A practical overview of the current EU framework governing fluorinated greenhouse gases and the obligations that may apply to businesses.
Fluorinated greenhouse gases, commonly known as F-gases, are widely used in refrigeration, air-conditioning systems, heat pumps, fire-protection equipment and a range of industrial applications. Although they are used in relatively small quantities compared with carbon dioxide, many F-gases have a very high Global Warming Potential (GWP).
To reduce their impact on climate change, the European Union has introduced increasingly strict controls over their production, importation, use and eventual recovery.
The current framework is established primarily by Regulation (EU) 2024/573 on fluorinated greenhouse gases, which replaced Regulation (EU) No 517/2014 and has applied since 11 March 2024. The Regulation applies throughout the European Union, including Cyprus.
The Regulation applies to fluorinated greenhouse gases listed in its Annexes I, II and III, whether used individually or as part of mixtures. It also applies to products and equipment that contain F-gases or rely on them for their operation.
Businesses potentially affected include:
The exact obligations depend on the nature of the activity, the type of gas involved and the quantities handled.
One of the central objectives of the new Regulation is to significantly reduce the availability and use of hydrofluorocarbons (HFCs) within the European Union.
The EU quota system progressively restricts the amount of HFCs that may be placed on the EU market. Under the current framework, the quota is progressively reduced with the objective of phasing out HFC consumption in the EU by 2050.
Businesses that depend on refrigeration, air-conditioning, heat pumps or other HFC-based technologies should therefore consider not only their present compliance obligations but also the effect of the gradual transition towards lower-GWP and non-fluorinated alternatives.
Regulation (EU) 2024/573 introduces and expands restrictions on placing certain products and equipment containing F-gases on the market. The restrictions are introduced progressively and depend on matters such as:
The legislation contains specific phase-out dates for refrigeration equipment, chillers, air-conditioning systems, heat pumps and other products. For example, new restrictions already apply to certain refrigeration equipment, while further restrictions affecting chillers, air-conditioning systems and heat pumps take effect progressively from 2027 onwards.
Businesses involved in importing or distributing such products should therefore review the applicable restrictions before placing equipment on the EU market.
The European Commission F-Gas Portal is a central part of the regulatory framework. Depending on their activities, businesses may be required to register before importing, exporting or carrying out other regulated activities involving F-gases.
Registration is particularly important for companies involved with HFC quotas, authorisations and imports of products or equipment containing regulated gases. Customs authorities can use the information held in the F-Gas Portal when checking imports and exports. Registration should therefore be completed correctly and the company information maintained accurately and kept up to date.
Certain companies carrying out activities covered by the Regulation must submit an annual F-Gas report to the European Commission. Reporting is generally completed electronically through the Commission’s reporting system connected with the F-Gas Portal.
For the categories of undertakings falling within Article 26, the annual reporting deadline is generally 31 March following the relevant calendar year.
The information reported may include quantities of F-gases:
Different thresholds and reporting requirements apply depending on the company’s activities.
Special rules apply when refrigeration equipment, air-conditioning equipment, heat pumps and certain other products are imported into the EU already charged with HFCs. Where the legislation applies, the HFCs contained in the equipment must be properly accounted for within the EU quota system.
This can require appropriate quota authorisations or delegations, supporting documentation and a declaration of conformity. The Regulation therefore affects more than businesses trading directly in refrigerant gases. Companies importing equipment that already contains HFCs may also have significant compliance obligations.
An important part of the regulatory framework is the requirement for certain information to be independently verified.
| Key threshold Where an undertaking reports that it placed 1,000 tonnes of CO₂ equivalent or more of HFCs on the market during the preceding calendar year, the accuracy of the report must generally be confirmed by an independent auditor at a reasonable level of assurance. The verification is generally required by 30 April. |
The independent auditor must be appropriately qualified under the Regulation and registered in the F-Gas Portal. Separate verification requirements also apply in certain circumstances to importers of products and equipment pre-charged with HFCs.
The European Commission has introduced detailed arrangements governing declarations of conformity and independent verification through Commission Implementing Regulation (EU) 2025/2155.
The Regulation is not limited to imports and reporting. Operators of equipment containing F-gases may also have obligations concerning:
The rules also progressively restrict the use of certain high-GWP gases for servicing existing equipment. For example, from 1 January 2026, the use of F-gases listed in Annex I with a GWP of 2,500 or more for servicing air-conditioning equipment and heat pumps is generally prohibited, subject to specific transitional exceptions for reclaimed and recycled gases.
F-Gas compliance increasingly affects import procedures, customs clearance, product selection, supply chains and annual regulatory reporting. Businesses should therefore establish:
F-Gas compliance should consequently be considered before an import takes place, rather than only when the annual reporting deadline approaches.
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