F-gas audit for importers of equipment containing fluorinated greenhouse gases
F-gases, which include fluorinated greenhouse gases such as HFCs, PFCs and similar substances, are commonly used in air-conditioning equipment, heat pumps and related devices. As they significantly contribute to global warming, the EU is gradually tightening regulations with the aim of reducing their use. In this context, Regulation (EU) 2024/573 has been adopted, introducing amended obligations for manufacturers and importers.
Import rules
The import of equipment containing F-gases is subject to European legislation. A specific part of the Regulation sets out reporting and mandatory documentation requirements, including registration, the declaration of conformity when placing equipment containing F-gases on the market, and the independent verification of the data related to such equipment as well as the processes used to record it.
As part of the phase‑down of fluorinated hydrocarbons, producers and importers are allocated quotas. The purpose of these quotas is to ensure that the overall permitted quantity of fluorinated hydrocarbons placed on the EU market is not exceeded.
Quotas, authorisations and declaration of conformity
Quota amounts are allocated to producers and importers of bulk F‑gas. Importers of equipment already containing F‑gas must hold an authorisation, an agreement with the quota holder transferring a portion of their quota to the importer. In order to be valid, this authorisation must be registered in the HFC Registry.
The importer prepares a declaration of conformity confirming that they hold the necessary authorisations and quota for the equipment they import.
Why is F-gas audit necessary?
The importer must maintain records of the imported equipment, including the model, number of units, and the amount of fluorinated hydrocarbons expressed in CO₂ equivalent. These data must be entered into the EU F‑gas portal by 31 March for the previous reporting period. If the verification threshold is exceeded, the accuracy of the documentation and the declaration of conformity for the previous year must be confirmed by an independent auditor registered on the F‑gas portal.
According to the Regulation, there are two types of verification:
- verification for bulk F‑gases
- verification for equipment/products
The Regulation sets out the following thresholds and deadlines:
- If an importer has placed on the market pre‑charged equipment containing 1,000 t CO₂ equivalent of F‑gas that had not previously been placed on the market, the auditor must submit a verification report to the European Commission through the F‑gas portal/BDR.
- Verification is mandatory above 10 t CO₂ equivalent of F‑gas contained in the equipment.
- The deadline for submitting the verification is 30 April.
The verification includes confirming the completeness and accuracy of the report, the declaration of conformity, the procurement processes, and the manner in which the F‑gas contained in the equipment is incorporated into the quota system.
Conclusion
Importers placing pre‑charged equipment containing fluorinated hydrocarbons on the market should check in due time whether they exceed the thresholds set by the Regulation and ensure that an auditor is engaged on time to carry out the verification.
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