Customs: movement of goods subject to fluorinated gas regulations
Under the Paris Agreement and its greenhouse gas emission reduction target of at least 55% by 2030, the European Commission has initiated a phase-out of fluorinated gases, or hydrofluorocarbons (HFCs). This approach is based on a new regulation, which came into force in 2024, which regulates the flows of goods containing these substances. Prohibitions, registration requirements for products and businesses on the F-Gas portal, as well as import quotas are the main levers of this regulation.
HFCs (hydrofluorocarbons) are fluorinated gases used in refrigeration, air conditioning, heat pumps, certain aerosols and various industrial uses. If they do not destroy the ozone layer, they have a strong global warming potential, which justifies their strict framework at European level.
In the F-Gas Regulation revised in 2024, HFCs are the main category of gases concerned in terms of quotas and restrictions. They are thus at the heart of the EU's gradual reduction scheme.
Each year, the European Union sets a maximum volume of HFCs that can be placed on the market. These volumes are distributed among authorised operators according to a quota system. In practice, this means that an importer or economic actor cannot freely introduce HFCs in Europe: it must have a quota or be included in a scheme authorized by the regulations depending on the nature of the goods (through annexes in the regulations).
Regulation (EU) 2024/573 provides that, in the case of goods moving under the transit suspensive procedure, the EDR issuing the transit document (T1) is registered on F-Gas, which in fact is not the practice since, as service providers, EDRs are not « market producers » goods. In this context, some EDRs may refuse to take over goods at EU borders;
In 2025, the European Parliament launched several plans to amend the new regulations. In this way, in the work to simplify the OMNIBUS package (Measures IV), proposals have been made to reduce record-keeping obligations with a rationalisation of registration requirements in the European F‐Gas portal. This simplification should allow service providers to be released from certain obligations, while ensuring that their customers remain in compliance for import.