EU F-Gas Regulation and its implications for refrigerated container importers

What are the implications of the EU F-Gas Regulation (Regulation (EU) 2024/573) specifically for importers of refrigerated containers and similar equipment?

1. Basics: What is the EU F-Gas Regulation?

The EU F-Gas Regulation (Regulation (EU) 2024/573) is a revised European Union regulation that has been in force since 11 March 2024 and replaces the older Regulation (EU) 2014/517. It serves to protect the climate by severely restricting the use of fluorinated greenhouse gases (F-gases) – in particular HFCs and other fluorinated gases – and reducing their emissions.

2. What does „F-gases” mean?

F-gases are synthetically produced fluorinated greenhouse gases containing fluorine, which are used, for example, as refrigerants in refrigeration systems, air conditioning systems, heat pumps and refrigerated containers.

Typical groups of F-gases are:

• HFCs (hydrofluorocarbons)
• PFCs (perfluorocarbons)
• SF₆ (sulphur hexafluoride)

They have a very high global warming potential (GWP) – in some cases, they are a thousand times more potent than CO₂ in terms of their impact on the climate. When they enter the atmosphere, they contribute significantly to climate change.

2.1. GWP limits and bans (new installations)

• From 1 January 2025: New, hermetically sealed (‘stand-alone’) refrigeration systems, which include most reefer units, will be subject to a GWP limit of < 150.
• Impact: This means the end of common high-GWP refrigerants such as R-404A (GWP 3922) and R-134a (GWP 1430) in new reefer containers.
• Alternatives: The transition to natural refrigerants such as R-744 (CO₂) or R-290 (propane) and other low-GWP HFO blends is being accelerated.

2.2. Service and maintenance ban, strict restrictions (from 2032)

• From 2030: A general ban on the use of newly produced F-gases with a GWP > 2,500 applies to the maintenance and servicing of refrigeration systems (including recycled gases).
• From 2032: For certain stationary applications, there will be a service ban on fresh goods (newly manufactured gases) with a GWP > 750. This could indirectly affect permanently installed reefer systems in warehouses.

2.3. Import/export restrictions (Kigali Agreement)

• From 12 March 2025, the export of equipment containing F-gases with a GWP of 1,000 or more to countries that have not ratified the Kigali Agreement will be prohibited.
• From 2028, trade in HFCs (in bulk or in equipment) with countries not covered by the protocol will be generally prohibited.

As a reference point, in 2024 the quota was 31%, and from 2025 it will have shrunk to the 2015 level of 24.5%.

3. Important changes & points in the regulation

Licence requirement for import & export

Anyone importing refrigerated containers or other equipment containing F-gas refrigerants into the EU has required an import licence since 2024, regardless of the quantity or weight of the F-gases. This requires registration on the European F-gas portal.

Relevance for importers:

When importing equipment containing F-gases (e.g. pre-filled refrigerated containers), the relevant permits must be applied for via this portal and customs declarations must contain the relevant information.

Phase-down and long-term ban

The EU is gradually reducing the amount of HFCs that may be placed on the market, with the aim of almost complete elimination by 2050. This also affects importers, as fewer HFC-containing equipment will be available and economically attractive.

Prohibitions on use and placing on the market

Prohibitions apply to certain classes of equipment with high GWP as soon as more climate-friendly alternatives become available. Requirements will increase over the next few years – e.g. for equipment with very high GWP refrigerants.

Documentation and reporting requirements

Anyone who imports refrigerated containers only temporarily into the EU must comply with reporting requirements – e.g. regarding F-gas content, GWP, origin, etc. – and correctly enter this information in the F-gas portal and, if necessary, in customs or safety reports.

4. Practical implications for refrigerated container importers

Increased administrative burden

• Registration on the F-gas portal: Mandatory for importers of equipment containing F-gases.
• Import licence: Without a valid licence, customs clearance and distribution are not legal.
• Documentation: Information on F-gas type, GWP, quantities and origin is required.

Strategic consequences and obligations for operators

Choice of refrigerants:
As appliances with high GWP are increasingly being banned or restricted, it makes sense for importers to:

• import containers with natural or low-GWP refrigerants (e.g. CO₂, ammonia, propane)
• use alternative technologies at an early stage
• Leak checks: The testing requirements are based on the CO₂ equivalent (GWP x quantity). The higher the GWP, the shorter the intervals
• Recording obligation: Operators of systems containing F-gases must keep detailed records.

Compliance & risk:

Failure to comply with the regulation can lead to delays at customs, fines or a ban on placing the product on the market if the registration on the F-gas portal or licensing is missing.

5. Summary – What importers need to bear in mind

• F-gas portal registration: Mandatory
• Import licence for F-gas equipment: Mandatory
• Customs declaration with correct information: Essential
• Phase-down & future bans: Long-term planning required
• Use of high-GWP refrigerants: is becoming increasingly restricted

Conclusion

The new EU F-Gas Regulation (EU) 2024/573 means the following for importers of refrigerated containers:

• Administrative obligations (portal, licence, documentation)
• Regulatory risks in the event of non-compliance
• Market shift towards climate-friendly refrigerants
• Long-term planning for new investments and product range strategy
• Higher costs for new investments

Officially, the EU F-Gas Regulation (currently: Regulation (EU) 2024/573) is being introduced purely for climate policy reasons – as importers, we ask ourselves: is this true, or is it another source of revenue for the EU?