Importers of products containing F gas: labels and record keeping
How to label equipment that contains fluorinated greenhouse gas (F gas) and records that you need to keep.
You must follow this guide if you import products to the EU that contain fluorinated greenhouse gases (F gases) regulated by the EU.
Label equipment
You must label any products you plan to import to the EU that contain EU regulated F gases. The label must state:
- that the equipment contains an F gas
- the industry name for the F gas, or the chemical name if there isn’t an accepted industry name
From 2017 the label on any product apart from insulating foam must also state the:
- mass of F gas in the equipment (in kg)
- carbon dioxide (CO2) equivalent mass of the F gas
- global warming potential of the F gas
Find the global warming potential of each F gas on the list of F gases regulated by the EU.
Find out how to use an F gas’ global warming potential to calculate the weight of the F gas in CO2 equivalent.
‘Hermetically sealed equipment’
If F gas is ‘hermetically sealed’ within a product, the label must also state that’s the case. F gas is hermetically sealed if both of the following apply:
- any part of the product that contains F gas is welded or brazed shut, or permanently sealed in another way
- the product has a tested leakage rate of less than 3 grams per year
A system that meets these 2 conditions is considered hermetically sealed even if it has capped valves or capped service ports to allow access for repairs and maintenance.
Product bans
The EU is banning the use of some F gases in the following types of product:
- refrigeration
- air conditioning
- fire protection
- aerosols
- insulating foam
Find out more about F gas product bans if you import any of these products.
EU phase down of HFCs
The EU is cutting the availability of hydrofluorocarbons (HFCs), which are a type of F gas, by 79% between 2015 and 2030.
Only companies with EU quotas will be able to supply HFCs to the EU market.
HFCs, particularly those with high global warming potentials, are likely to become more expensive.
The HFCs that are being phased down are listed with their global warming potentials in section 1 of the list of F gases regulated by the EU.
Find out more about the HFC phase down.
Secure HFCs from EU quotas
Products like air conditioners and refrigeration systems are often filled with HFCs when they’re manufactured. This is known as ‘pre-charging’.
From 1 January 2017 any HFCs pre-charged in the following equipment must be accounted for in the EU quota system, if the equipment’s going to be sold in the EU:
- refrigeration systems
- air conditioning and heat pump equipment
You can secure HFCs from the EU quota system by:
- applying for a quota yourself
- purchasing HFCs directly from a quota holder
- getting authorisation from an EU quota holder to use a specified amount of their quota
In the final case you’ll need to get a letter from the EU quota holder confirming they won’t make an agreed quantity of HFCs from their quota available to the EU market.
You can then buy that quantity of HFCs outside the quota system and use it in equipment you’re going to import to the EU.
Prove origin of HFCs
When you bring equipment into the EU, you’ll need to provide documents to prove that your HFCs come from a quota holder’s quota. You’ll need to write a ‘declaration of conformity’ to confirm this.
If your equipment contains HFCs that haven’t been sold in the EU before, you’ll also have to:
- keep the documentation and declaration of conformity for 5 years after you place the equipment on the market
- get an independent auditor to check the accuracy of the documents you used to prove where your HFCs come from
The auditor must check documents by 31 March of the year after you import the equipment.
The requirement for auditor checks doesn’t start until 2017. That means your first auditor checks must be complete by 31 March 2018.
The auditor must be qualified to check financial statements, or accredited under the EU Emissions Trading Directive.
Join the HFC Registry
You must join the EU HFC Registry if you import equipment into the EU that contains HFCs that haven’t been sold in the EU before.
The HFC Registry is part of the F gas portal on the European Commission website. You’ll need to register for an account to access the F gas portal if you haven’t already.
Report data to the EU
You must report data for any year in which you import or produce more than 500 tonnes carbon dioxide equivalent of the following gases:
- F gases regulated by the EU
- gases with record keeping requirements under the EU F gas regulation
That’s equal to 350 kg of HFC 134a or 125 kg of HFC 404A in a calendar year.
Find out how to calculate the weight of an F gas in carbon dioxide equivalent.
What you have to report
In any year that you meet the reporting threshold, you must report:
- any category of equipment you imported that contains gases you have to report on (eg hermetically sealed refrigeration systems, single split air conditioning systems etc)
- the number of units of each type of equipment you placed on the market
- the quantity of each of the gases that are part of the phase down that was contained in the equipment you imported
When you have to report
You must report the data by 31 March of the following year.
The first year for which you have to report data on imported products and equipment is 2014, so the first report is due by 31 March 2015.
How to submit reports
Submit reports through the F gas portal on the European Commission website.