The short answer
Article 2, point (a), states that the Regulation applies to the fluorinated greenhouse gases listed in Annexes I, II and III, whether alone or as mixtures. Section 1 of Annex II is the list of unsaturated hydro(chloro)fluorocarbons, which is exactly the family sold as HFO and HCFO.
- Applies: almost the whole of Chapter II — emission prevention, leak checks, detection systems, records, recovery and certification.
- Applies: the market rules too — the purchase right in Article 11(6), the non-refillable container ban in Article 11(3), labelling under Article 12, portal registration and the licence under Articles 20 and 22, and reporting under Article 26.
- Does not apply: the quota system of Article 16, because it concerns hydrofluorocarbons; nor the pre-charged equipment rule of Article 19, which is drafted for substances listed in Section 1 of Annex I.
- Watch the unit. For Annex I the thresholds are in tonnes of CO2 equivalent; for Section 1 of Annex II they are in kilograms. At small charges the HFO regime is stricter, not looser.
No prices, delivery times, availability, national penalty amounts, dangerous-goods figures or UN numbers. No flammability classification for any refrigerant either: that is read from the applicable safety standard and from the safety data sheet.
What Annex II actually contains
Annex II has three sections and only the first one concerns a refrigeration company. Its full heading in the Regulation is unsaturated hydro(chloro)fluorocarbons.
| Substance, as listed | GWP in the Annex II column |
|---|---|
| HCFC-1224yd | 0,06 |
| Trans-1,2-difluoroethylene (HFC-1132) and isomers | Greater than 1; the value is not yet available |
| 1,1-difluoroethylene (HFC-1132a) | 0,052 |
| Nonafluoro-(trifluoromethyl)pent-2-ene, in the form listed in the Annex | 1, default value |
| HFC-1234yf | 0,501 |
| HFC-1234ze and isomers | 1,37 |
| HFC-1336mzz(E) | 17,9 |
| HFC-1336mzz(Z) | 2,08 |
| HCFC-1233zd and isomers | 3,88 |
| HCFC-1233xf | 1, default value |
Section 2 covers fluorinated substances used as inhalation anaesthetics and Section 3 nitrogen trifluoride and sulfuryl fluoride. Those have their own regimes — the desflurane use prohibition in Article 13(8), or the documentation of fumigation with sulfuryl fluoride in Article 4(2) — and nothing to do with refrigeration.
Every GWP value in Section 1 is far below 150. That has a direct consequence: the thresholds in the Regulation that switch on at GWP 150 or 2 500 are not reached by these substances. Which does not mean the Annex IV prohibitions pass them by, as shown below.
The individual status of the most widely used is described on the R-1234yf page, and the blends containing them in R-454C and R-513A.
Kilograms, not tonnes of CO2 equivalent
The most practical difference between Annex I and Section 1 of Annex II is the unit in which the thresholds are expressed. The Regulation does not use CO2 equivalent for Section 1 of Annex II gases; it uses mass.
| Duty | Annex I threshold | Annex II Section 1 threshold | Basis |
|---|---|---|---|
| Leak check | 5 tonnes CO2 equivalent | 1 kilogram | Article 5(1) |
| 12-month interval | Under 50 tonnes CO2 equivalent | Under 10 kilograms | Article 5(6), point (a) |
| 6-month interval | 50 to 500 tonnes CO2 equivalent | 10 to 100 kilograms | Article 5(6), point (b) |
| 3-month interval | 500 tonnes CO2 equivalent or more | 100 kilograms or more | Article 5(6), point (c) |
| Leakage detection system | 500 tonnes CO2 equivalent | 100 kilograms | Article 6(1) |
The comparison that changes design decisions: a system holding 1 kilogram of an Annex II Section 1 gas has to be checked, while 1 kilogram of R-134a, at a GWP of 1 430, is 1,43 tonnes of CO2 equivalent and stays below the 5-tonne threshold. At small charges the HFO regime is the stricter one.
Article 6(1) sets the 100-kilogram figure for the equipment of Article 5(2), points (a) to (d). Article 6(2), which concerns organic Rankine cycles and electrical switchgear installed from 1 January 2017, is expressed only in tonnes of CO2 equivalent of Annex I gases. For those two categories there is no kilogram threshold for Annex II gases at all.
The calculation and the intervals are covered in leak check frequency, and detection systems in leak detection systems.
The duties that apply in full
The list below contains only provisions that name Annex II or its Section 1 expressly, or that speak of fluorinated greenhouse gases in general and therefore include them.
- Emission prevention. Article 4(1), (3) and (5): the ban on intentional release, the precautions against unintentional release and repair without undue delay. Article 4(6) makes the placing on the market of fluorinated greenhouse gases conditional on evidence about trifluoromethane produced as a by-product.
- Certification. Article 4(7), second subparagraph, requires certification of legal persons installing, servicing, repairing or decommissioning the listed equipment, for gases in Annex I and in Section 1 of Annex II. Article 10(5), point (c), includes the recovery of those gases in the certification programmes, and Implementing Regulation (EU) 2024/2215 names them expressly in Article 2(1).
- Records. Article 7(1) for equipment subject to checks, paragraph 3 for undertakings supplying such gases and paragraph 4 for sellers of non-hermetically sealed equipment charged with gases in Annex I and in Section 1 of Annex II.
- Recovery. Article 8(1) for all fluorinated greenhouse gases; paragraph 6 bars re-use of recovered Annex I and Annex II Section 1 gases without recycling or reclamation; paragraphs 7, 8 and 9 deal with containers and foams.
- The purchase right. Article 11(6) expressly covers gases listed in Annex I or in Section 1 of Annex II.
- Non-refillable containers. Article 11(3) prohibits the import, supply, use and export of non-refillable containers for gases listed in Annex I and in Section 1 of Annex II, empty or filled.
- Selling pre-charged equipment. Article 11(7) concerns non-hermetically sealed equipment charged with gases from both lists.
- Labelling. Article 12(1) and (3) for products and equipment; paragraph 5 for foams and pre-blended polyols containing gases listed in Annexes I and II; paragraph 7 for containers of reclaimed or recycled gas.
- Portal, licence and customs. Article 20(4), point (a), and Article 22(1) speak of fluorinated greenhouse gases without restricting the Annex, and Article 23(3) requires the corresponding data in the customs declaration.
- Reporting. Article 26(1): producers, importers and exporters report quantities exceeding one metric tonne or 100 tonnes of CO2 equivalent of fluorinated greenhouse gases other than hydrofluorocarbons. Paragraph 2 covers destruction, paragraph 4 gases contained in products and equipment, and paragraph 6 reclamation.
Portal registration is described in F-gas Portal registration, and the annual report in annual reporting.
What does not apply, and why
Each absence below follows from precise wording in the text, not from a general exemption for HFOs.
| Provision | Why it does not apply |
|---|---|
| Quota, Article 16(1) | It concerns the placing on the market of hydrofluorocarbons, defined in Article 3, point (4), as the substances listed in Section 1 of Annex I or mixtures containing any of those substances |
| Reference values and quota transfer, Articles 17 and 21 | They are built on the same quota system |
| Production rights, Articles 14 and 15 and Annex V | They concern the production of hydrofluorocarbons |
| Pre-charged equipment, Article 19(1) | It addresses equipment pre-charged with substances listed in Section 1 of Annex I |
| Servicing bans in Article 13(4) and 13(5) | They are drafted for fluorinated greenhouse gases listed in Annex I |
| The advertising mention, Article 12(16), second subparagraph | It applies to gases listed in Annexes I and II with a GWP of 150 or more; no Section 1 of Annex II substance reaches that value |
One exception worth reading twice. Article 13(3) is not limited to Annex I: it prohibits the use of fluorinated greenhouse gases with a GWP of 2 500 or more for the maintenance or servicing of refrigeration equipment. The wording therefore covers Annex II as well, but no substance in Section 1 comes close to 2 500. The drafting difference matters when you assess a blend rather than a pure substance.
On quota and the difference between registration, quota, authorisation and transfer, see the dedicated page, and on the CO2 equivalent calculation at import, the CO2 equivalent calculation.
Annex IV does not pass Annex II gases by
Many Annex IV entries are built on a GWP value, and there the Section 1 Annex II substances pass without difficulty. Other entries, however, simply prohibit equipment that contains fluorinated greenhouse gases, with no GWP limit at all. Those catch HFO refrigerants too.
| Annex IV entry | What it prohibits | Date |
|---|---|---|
| Point 2(b) | Domestic refrigerators and freezers that contain fluorinated greenhouse gases, except if required to meet safety requirements at the site of operation | 1 January 2026 |
| Point 7(c) | Chillers up to and including a rated capacity of 12 kW that contain fluorinated greenhouse gases, except if required to meet safety requirements | 1 January 2032 |
| Point 8(c) | Self-contained air-conditioning equipment and heat pumps up to and including 12 kW that contain fluorinated greenhouse gases, except if required to meet safety requirements | 1 January 2032 |
| Point 9(d) | Split systems of a rated capacity up to and including 12 kW that contain fluorinated greenhouse gases, except if required to meet safety requirements | 1 January 2035 |
| Point 17(c) | Foams that contain fluorinated greenhouse gases, except if required to meet safety requirements | 1 January 2033 |
| Point 19(b) | Technical aerosols that contain fluorinated greenhouse gases, except if required to meet safety requirements or when used for medical applications | 1 January 2030 |
| Point 20 | Personal care products that contain fluorinated greenhouse gases | 1 January 2025 |
By contrast, entries such as point 3(c), which addresses other fluorinated greenhouse gases with a GWP of 150 or more from 1 January 2025, do not reach Section 1 of Annex II substances, because all of them are below 150.
The full timetable of the prohibitions is in the ban timetable.
Mixtures: the rule that catches people out
This is where the most expensive mistake lives. Article 3, point (4), defines hydrofluorocarbons as the substances listed in Section 1 of Annex I or mixtures containing any of those substances. The definition sets no minimum proportion.
A blend containing even a fraction of a substance listed in Section 1 of Annex I is a hydrofluorocarbon for the purposes of the Regulation, however large the HFO share is. The quota system of Article 16 and the pre-charged equipment rule of Article 19 apply to it. Only a blend made up exclusively of substances that are not listed in Section 1 of Annex I stays outside the quota.
Article 3, point (2), defines a mixture as a substance composed of two or more substances, at least one of which is listed in Annex I, II or III. Article 3, point (1), and Annex VI give the method for the GWP: 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 %.
For a blend containing both Annex I and Section 1 Annex II gases, the check thresholds need care: Article 5(1) states a threshold in tonnes of CO2 equivalent for Annex I gases and a threshold in kilograms for Section 1 of Annex II gases. Test each component against its own threshold before concluding that a system is exempt.
The difference between virgin, recycled and reclaimed gas, relevant to Article 8(6) and to the label in Article 12(7), is explained on the dedicated page, and disposable cylinders in non-refillable cylinders.
Checklist
- Identify the substance in the right AnnexSection 1 of Annex I for HFCs, Section 1 of Annex II for HFOs and HCFOs. Article 2, point (a), covers them all.
- Use kilograms for Section 1 of Annex IIArticle 5(1): 1 kilogram, not 5 tonnes of CO2 equivalent.
- Check the blend before ruling out quotaArticle 3, point (4): any trace of a Section 1 Annex I substance makes the blend a hydrofluorocarbon.
- Do not assume Annex IV does not applyEntries with no GWP limit prohibit any fluorinated greenhouse gas, whatever its value.
- Confirm the purchase rightArticle 11(6) expressly covers gases listed in Section 1 of Annex II.
- Refuse non-refillable containersArticle 11(3) bans them for Section 1 Annex II gases as well.
- Check the reporting thresholdArticle 26(1): one metric tonne or 100 tonnes of CO2 equivalent for gases other than hydrofluorocarbons.
- Make sure the portal registration is valid before importingArticle 20(4), point (a), and Article 22(1) draw no distinction between Annexes.
Frequently asked questions
Do I need quota to import R-1234yf?
No. Article 16(1) makes the placing on the market of hydrofluorocarbons conditional on quota, and Article 3, point (4), defines them as the substances listed in Section 1 of Annex I or mixtures containing any of them. R-1234yf sits in Section 1 of Annex II. What does remain compulsory is a valid portal registration under Article 20(4), point (a), and the licence required by Article 22(1).
Does an HFO blend with a little R-32 stay outside the quota?
No. Article 3, point (4), brings into the definition of hydrofluorocarbons any mixture containing any of the substances listed in Section 1 of Annex I, with no minimum share. R-32 is listed there, so the blend falls inside the quota system.
Why does a small HFO system need checking when an R-134a one does not?
Because the unit differs. Article 5(1) sets 1 kilogram for Section 1 Annex II gases and 5 tonnes of CO2 equivalent for Annex I gases. At 1 kilogram, a gas with a GWP of 1 430 reaches 1,43 tonnes of CO2 equivalent and stays below the threshold, while the Annex II gas reaches its own.
Does the GWP 2 500 servicing ban apply to HFO gases?
Article 13(3) is not limited to Annex I, so formally it covers Annex II as well. In practice no Section 1 Annex II substance comes near 2 500 according to the GWP column of the Annex. Be careful with blends: their GWP is calculated in accordance with Annex VI and can exceed the threshold where the blend also contains Annex I components.
Does equipment charged with an Annex II gas have to be labelled?
Yes. Article 12(1) lists the categories of products and equipment that must be labelled where they contain fluorinated greenhouse gases or their functioning relies upon them, drawing no distinction between Annexes. The content of the label is that of paragraph 3, and the format is set by Implementing Regulation (EU) 2024/2174.
Is a leakage detection system compulsory at 100 kilograms?
Article 6(1) imposes that duty on operators of the stationary equipment of Article 5(2), points (a) to (d), containing 100 kilograms or more of Section 1 Annex II gases. Article 6(2), for organic Rankine cycles and electrical switchgear, is expressed only in tonnes of CO2 equivalent of Annex I gases.
Official sources
Annexes I, II, IV and VI were read in full in the Official Journal text, together with Chapters II, III, IV and V of the Regulation.
How current this page is, and its limits
This page compares the provisions of the Regulation according to the Annex in which the gas sits. It contains no prices, availability, penalty amounts or dangerous-goods data, and it does not replace checking the exact composition of a blend in the safety data sheet.
General information prepared by EgoLog on the basis of the official texts. It is not legal advice and it is not customs advice.
The Annexes may be amended. Check the text in force before taking a commercial decision. Check the safety class of each refrigerant in the safety data sheet and in the applicable standard; handling follows the applicable safety requirements, and work on the refrigerant circuit is done only by certified personnel. See safety classes.