Consultation outcome

Environment Agency charge proposal: fluorinated greenhouse gases (F gas) and ozone depleting substances (ODS): summary of consultation responses

Updated 1 April 2025

Introduction

The Environment Agency administers the fluorinated greenhouse gases (F gas) and ozone depleting substances (ODS) online services on behalf of England, Scotland and Wales.

Our role is to manage businesses registering on these services. This involves:

• calculating quota and managing quota transactions
• determining licence applications
• reviewing annual reports
• working with businesses and HM Revenue and Customs to ensure ongoing compliance with the scheme
• providing guidance and a helpdesk

The government funding we receive to manage these services is no longer sufficient. We will not be able to continue to provide the same level of service without introducing charges to fully recover our costs.

The consultation set out our new charging proposals for F gas and ODS and we invited businesses to share their views.

How we ran the consultation

The consultation ran for 8 weeks from 19 December 2024 to 13 February 2025. It was hosted on GOV.UK and our consultations website (Citizen Space). It was open to anybody to take part. Those who preferred to respond by email or post were able to request a copy of the consultation document and response form instead of responding online.

We ran the consultation in line with our legal requirements to consult following the Cabinet Office’s consultation principles guidelines. We notified ministers of our intention to consult.

It was important for us to give our customers the opportunity to understand the proposals and the impact they will have. We encouraged our customers to give us their views through the consultation and publicised it openly.

In the run up to the consultation, our staff engaged with over 2,000 businesses. We directly contacted each registered business advising them of our consultation, when it launched, and again before the end of the consultation period.

Key findings and actions we will take

This section includes an overview of responses to the consultation, key points we identified within those responses and a summary of our response to each of these.

Overview of consultation responses

We received a total of 144 responses to the consultation. Of these responses,143 were submitted using our Citizen Space consultation tool and one was sent using our consultation response form.

The 144 responses were submitted by:

• 18 individuals
• 122 organisations or groups
• 1 other
• 3 who provided no information

You can find detailed information on the responses to each question in Annex 1. This includes analysis of the comments we received. Annex 2 gives a list of organisations and groups that participated in the consultation. These organisations represent a broad range of the businesses that use the service.

The overall response to this consultation represents approximately a 7% response rate from our over 2,000 registered customer base. We are really pleased with this response. We would like to thank all those who participated in the consultation and took time to provide this valuable feedback.

Consultation outcome

We conducted a thorough review of comments to identify the key points from the themes and considered whether it may be appropriate to make changes to our original proposals. The consultation feedback was very helpful in understanding any concerns or issues relating to our proposals. It was also valuable to hear from those who expressed their support for the changes we proposed.

After careful consideration, we will implement all the proposed charges as outlined in the consultation document. A summary of feedback we received and our response to the key points are set out under separate headings.

Key themes and our response

The overview of all the feedback to the consultation is provided in Annex 1.

Respondents commented on how we have designed the proposed charging scheme and how the proposed charges may impact our customers. Specific points raised by respondents and our response follow.

Impact to customers – charges are too high

Businesses did not support the introduction of these new charges, and some considered the charges too high.

“It is a high service fee for our company”

“Charge is way too high”

Although the majority of responses were against introducing charges for the provision of these services, we noted that there was support from a minority of businesses for their introduction.

“We believe that the proposed charges for F gas annual subsistence are reasonable and necessary to maintain the high standards of environmental protection and compliance.”

“As per the registration fee it seems reasonable, provided charges don’t escalate and keep in line with the value of services and support provided.”

Our response

We need to make sure we fully recover our costs, and in line with other regulatory regimes will apply the polluter pays principle. We have designed our charges in line with managing public money rules to reflect the distinct items of work we need to undertake.

The design of the scheme has been made to make sure that we recover the appropriate costs for each component of our work.

Charge scheme design – seek other funding sources

Many comments asked why the customer now had to pay for the service including a subsistence charge.

“This is a statutory requirement, not a voluntary one. On that basis, the service should be fully funded by government. Statutory requirements should not be directly chargeable”

“I do not agree with annual fee. This is a government organisation and government policy and is funded by the government. From company taxes we already pay”

Our response

Since EU exit, the funding for F gas and ODS services have been directly from government; businesses have not had to contribute to the costs of delivery.

The majority of companies did not support the proposal to introduce charges to those businesses that utilise the service.

The polluter pays principle applies to our other regulatory regimes, and we are introducing charges to this service to abide by that principle.

We would also like to make it clear that the registration charge does not apply to existing F gas, ODS and LabODS registered businesses. The registration charge will only apply to companies who decide they need to start to use these services and register for the first time.

Also, the subsistence charges will only apply to businesses that are:

• required to submit reports on their F gas activities
• ODS businesses holding a licence within the calendar year
• ODS business who are required to submit a report for the calendar year

The Environment Agency will invoice the appropriate companies at the end of the calendar year.

Charge scheme design – other suggestion that charges should be based on substance use

The majority of businesses did not agree with the introduction of these new charges. Several respondents suggested that the charge should be based on the quantity of the substances used.

“Again, apply a levy per tonne - this isn’t anti-competitive, whereas your proposed system is. More income will be generated with a levy per tonne model.”

“A suggestion of a tiered subsistence charge based on annual reported quantities may be beneficial.”

Our response

Our regulatory work is not linked to the quantities of substances used by individual businesses but relates to distinct items of service delivery. Therefore, applying a sliding or tiered charge based on usage would not be compliant with managing public money rules.

Next steps

We have considered all consultation feedback and assessed whether we need to make changes to our proposals.

We have now published the updated charging scheme on GOV.UK. The charges are effective from 1 April 2025.

We have also published a guide on how we calculate our charges.

Annex 1: Detailed summary of consultation responses

This annex sets out the responses we received to our consultation on Environment Agency charge proposal: fluorinated greenhouse gases (F gas) and ozone depleting substances (ODS).

The consultation questions were divided into several topics: 

• about you and additional questions 
• F gas charging proposals
• ODS charging proposals
• additional comments about the charging proposals 

We received 144 responses through the online tool and consultation response form.

About you 

Within the online tool and response form, we included an ‘about you’ section to provide us with an understanding of who responded and to help us better analyse the consultation feedback.

We asked if consultees were giving a personal response as an individual or providing their response on behalf of an organisation. The 144 responses (143 online and one using our consultation response form), stated:

• responding as an individual – 18
• responding on behalf of an organisation, group or trade association – 122
• other – 1
• no answer given – 3

We asked those responding to tell us which section of the consultation they were responding to 

• F gas only – 102
• ODS only – 16
• both F gas and ODS – 23
• no answer given – 3

We asked how respondents found out about the consultation and they said: 

• from the Environment Agency – 131
• from another organisation – 1
• press article – 3
• social media, for example, Facebook – 2
• through a meeting you attended – 1
• through an organisation, group or trade association you are a member of – 1
• not answered – 2
• other – 3

The 3 responses who said ‘other’, found out about the consultation from:

• email from colleague
• Linkedln network
• word of mouth

Consultation questions

Questions are set out in the same format as they were presented in the online consultation tool and response form. Multiple choice questions gave respondents the option to select one response. These were followed by a free text box for comments.

For each question, we report the multiple choice options selected and the ‘themes’ identified in free text comments.

Themes or key points: We reviewed the free text comments and used content analysis to define and group recurrent ideas or concerns. We used descriptive labels (called ‘tags’) to summarise specific ideas. More than one ‘tag’ can be used in a comment. We then grouped ‘tags’ of a similar nature within a ‘theme’. These ‘themes’ help us to describe the overall response to each question and show where particular feedback was given about the consultation, environment or Environment Agency. The tag ‘not applicable’ is used if a comment does not include any relevant themes.

Themes are given in descending order with the most frequently identified first. Any ‘tags’ identified more than 3 times are noted alongside themes to give additional detail about the feedback we received. The number of times a tag is identified is given in brackets. When the number of each individual tag identified in a theme are added together, and is less than 10, we report the theme only.

F gas charging proposals

Question 1: Do you agree or disagree with the proposed F gas registration charge?

This question received more negative (70) responses than positive (24) responses:

• strongly agree – 3
• agree – 21
• neither agree nor disagree – 14
• disagree – 20
• strongly disagree – 50
• do not know – 4
• not applicable – 11
• did not answer – 21

Free text comments were submitted by 56 respondents to the consultation (39%):

• charge scheme design – ‘charging and permitting policy’ (20); ‘other suggestion for proposal’ (14); ‘seek other funding’ (3)
• impact for customers – ‘ economic impact for customers’ (16); ‘charge is too high’ (7)
• support for proposal – ‘partially agree with proposal’ (14); ‘agrees with proposal’ (3)

The following themes of ‘our business approach’, ‘protecting the environment’ and ‘service we provide’ were identified fewer times. Three comments were ‘not applicable’.

Question 2: Do you agree or disagree with the proposed F gas annual subsistence charge?

This question received more negative (87) responses than positive (20) responses:

• strongly agree – 1
• agree – 19
• neither agree nor disagree – 10
• disagree – 22
• strongly disagree – 65
• do not know – 2
• not applicable – 3
• did not answer – 22

Free text comments were submitted by 64 respondents to the consultation (44%):

• charge scheme design – ‘charging and permitting policy’ (35); ‘other suggestion for proposal’ (28); ‘seek other funding’ (3)
• impact for customers – ‘economic impact for customers’ (31); ‘charge is too high’ (14)
• support for proposal – ‘partially agree with proposal’ (9); ‘agrees with proposal’ (4) 

The following theme of ‘our business approach’ was identified fewer times. One comment was ‘not applicable’.

ODS charging proposals

Question 3: Do you agree or disagree with the proposed charge for registering on the ODS service?

This question received slightly more negative (19) responses than positive (17) responses:

• strongly agree – 1
• agree – 16
• neither agree nor disagree – 15
• disagree – 8
• strongly disagree – 11
• do not know – 5
• not applicable – 68
• did not answer – 20

Free text comments were submitted by 34 respondents to the consultation (24%):

• charge scheme design – ‘charging and permitting policy’ (12); ‘other suggestion for proposal’ (5)
• impact for customers – ‘economic impact for customers’ (8); ‘charge is too high’ (8)
• other issues – ‘customer is not affected by charge’ (9)

The following themes of ‘support for proposal’ ,‘our business approach’ and ‘other issues’ were identified fewer times.

Standard import or export licence application charge

Question 4: Do you agree or disagree with the proposed ODS standard import or export licence application charge?

This question received slightly more negative (19) responses than positive (18) responses:

• strongly agree – 4
• agree – 14
• neither agree nor disagree – 13
• disagree – 9
• strongly disagree – 10
• do not know – 3
• not applicable – 70
• did not answer – 21

Free text comments were submitted by 30 respondents to the consultation (21%):

• charge scheme design – ‘charging and permitting policy’ (14); ‘other suggestion for proposal’ (5)

• impact for customers – ‘economic impact for customers’ (5); ‘charge is too high’ (5); ‘increased regulatory burden’ (1)

The following theme of ‘support for proposal’ and ‘other issue’ were identified fewer times.

Multi-shipment import or export licence application charge

Question 5: Do you agree or disagree with the proposed ODS multi-shipment import or export licence application charge?

This question received slightly more negative (17) responses than positive (13) responses:

• strongly agree – 2
• agree – 11
• neither agree nor disagree – 17
• disagree – 9
• strongly disagree – 8
• do not know – 3
• not applicable – 74
• did not answer – 20

Free text comments were submitted by 24 respondents to the consultation (17%):

• impact for customers – ‘economic impact for customers’ (6); ‘charge is too high’ (6);
• charge scheme design – ‘charging and permitting policy’ (8)

The following themes of ‘support for proposal’, ‘other issue’ and ‘our business approach’ were identified fewer times. Four comments were ‘not applicable’.

ODS charging proposals: LabODS declaration charge

Question 6: Do you agree or disagree with the proposed LabODS declaration charge?

This question received more negative (22) responses than positive (10) responses:

• strongly agree – 3
• agree – 7
• neither agree nor disagree – 11
• disagree – 10
• strongly disagree – 12
• do not know – 5
• not applicable – 77
• did not answer – 19

Free text comments were submitted by 27 respondents to the consultation (19%):

• impact for customers – ‘charge is too high’ (9) ‘economic impact for customers’ (7)
• charge scheme design – ‘charging and permitting policy’ (8); ‘other suggestion for proposal’ (3)

The following themes of ‘support for proposal’, ‘our business approach ’ and ‘other issues’ were identified fewer times.

ODS charging proposals: quota application charge

Question 7: Do you agree or disagree with the proposed ODS quota applications charge?

This question received more negative (19) responses than positive (9) responses:

• strongly agree – 4
• agree – 5
• neither agree nor disagree – 11
• disagree – 12
• strongly disagree – 7
• do not know – 6
• not applicable – 80
• did not answer – 19

Free text comments were submitted by 25 respondents to the consultation (17%):

• impact for customers – ‘economic impact for customers’ (8); ‘charge is too high’ (6)
• charge scheme design – ‘charging and permitting policy’ (10); ‘other suggestion for proposal’ (3)

The following themes of ‘other issues’ and ‘support for proposal’ were identified fewer times.

ODS charging proposals: annual subsistence charge

Question 8: Do you agree or disagree with the proposed ODS annual subsistence charge?

This question received more negative (32) responses than positive (7) responses:

• strongly agree – 3
• agree – 4
• neither agree nor disagree – 9
• disagree – 11
• strongly disagree – 21
• do not know – 4
• not applicable – 72
• did not answer – 20

Free text comments were submitted by 35 respondents to the consultation (24%):

• impact for customers – ‘charge is too high’ (13); ‘economic impact for customers’ (13); ‘seek other funding’ (2)
• charge scheme design – ‘charging and permitting policy’ (15); ‘other suggestion for proposal’ (4)
• other issues – ‘other issues’ (7) ‘customer is not affected by charge’ (4);

The following themes of ‘support for proposal’, ‘our business approach’ and ‘the consultation design’ were identified fewer times.

Additional comments about the F gas and ODS charging proposals

Question 9: Please share any additional comments or suggestions you may have about our F gas and ODS charging proposals.

Free text comments were submitted by 70 respondents to the consultation (49%):

• charge scheme design – ‘charging and permitting policy’ (49); ‘other suggestion for proposal’ (31); ‘seek other funding’ (2)
• impact for customers – ‘economic impact for customers’ (46); ‘charge is too high’ (16)
• other issues – ‘other issues’ (17)
• support for proposal – ‘partially agree with proposal’ (8); ‘agrees with proposal’ (5)

The following themes of ‘our business approach’ and ‘service we provide’ were identified fewer times. Three comments were ‘not applicable’.

Annex 2: List of consultation participants

The number of respondents in the consultation who said they were an organisation or business will differ from the number of organisations named in this list. This is because some respondents indicated they did not want their response to be published.

List of organisations or businesses that gave a name

Apex Molecular Limited

Apollo Scientific Ltd

ARKEMA

Automated Environmental Systems Ltd

Avtrade Ltd

Azur Aviation Limited

Baotou Daozheng trading Co.LTD

Beijing Daozheng international tax consulting Co.LTD

Capelo Limited

Capes Consulting Ltd

Charles River Labs

Chengdu Daozhengxingyuan trading Co.LTD

China Tesa Appliance Co., Limited

Chongqing Daoxin trading Co.LTD

Clivet S.p.A. Group, including:

• CLIVET S.P.A. (FG72UA63NE)

• CLIVET GMBH (FG00LD46AB)

• CLIVET AIRCONDITIONING SYSTEMS PRIVATE LIMITED (FG62RO37VR)

• OOO CLIVET (FG80QB33GA)

• CLIVET MIDEAST FZCO (FG72HZ70KS)

• CLIVET GROUP UK LIMITED (FG07AF60GW)

• CLIVET AIR S.R.L. (FG79AV04KH)

• CLIVET FRANCE SAS (FG88BF51RW)

• CLIVET SOUTH-EAST EUROPE D.O.O. (FG17PT52CU)

Colmenar Associates Ltd

Concept Life Sciences IDDS Ltd

Cormica Bradford Ltd.

CRUK Scotland Institute

Daikin Applied (UK) Ltd

Daozheng (Changchun) flourine trade Co.LTD

Daozheng (Haikou) trading Co.LTD

Dola (Guangzhou) Chemical trade Co.LTD

Dometic UK Ltd

F and R Products Limited

FG EUROPE UK LIMITED

Fireboy Xintex UK Operations Ltd.

FläktGroup UK Limited

Fluorochem Ltd

Foodservice Equipment Association

Fraser Technologies Limited.

Fuzhou city Gulou Zhongshuidaozheng trading Co.LTD

Glasgow Scientific Services

Global energy systems & technology

Guangzhou luoxin flourine Co.LTD

Guangzhou Tengan fluorine trade Co.LTD

Guangzhou Xingmeng fluorine trade Co.LTD

Haerbin daozheng flourine trading Co.LTD

HD Hyundai Construction Equipment

Honeywell Advanced Limited

Huayuefengxing(Guangzhou)trade Co.LTD

IDS Refrigeration Limited T/A Climalife

Jingji fluorine chemical (Guangzhou) Co.LTD

Khorgos DZDL Corporate Consulting Service Co.,LTD

Lancer UK

Lanzhou Zhongshui trading Co.LTD

LGL LENNOX BV

Loughborough University

MeridianXP Limited

Mexichem UK Limited

Mitsubishi Heavy Industries

National Refrigerants Ltd

Pitkin & Ruddock Ltd

Powermaster

Puyang city Daozheng trading Co.LTD

Qingdao zhongshuidaozheng trading Co.LTD

Quotient Sciences (Alnwick) Ltd

Rapiscan Systems Ltd

REACH24H Consulting Group

Scott-Drummond Ltd

Shen County Wenshui Trading Co.,Ltd.

Shenchuang Industrial Zone Co., Ltd

Shenxian Xisheng Corporate Consulting Center

Shenxian ZSZD Technology Innovation Development Center(LLP)

Shijiazhuang daozheng flourine trading Co.LTD

Shizuishan Daozheng trading Co.LTD

Solvay France

Taian city taian district Zhongshuidaozheng trading Co.LTD

TaiyuanDaozheng trading Co.LTD

Temperature Applied Sciences Ltd

The F-Gas Register

The Institute of the Motor Industry

The University of Plymouth

Thermofisher Scientific

Thermofrost Cryo Ltd

ThermOzone Ltd

THT Anshuo chemical technology Co., LTD

THT Jifeng chemical technology Co.,LTD

THT Jitai chemical technology Co.,LTD

THT Lekangan chemical technology Co., LTD

THT Ruidaan chemical technology Co., LTD

THT Taifu chemical technology Co.,LTD

THT Tengming chemical technology Co.,LTD

Tianjin Daoeryuan Chemical trading Co.LTD

Tianjin Daohe Chemical trading Co.LTD

Tianjin Daoyi Chemical Trading Co.LTD

Tianjin Daozheng Chemical trading Co.LTD

Tianjin dola fluorine trade Co.LTD

Tianjin Weitai trading Co.LTD

Tianjin Yutai trading Co.LTD

University of York

Vectura Group Limited

Veolia ES (UK) Ltd

WEIFANG Changwen Chemical Co.LTD

Weifang Tianyue Chemical Co.LTD

Wilhelmsen Ships Service UK Ltd

Wirtgen Limited

Xian Zhongshuidaozheng trading Co.LTD

Zhengzhou Daozheng trading Co.LTD

Zhongshui(Beijing) Chemical Co.LTD