The amendment to Regulation (EU) 2024/573, which came into force on 11 March 2024, aims to accelerate the EU's phase-out of fluorinated greenhouse gas emissions. The regulations for the import and export of fluorinated greenhouse gases have therefore been tightened. Companies that import or export fluorinated greenhouse gases to the EU must now register on the newly created F-gas portal in order to obtain a valid licence. The beginning of 2025 brought dynamic developments: firstly, new regulations on labelling obligations and chargeable quota allocation have been applicable since 1 January 2025. In addition, supplementary implementing regulations and guidelines from the EU Commission for registration in the F-Gas portal were published in March 2025, providing valuable assistance.

Start of application of the regulations on labelling requirements and quota allocation

Regulation (EU) 2024/573 (hereafter "F-Gas Regulation") entered into force on 11 March 2024, replacing Regulation 517/2014, which has been in force since 1 January 2015. There are also various implementing regulations that supplement the provisions of the F-Gas Regulation. Since 1 January 2025, the new provisions on labelling requirements and regulations on the modalities of quota allocation for the placing on the market of hydrofluorocarbons have been applicable. In addition, bans on the placing on the market of products containing fluorinated greenhouse gases with a particularly high global warming potential have been in force since 1 January 2025. Further regulations regarding the use of the ‘F-gas portal’ have been in force since 3 March 2025.

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The F-Gas Regulation as a building block of the European Green Deal

By revising the F-Gas Regulation, the EU Commission is driving forward the European Green Deal's goal of making Europe the first climate neutral continent by 2050. The EU has set itself the ambitious target of reducing emissions of fluorinated greenhouse gases to 'zero' by 2050.

Fluorinated greenhouse gases are man-made chemicals that are very potent greenhouse gases, often thousands of times more potent than carbon dioxide (CO2). The Regulation applies to the fluorinated greenhouse gases and mixtures listed in Annexes I to III of the Regulation. They are considered to be particularly harmful to the climate, but are still used in certain industries. In particular refrigeration units, air conditioning equipment and heat pumps rely on fluorinated greenhouse gases through the use of chemicals. By strengthening the F-Gas Regulation, the EU wants to create incentives to switch to alternatives that are already available and have a lower impact on the climate, or to develop innovative new solutions.

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Significant changes

The provisions of the previous Regulation (EU) 517/2014 have already led to a gradual reduction of fluorinated greenhouse gas emissions across the EU. The new version of the F-Gas Regulation aims to accelerate the phase-out of fluorinated greenhouse gas emissions in the EU. This applies to the import and export as well as the production and use of these greenhouse gases within the Union. The prohibitions from placing on the market and use of certain products have been adapted and extended.

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Registration in the F-Gas portal

In future, importers and exporters of fluorinated greenhouse gases and equipment and products containing them will have to register in advance on the electronic F-Gas Portal and submit valid licences to customs authorities before importing or exporting. The F-Gas Portal replaces the electronic register previously maintained by the EU. In the future, the F-Gas Portal will be interconnected to the EU's single window environment for customs, once it is established, so that customs authorities can take over the implementation of import and export requirements.

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Quota allocation subject to a charge

The Regulation further reduces the annual quantities of partially fluorinated greenhouse gases available in the EU by 2050. The production of hydrofluorocarbons in the Union will only be allowed following the allocation of quantitative production rights. Producer and importers of hydrofluorocarbons will have to apply for quotas for placing on the market, as was the case under the previous Regulation. However, the quota allocations shall be subject to the payment. The fee is EUR 3 per tonne of CO2 equivalent to be allocated. Producers and importers have the option of paying for only part of their allocated quota, thus reducing their quota according to their needs. Until 2028, unused quotas will be distributed free of charge. From 2028, unused quotas will be cancelled. The possibilities for transferring quotas have also been tightened. Allocated quotas can now only be transferred once.

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Outlook and challenges

Companies importing fluorinated greenhouse gases into the Union or exporting them from the Union must register on the F-Gas Portal and obtain a licence. From 1 January 2025, the placing on the market ban will also apply to other refrigeration equipment, refrigeration systems, fire protection equipment and personal care products, for example. In addition, the list of bans on the marketing of certain products containing fluorinated greenhouse gases and restrictions on their use is constantly being expanded.  From 1 January 2025, there will also be a ban on metered dose inhalers filled with the partially fluorinated hydrocarbons listed in Annex I, Group 1. From 3 March 2025, the F-Gas portal will be interconnected to the customs single window environment, which is not yet active. The EU Commission has already published and integrated the corresponding TARIC codes. The EU Commission is also gradually publishing exemptions from the regulation for certain goods. For example, on 16 December 2024, exemptions were published for blood transport boxes and blood plasma contact shock freezers, as well as for mechanical cryogenic freezers at -150 degrees Celsius. The EU Commission also published guidelines for registration on the F-Gas Portal on 17 March 2025. On 31 March 2025, implementing regulations were also published regarding certificates for the recovery of solvents and work on fire protection systems and electrical switchgear. It is therefore important to keep an eye on the Commission's communications.