undertakings to hold a valid registration in the F-gas Portal before importing or exporting fluorinated greenhouse gases, or products and equipment containing them. Temporary storage is the exception.

Article 22(1) then makes the practical link: import and export are subject to the presentation of a valid licence to customs authorities, issued by the Commission under Article 20. In practice the licence is not a separate application — a valid registration is what produces it, and it is downloadable from the portal once your status is valid.

The portal is interconnected with the EU Single Window Environment for Customs through EU CSW-CERTEX (Article 20(2)), and Member States connect their national customs systems to it (Article 20(3)). That is why the data in your registration has to match the data customs sees.

Quota: needed for bulk, not for everything

Article 16(1) is blunt: placing hydrofluorocarbons on the market is allowed only to the extent that producers and importers have been allocated quota, and they must not exceed the quota available to them at the moment of placing on the market.

Article 16(2) lists situations where that does not apply, including HFCs imported for destruction, supplied for use as feedstock, supplied directly for export out of the Union without being made available to anyone else inside it first, and supplied for use in military equipment.

Two points that catch importers out:

• Quota is not automatic with registration. They are separate. A valid licence lets you trade; quota is what lets you place bulk HFCs on the EU market.
• Quota is no longer free. The Commission applies a quota allocation price of EUR 3 per tonne of CO2 equivalent from the allocation for 2026 onwards, and the next declaration window to obtain quota from the reserve runs by 1 April 2027 for the years 2028 to 2030.

Equipment already charged with HFCs

If you import refrigeration or air-conditioning equipment, heat pumps or metered dose inhalers that arrive pre-charged, Article 19(1) requires the gas inside them to be accounted for within the quota system. For metered dose inhalers this applies from 1 January 2025.

You usually do not hold that quota yourself. Article 21(2) lets a producer or importer with a reference value authorise another undertaking, in the F-gas Portal, to use all or part of its quota for importing pre-charged equipment. That authorisation is what covers your shipment.

On top of that, Article 19(2) requires manufacturers and importers of such products or equipment to document compliance fully and to draw up a declaration of conformity. By drawing it up they assume responsibility for compliance.

Who has to be named on the customs declaration

This is the detail that most often goes wrong when a forwarder handles the entry. Article 23(2) says that for release for free circulation, the undertaking holding the quota or authorisation and registered in the F-gas Portal shall be the importer indicated in the customs declaration.

For imports under a procedure other than release for free circulation, the registered undertaking has to be the declarant indicated in the declaration and the holder of the authorisation for that special procedure, unless rights and obligations are transferred under Article 218 of the Union Customs Code so that another person may be the declarant.

Article 23(1) puts enforcement on customs and market surveillance authorities, which is why the check is automatic rather than discretionary.

EORI and matching data

Customs identifies you by your EORI number, and the F-gas Portal registration carries both your VAT and EORI details. The Commission's registration guidance is explicit that both must be indicated correctly, must be verifiable as valid in the respective databases, and that the address in the portal must match the address in the VAT database, in the EORI database and on the financial identification form.

An invalid EORI is not a paperwork nuisance — the guidance states plainly that goods would be blocked at customs. Check it in the EORI validation database before you ship, not after.

Labelling the containers and equipment

Article 12(1) allows the following to be placed on the market, supplied or made available only if they are labelled: refrigeration equipment, air-conditioning equipment, heat pumps, fire protection equipment, electrical switchgear, aerosol dispensers containing fluorinated greenhouse gases including metered dose inhalers, all fluorinated greenhouse gas containers, fluorinated greenhouse gas-based solvents, and organic Rankine cycles.

Article 12(2) adds that products or equipment covered by an exemption must be labelled accordingly, specifying the end date of the exemption.

The label format itself is set by Commission Implementing Regulation (EU) 2024/2174, which applies from 1 January 2025. Check the current format against that act rather than reusing an older label design.

What travels with the shipment

The regulation does not publish a single packing list, so treat the following as the working set that customs, market surveillance and your own buyers will ask for:

• the import licence from the F-gas Portal, valid at the time of import;
• evidence of the quota position, or of the authorisation to use quota where the goods are pre-charged equipment;
• the declaration of conformity for pre-charged products and equipment under Article 19(2);
• the customs declaration naming the registered undertaking correctly under Article 23(2);
• the commercial invoice and transport documents, including the ADR paperwork the carrier requires;
• the safety data sheet and correct labelling on every container.

What you owe after the goods arrive

The obligations continue past the border. Under Article 26(1), by 31 March each year every producer, importer and exporter that produced, imported or exported hydrofluorocarbons — or quantities exceeding one metric tonne or 100 tonnes of CO2 equivalent of other fluorinated greenhouse gases — reports the data specified in Annex IX for the preceding calendar year. Undertakings receiving quota under Article 21(1) report as well.

Article 26(4) adds a separate duty for equipment: undertakings that placed 10 tonnes of CO2 equivalent or more of HFCs, or 100 tonnes of CO2 equivalent or more of other fluorinated greenhouse gases, contained in products or equipment on the market must report the Annex IX data too.

Where the volumes are large, verification follows. Article 26(8) requires undertakings reporting the placing on the market of 1 000 tonnes of CO2 equivalent or more of HFCs to have the veracity of that report confirmed by an independent auditor, by 30 April. The auditor must be registered in the F-gas Portal and appropriately accredited.

The reporting format is set by Commission Implementing Regulation (EU) 2024/2195, with the first submission in that format due on 31 March 2025 for 2024 data.

If you also export

Exports run through the same licence requirement in Article 22(1), but carry an additional restriction. From 12 March 2025, Article 22(3) prohibits the export of foams, technical aerosols, and stationary refrigeration, air-conditioning and heat pump equipment referred to in Annex IV that contain, or whose functioning relies upon, fluorinated greenhouse gases with a GWP of 1 000 or more.

The prohibition does not extend to military equipment, or to products and equipment that may still lawfully be placed on the market under the relevant exemptions. Check Annex IV against the specific product before quoting an export.

Common mistakes

• Treating registration as permission to place gas on the market. Registration is the licence to trade; quota is what allows bulk HFCs to be placed on the market.
• Letting the forwarder appear as importer on the declaration. Article 23(2) requires the registered quota or authorisation holder to be named.
• Confusing quota with an authorisation to use quota. Bulk needs the first; pre-charged equipment needs the second.
• Importing pre-charged equipment without a declaration of conformity. Article 19(2) makes it a documented responsibility, not an optional form.
• An EORI or VAT number that the databases show as invalid. The result is goods stopped at the border.
• Addresses that differ between the portal, VAT, EORI and the bank document. The registration is returned and the timeline slips.
• Reusing an old label design. The format follows Implementing Regulation (EU) 2024/2174 from 1 January 2025.
• Assuming imported gas can be described as reclaimed. Article 22(2) treats imported F-gases as virgin.
• Forgetting the nil-report. Quota holders who placed nothing on the market still report.
• Missing the auditor deadline. Above 1 000 tonnes of CO2 equivalent the verification is due by 30 April, and the auditor has to be registered beforehand.

Checklist before the goods move

• F-gas Portal registration validStatus valid, and the licence downloaded and current for the date of import.
• Quota or authorisation in placeQuota for bulk HFCs; an authorisation to use quota for pre-charged equipment.
• Declaration of conformity preparedFor pre-charged products and equipment under Article 19(2).
• Customs declaration names the right undertakingThe registered quota or authorisation holder as importer or declarant, per Article 23(2).
• EORI and VAT verified as validChecked in the databases on the day, with addresses matching the portal.
• Labelling checked against the current formatImplementing Regulation (EU) 2024/2174, including exemption end dates where relevant.
• Safety data sheets readyAvailable for every substance in the consignment.
• Transport paperwork arrangedADR documentation and carrier requirements settled before collection.
• Reporting diarised31 March for the annual report; 30 April for auditor verification above 1 000 t CO2e.

Frequently asked questions

Official sources

The article references in this guide were read directly in the Official Journal text of the regulation, through the EU Publications Office.

Currency of this guide and limits of responsibility

This is general information prepared by EgoLog on the basis of the regulation and official Commission material. It is not legal or customs advice, and it does not replace the assessment of your own situation.

Whether quota, an authorisation or an exemption applies to a particular consignment depends on facts we cannot see. Where it is unclear, ask the European Commission or your national competent authority before the goods move.