Short answer
For gas leaving the Union the Regulation requires three things, and does not require a fourth that many people go looking for.
- A valid F-gas Portal registration before the operation — Article 20(4), point (a). Article 20(5) adds the decisive sentence: a valid registration in the F-Gas Portal at the moment of import or export constitutes the licence required under Article 22. There is no separate export licence document.
- Compliance with the export restrictions in Article 22, in particular the prohibition in paragraph 3 for certain equipment with a GWP of 1 000 or more, applicable from 12 March 2025.
- Correct data in the customs declaration and an annual report — Article 23(3) and Article 26(1) with Annex IX.
What the Regulation does not provide: any return of quota when gas leaves the Union. Annex VII sets the maximum quantities that may be placed on the market and how reference values are calculated; it contains no mechanism by which an export gives quota back. The only quota carve-out linked to export is in Article 16(2), point (c), and it bites before the gas is placed on the market.
No national customs procedures, lists of customs offices, form numbers, fees or national deadlines. No dangerous-goods thresholds either. The Union Customs Code appears only where the Regulation itself points at it. For the inbound procedure, see the dedicated import guide.
Three situations that get confused
The word export covers situations with different regimes. Before any paperwork, establish which one you are in.
| Situation | What the text calls it | Main consequence |
|---|---|---|
| Re-export of gas imported and released for free circulation | The gas has already been placed on the market within the meaning of Article 3, point (6) | Quota was consumed at import; the Regulation provides no way of getting it back |
| Direct export of bulk gas supplied by a producer or importer | Article 16(2), point (c): supplied directly for export, not contained in products or equipment, not made available to anyone in the Union first | Exempt from the quota requirement; the label must carry the direct-export statement under Article 12(9) |
| Export of products and equipment containing fluorinated greenhouse gases | Article 22(3) and Annex IV | Prohibited from 12 March 2025 for the listed categories at a GWP of 1 000 or more |
| Re-export of non-compliant goods found before release for free circulation | Article 11(1), third and fourth subparagraphs | Re-export is allowed, and in that case Article 22(3) does not apply |
There is one more line the Regulation draws, in Article 23(12), third subparagraph: the export of fluorinated greenhouse gases listed in Section 1 of Annex I for which non-compliance has been established after their release for free circulation is prohibited. The moment of discovery changes the outcome entirely.
For goods coming into the Union, see the HFC import procedure, and for quantities in CO2 equivalent, the CO2 equivalent calculation.
The portal and the licence are one thing, not two
Article 20(1) describes the F-gas Portal as the electronic system for the management of the quota system, the licensing requirements of imports and exports, and reporting obligations. Article 20(2) provides for interconnection with the EU Single Window Environment for Customs, and Article 20(7) gives competent authorities, including customs, access to the portal.
Article 20(4) lists the activities for which a registration must be valid before they are carried out. Point (a) covers expressly the import or export of fluorinated greenhouse gases and of 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. The registration is valid only once the Commission validates it and for as long as it is not suspended, revoked or withdrawn.
A valid registration in the F-Gas Portal at the moment of import or export constitutes a licence required under Article 22.
Article 22(1) closes the circle: the import and export of fluorinated greenhouse gases, and of products and equipment containing those gases or whose functioning relies upon them, are subject to the presentation to customs authorities of a valid licence issued by the Commission pursuant to Article 20(4) and (5), except in the case of temporary storage. The paragraph does not apply to products and equipment that are personal effects.
The Commission's portal page lists the categories that have to register, among them producers, importers and exporters of HFCs in bulk, exporters of other fluorinated greenhouse gases listed in Annexes I, II or III, and exporters of products and equipment containing such gases.
What registration is and is not — and how it differs from quota, authorisation and transfer — is set out in the guide on portal, quota, authorisation and transfer, and the enrolment steps in F-gas Portal registration.
What is not allowed to leave
The Article 22(3) prohibition. From 12 March 2025 the export of foams, technical aerosols, stationary refrigeration and stationary air-conditioning equipment and stationary heat pumps as referred to in Annex IV that contain, or whose functioning relies upon, fluorinated greenhouse gases with a GWP of 1 000 or more is prohibited.
The second subparagraph of that paragraph carries two exceptions: the prohibition does not apply to military equipment, nor to products and equipment that can be placed on the market in the Union in accordance with Annex IV. In other words, if the equipment would still be lawful to place on the internal market, this paragraph does not block its export.
The Article 22(4) derogation. The Commission may, by means of implementing acts, for cases of an exceptional nature, following a substantiated request by the competent authority of the Member State concerned, authorise the export of the products and equipment referred to in paragraph 3, where it is demonstrated that in view of the economic value and the expected remaining lifetime of the specific good, the prohibition of export would impose a disproportionate burden on the exporter. Such exports are only allowed if they are in accordance with the national law of the country of destination.
Restrictions notified by the destination country. Article 22(5): undertakings with an establishment within the Union shall take all necessary measures to ensure that the export of refrigeration and air-conditioning equipment and of heat pumps does not violate import restrictions that the importing state has notified under the Protocol.
Trade with States not covered by the Protocol. Article 25(1): the import and export of hydrofluorocarbons, and of products and equipment containing them or whose functioning relies upon them, from and to any State or regional economic integration organisation that has not agreed to be bound by the provisions of the Protocol applicable to those gases, shall be prohibited from 1 January 2028. Article 25(3) allows the Commission to authorise such trade by implementing act to the extent that the State is determined by a meeting of the Parties to be in full compliance with the Protocol.
There is no article in the Regulation headed export licences, and no list of countries to which export is already prohibited today. Article 25 sets a date, 1 January 2028, and a criterion — acceptance of the applicable Protocol provisions. The status of a particular country is checked at source, not assumed.
Quota and labels: where export really does matter
Article 16(1) says the placing on the market of hydrofluorocarbons is allowed only to the extent that producers and importers have been allocated quota. Article 16(2) lists the cases in which paragraph 1 does not apply, and point (c) is the one about export:
Hydrofluorocarbons supplied directly by a producer or an importer to undertakings for export out of the Union, not contained in products or equipment, where those hydrofluorocarbons are not subsequently made available to any other person within the Union, prior to export.
Three cumulative conditions, then: direct supply from a producer or importer, bulk gas, and no making available inside the Union before export. If the cylinder has passed through a distributor and been made available to someone else in the Union, the carve-out no longer applies — the gas was placed on the market and the quota was used there.
The label travels with the carve-out. Article 12(9) requires containers holding Annex I gases and intended for direct export to be labelled with an indication that the contents are for direct export only. Article 12(14) adds, for gases listed in Section 1 of Annex I, that the label referred to in paragraphs 8 to 12 must include the indication that the contents are exempted from quota under the Regulation, and it gives a warning: in the absence of those labelling requirements, the hydrofluorocarbons shall be subject to the quota requirements pursuant to Article 16(1).
The exact wording comes from Implementing Regulation (EU) 2024/2174, Article 1(7), point (d), which prescribes the text for Annex I gases supplied by a producer or importer to an undertaking for direct export in bulk out of the Union, completed by the quota-exemption statement set out in the closing subparagraph of the same paragraph.
The rest of the labelling duties still apply: the content required by Article 12(3), the legibility and language of Article 12(4), and the format in Article 1(1) to (3) of the implementing regulation. For reclaimed or recycled gas the indications of Article 12(7) are added, explained in the guide on reclaimed, recycled and virgin refrigerant.
Annual reporting of exported quantities
Article 26(1), first subparagraph: by 31 March 2025 and every year thereafter, each 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 during the preceding calendar year shall report to the Commission the data specified in Annex IX on each of those substances.
What the exporter reports is in Annex IX, point 3: the quantities of each substance listed in Annexes I, II and III that it has exported from the Union, specifying whether from own production or import or whether purchased from other undertakings within the Union, including the amounts of hydrofluorocarbons contained in pre-blended polyols.
That is exactly the distinction this page makes. The report does not only ask how much you exported; it asks where the gas came from. The traceability has to exist in your own records before it can be transcribed into the report.
The importer has a mirror obligation in Annex IX, point 2: it reports separately, among other things, amounts imported, not released for free circulation and re-exported contained in products or equipment by the reporting undertaking, as well as direct exports, identifying the exporting undertaking. Quantities are reported separately for each country of origin.
Article 26(9) specifies that all reporting and verification is carried out via the F-gas Portal. The annual routine is covered in the guide on annual F-gas reporting.
Annex IX, point 6(d) requires reporting of the amount of hydrofluorocarbons charged into imported equipment, released for free circulation, for which the hydrofluorocarbons had previously been exported from the Union and had been subject to quota limitations for placing on the Union market. In that case the report must also specify the exporting undertaking and the year of export, as well as the undertaking that first placed the gas on the Union market and the year of that placing.
The document chain, in order
Check the portal registration before anything else
Article 20(4), point (a) requires a valid registration before export. Without it there is no licence under Article 22(1), because the licence is the registration (Article 20(5)).
Establish which situation you are in
Re-export of gas already released for free circulation, direct bulk export within the meaning of Article 16(2), point (c), or export of equipment. Each has different quota and labelling consequences.
Check the restrictions that apply to the goods
Article 22(3) for Annex IV equipment at a GWP of 1 000 or more, Article 22(5) for restrictions notified by the importing state, and Article 25(1) for trade with States not covered by the Protocol.
Inspect the cylinder label
The content required by Article 12(3), the legibility and language of Article 12(4), the direct-export statement of Article 12(9) and the quota-exemption indication of Article 12(14) where they apply.
Prepare the data for the customs declaration
Article 23(3) requires, on export, the F-gas Portal registration identification number, the EORI number, the net mass, the commodity code and the tonnes of CO2 equivalent.
Make sure the declared exporter is the registered undertaking
Article 23(2), third subparagraph: for exports, the undertaking registered in the F-gas Portal shall be the exporter indicated in the customs declaration. Article 23(4) requires customs to verify this.
Prepare the commercial document and the packing list
Product designation, quantity in kilograms and in CO2 equivalent, cylinder numbers and the reference to the safety data sheet. Not a requirement of the Regulation, but what supports the data in the declaration.
Keep the records that concern the goods
If you supplied the gas to an undertaking, Article 7(3) requires the purchaser's certificate number and the quantities, kept for at least 5 years. Your internal records must also show where the gas came from, for Annex IX, point 3.
Enter the operation into the annual report preparation
Article 26(1) and Annex IX, point 3, through the F-gas Portal, by 31 March of the following year.
Checklist before despatch
- The F-gas Portal registration is validated and activeArticle 20(4), point (a) and the closing subparagraph of that paragraph.
- You know which of the three export situations appliesRe-export after release for free circulation, direct export within Article 16(2), point (c), or export of equipment.
- The goods do not fall under the Article 22(3) prohibitionFoams, technical aerosols, stationary refrigeration, stationary air conditioning and stationary heat pumps as referred to in Annex IV, at a GWP of 1 000 or more.
- Restrictions notified by the importing state have been checkedArticle 22(5), for refrigeration and air-conditioning equipment and heat pumps.
- The destination country's status under the Protocol is knownArticle 25(1) sets the date of 1 January 2028 for States that have not agreed to be bound by the applicable provisions.
- The label matches the situationArticle 12(9) for direct export, Article 12(14) for the quota-exemption indication, Article 12(3) and (4) for the rest.
- The Article 23(3) data are ready for customsPortal registration number, EORI, net mass, commodity code, tonnes of CO2 equivalent.
- The exporter on the customs declaration is the registered undertakingArticle 23(2), third subparagraph.
- The origin of the gas is documentedOwn production, import, or purchase from another undertaking in the Union — the distinction required by Annex IX, point 3.
- The operation is queued for the annual reportArticle 26(1), through the portal, by 31 March.
Frequently asked questions
Do I get quota back if I export gas I imported?
No. The Regulation provides for no return of quota on export. Quota attaches to the placing on the market, defined in Article 3, point (6) as release for free circulation or the first supply within the Union, and Annex VII sets the maximum quantities and the method for calculating reference values with no export-credit mechanism. The only export-related carve-out is Article 16(2), point (c), which applies before the gas is placed on the market.
Do I need a separate export licence?
No. Article 22(1) requires the presentation to customs of a valid licence issued by the Commission pursuant to Article 20(4) and (5), and Article 20(5) says that a valid registration in the F-Gas Portal at the moment of import or export constitutes that licence. There is no second document to apply for.
Is the export of second-hand equipment allowed?
It depends on the equipment and the gas. Article 22(3) prohibits, from 12 March 2025, the export of foams, technical aerosols, stationary refrigeration and stationary air-conditioning equipment and stationary heat pumps as referred to in Annex IV containing gases with a GWP of 1 000 or more. The exceptions are military equipment and products that can still be placed on the market in the Union in accordance with Annex IV. Article 22(4) allows an individual derogation in exceptional cases, authorised by the Commission.
What happens to goods found to be non-compliant?
The moment of discovery decides. Article 11(1), fourth subparagraph allows the re-export of products and equipment for which the non-compliance has been established prior to their release for free circulation, and in such cases Article 22(3) does not apply. Conversely, Article 23(12), third subparagraph prohibits the export of fluorinated greenhouse gases listed in Section 1 of Annex I for which the non-compliance has been established after their release for free circulation.
Does temporary storage require registration?
Article 20(4), point (a) expressly excludes temporary storage, as defined in Article 5, point (17), of Regulation (EU) No 952/2013, from the activities that require prior registration. Likewise, Article 22(1) exempts temporary storage from the licence requirement. Note, however, Article 23(2), second subparagraph, which deals separately with imports other than release for free circulation.
Is re-exported gas treated as reclaimed or as virgin?
Article 22(2) says only this: fluorinated greenhouse gases imported into the Union shall be considered as virgin gases. Reclaimed or recycled status depends on labelling under Article 12(7) and on the definitions in Article 3. Do not infer status from the commercial route.
Do I have to report even if I exported small quantities?
Article 26(1), first subparagraph ties the reporting duty to hydrofluorocarbons or to quantities of other fluorinated greenhouse gases exceeding one metric tonne or 100 tonnes of CO2 equivalent during the preceding calendar year. Check the wording that applies to your situation in the official text before concluding that you have no duty; reporting in any event goes through the portal under Article 26(9).
Official sources
Chapters IV and V of the Regulation were read in full in the Official Journal text, together with Annexes VII and IX. The Union Customs Code is cited only where the Regulation itself points at it.
How current this page is, and the limits of our liability
This page reports what the Regulation says about export, including where the text says something other than what is commonly assumed. It does not contain national customs procedures, it does not confirm the status of any particular country under the Protocol, and it does not replace checking the commodity code and the customs regime applicable to your operation.
General information prepared by EgoLog on the basis of the Regulation, the implementing regulation on labelling and official Commission material. It is not legal advice and it is not customs advice.
Annex IV and the Protocol lists may be amended. Check the text in force and confirm the applicable regime with the competent customs authority before committing to a shipment.