Overview#
The F-Gas Regulation tackles a group of powerful climate pollutants. Fluorinated greenhouse gases trap far more heat than carbon dioxide for each tonne emitted, so even small leaks matter. The law squeezes them out of the market on a falling schedule.
The biggest target is the family of HFCs, the hydrofluorocarbons that replaced ozone-damaging gases in fridges, air conditioners and heat pumps. They are kind to the ozone layer but strong warming agents, which is why the EU now phases them down.
How it works#
Two mechanisms do most of the work.
The phase-down: a quota that reaches zero#
Article 16 allows HFCs to be placed on the market only within quota allocated by the Commission to producers and importers, and Annex VII sets the total for each period. The 2015 base value was 176 700 479 tonnes of CO2 equivalent. Because the quota is counted in CO2 equivalent rather than in kilograms, a producer can stretch the same quota further by selling gases with a lower GWP, which is exactly the incentive the regulation wants.
The quota does not bite everywhere. Article 16(2) leaves out HFCs imported for destruction, used as feedstock, supplied for export in bulk, supplied for military equipment, and supplied for semiconductor etching and chamber cleaning. Pre-charged equipment is inside it: Article 19 says refrigeration and air-conditioning equipment, heat pumps and metered dose inhalers pre-charged with Annex I Section 1 HFCs may not be placed on the market unless that gas is accounted for within the quota system, which is why an importer of finished equipment cannot ignore this chapter. And Article 11(8) requires anyone placing bulk F-gases on the market to be established in the Union or to have appointed an only representative established there.
Product bans: Annex IV#
Article 11(1) prohibits placing on the market the products and equipment listed in Annex IV from the date the annex gives for each, differentiated where applicable by the type or GWP of the gas contained. Military equipment is exempt. Three general rules ride on top of the list:
- Repair parts stay available. Parts needed to repair or service existing equipment may still be placed on the market, provided the repair does not increase the capacity, increase the gas charge, or switch to a gas with a higher GWP.
- Sell-through needs proof after a year. Equipment lawfully placed on the market before its ban date may still be supplied onwards, but from one year after that date only with evidence that it was placed on the market lawfully before the ban.
- A lifecycle case can lift the ban. Equipment shown under ecodesign rules to have lower lifecycle CO2-equivalent emissions than equivalent compliant equipment is excluded, and Article 11(5) lets the Commission grant four-year exemptions where no alternative exists or its cost would be disproportionate.
The list itself runs to 21 points. The dates below are the ones still ahead that a maker or importer of equipment is most likely to meet. Almost every entry carries the qualifier "except if required to meet safety requirements at the site of operation", and several of the air-conditioning entries add that where safety rules do not allow a GWP below 150, the limit is 750 instead. Read the annex entry before relying on a date.
Several entries are older than this regulation and simply carried over, such as the bans on F-gases in footwear (2006), tyres, domestic windows and non-refillable containers (2007) and one-component foams with a GWP of 150 or more (2008). Article 11(3) goes further than the container entry: non-refillable containers for Annex I and Annex II Section 1 gases may not be imported, supplied, used or exported at all, whether empty or filled, outside laboratory and analytical use.
Switchgear: a ban on putting into operation#
The Annex IV bans bite when a product is first made available on the EU market. They fall on the manufacturer or importer, and the customer downstream can rely on the date the unit was first supplied.
For electrical switchgear the regulation bans putting into operation instead. It is the operator's act that is prohibited, so a panel lawfully sold can still be one the customer may not energise. The operator must document any derogation for five years and notify the competent authority when relying on one.
Switchgear using F-gas, typically sulphur hexafluoride (SF6), as its insulating or breaking medium may not be put into operation:
The derogations matter in practice. Switchgear with a medium below a GWP of 1 000 may still be put into operation where a procurement procedure drew no bids, or bids from only one manufacturer, for F-gas-free equipment (or, for the high-voltage classes, for equipment with a GWP below 1) during the first two years after the date, and after those two years only where no bid for such equipment was received at all. Equipment with a GWP of 1 000 or more is allowed where no bid at all came in below 1 000. An order placed before 11 March 2024 is outside the ban, as are extension devices that would otherwise force replacement of an entire existing installation, and moving an existing installation to another site in the Union does not count as putting into operation.
Labelling: what the product must say#
Article 12 applies since 1 January 2025 (the old Article 12 of Regulation 517/2014 ran until the end of 2024) and it is the part of this regulation that an equipment maker touches on every unit.
Refrigeration equipment, air-conditioning equipment, heat pumps, fire protection equipment, electrical switchgear, aerosol dispensers containing F-gases including metered dose inhalers, all F-gas containers, F-gas-based solvents and organic Rankine cycles may only be placed on the market, supplied or made available if labelled.
Retrofitted equipment whose gas has been changed must be relabelled. Foams and pre-blended polyols containing Annex I or II gases must name the gas and state that they contain F-gas, and foam panels and laminated boards must carry that statement indelibly on the board itself. Containers of reclaimed or recycled gas must say so, and reclaimed gas must carry the batch number and the name and address of the reclamation facility.
Servicing bans and the leak-check threshold#
Two more rules reach equipment that is already installed. Article 13 prohibits using F-gases with a GWP of 2 500 or more to maintain or service any refrigeration equipment from 1 January 2025 and air-conditioning equipment and heat pumps from 1 January 2026, and gases with a GWP of 750 or more for stationary refrigeration equipment other than chillers from 1 January 2032, with carve-outs for reclaimed and recycled gas that run to 2030 and 2032 respectively for the first two. Article 5 requires leak checks on equipment holding 5 tonnes of CO2 equivalent or more of Annex I gases, or 1 kg or more of Annex II Section 1 gases, with exemptions for small hermetically sealed equipment that is labelled as such.
Why phase down rather than ban outright#
Many HFCs do useful work and safe substitutes are not ready for every use at once. The quota lets the market adapt. As the cap tightens, the most warming gases become scarce and expensive, which pushes industry toward lower-impact refrigerants and natural alternatives.
This is a different problem from ozone depletion, handled by the Ozone Regulation. Some fluorinated compounds also fall under the wider concern about PFAS, since certain F-gases are themselves per- and polyfluorinated substances. And the lifecycle escape hatch in Article 11(2) ties the regulation to ecodesign requirements, which the ESPR is now extending to more product groups.