Imports of RAC Equipment Pre-Charged with HFCs

Regulation (EU) No 517/2014 (‘the F-gas Regulation’) introduces a HFC phase-down and a quota system for producers and importers of bulk hydroflurocarbon gases (HFCs) transported in gas containers or gas bottles. Note that importers and EU manufacturers of equipment pre-charged with HFCs do not place bulk gases on the EU market. Therefore, they do not have an HFC quota. But they are affected by the phase-down nonetheless.

The aim of the HFC phase-down is to gradually reduce the use of HFCs which are potent greenhouse gases. If HFCs inside imported equipment could be imported without any restriction, it would not be possible to meet the environmental objective of reducing greenhouse gas emissions. However, the import of equipment pre-charged with HFCs has not been prohibited, it can still be carried out subject to certain conditions. Nevertheless, avoiding the import of HFC-charged RAC equipment, wherever possible, is the most straightforward option to comply with the HFC phase-down

From 1 January 2017, importers of refrigeration, air conditioning and heat pump (RAC) equipment pre-charged with HFCs need to ensure that the HFCs charged into the equipment are accounted for within the quota system when placing pre-charged equipment on the EU market (Article 14 of the F-gas Regulation). The term ‘equipment’ refers to both stationary and mobile equipment such as air-conditioning in vehicles, unless noted otherwise.

Ask yourself these questions to see if the Article 14 obligations concern your company:

1) Is your company the importer?

2) Is the equipment imported for free circulation in the EU?

3) Does the imported equipment contain gases listed in Annex I and/or Annex II of the F-gas Regulation?

The equipment is considered to contain F-gases even if those gases are only found in specific parts of the equipment (e.g. in insulation foams of appliances). However, for F-gas Regulation Article 14 compliance, only the HFCs charged into the refrigeration circuits are relevant.  

If you answer ‘yes’ to all three questions, your company will have certain obligations under the F-gas Regulation. 

The main obligations for importers of equipment containing fluorinated greenhouse gases are:

  • Importers of stationary and mobile refrigeration, air conditioning and heat pumps (RAC) must make sure that all hydrofluorocarbons (HFCs) pre-charged into equipment is accounted for under the HFC quota system. Importers will also need to register in the HFC Registry and draw up one or more declaration(s) of conformity at the time of import (F-gas Regulation Articles 14 and 17) and ensure that compliance is fully documented and verified.
  • Importers of any products or equipment containing gases listed in Annex I and/or Annex II of the F-gas Regulation must report yearly on imports by 31 March of the year following the import (F-gas Regulation Article 19).
  • Restrictions on placing on the market  apply to certain types of equipment containing Annex I gases. The specific conditions are listed in Annex III of the F-gas Regulation (F-gas Regulation Article 11).
  • Equipment containing Annex I gases needs to be labelled (F-gas Regulation Article 12).

 

Download a copy of the European Commission guidance document relating to the import of pre-charged equipment at this link.

Download a January 2017 presentation by the Department of Communications, Climate Action and Environment relating to the import of pre-charged equipment at this link.