Importing R410A and R134a into the EU: The F-gas Licence, Quota and Packing Checks a Buyer Should Make
· HANGRUI HOLDINGS LIMITED
The short answer: importing R410A or R134a into the EU is not a price question first — it is a licence-and-quota question. Since 11 March 2024, a licence is required to import the HFCs listed in Annexes I–III of Regulation (EU) 2024/573 and products containing them, whatever the quantity; the quota behind the volume moves through the Commission’s F-gas Portal. A supplier who cannot answer the four checks below in writing is a schedule risk, not a bargain.
Check 1 — Licence and F-gas Portal registration
| What to ask | Why it decides the shipment |
|---|---|
| Do you hold an F-gas licence for import? | The licence is issued by the Commission and requires registration in the F-gas Portal — it is the entry condition under the Regulation, not a formality |
| Which undertaking is the importer of record? | Quota sits with a registered undertaking; the name on the documents must be that undertaking, not a sales agent |
| Is the registration valid for this year? | Registration and reporting obligations under the Regulation are annual |
The Regulation repealed Regulation (EU) No 517/2014 and entered into force on 11 March 2024; the rules on labelling, product information and quota allocations have applied since 1 January 2025. A supplier quoting “517/2014” as the governing instrument is working from a superseded text.
Check 2 — Quota: who holds it, and how it can move
Quota is not transferable by email. It is managed in the F-gas Portal, and the Regulation distinguishes several ways a volume can be legitimately placed on the market:
| Route | Who can do it | Condition that matters commercially |
|---|---|---|
| Own quota (reference value) | Producers or importers with a reference value under Article 17(1) | The volume is theirs to place on the market |
| Authorisation to use quota | Only those with a reference value may authorise all or part of their quota | Must be initiated in the Portal and is valid only once the receiving undertaking accepts it — an unaccepted authorisation is automatically cancelled after 30 days |
| Delegation of an authorisation | The beneficiary may delegate once, to another undertaking registered in the Portal | A delegated authorisation cannot be delegated a second time |
| Transfers between undertakings | Undertakings with a reference value, including via an only representative in the Union | Corrections to Portal data must be reported to the Commission by 31 March of the following year |
⇒ The commercial consequence: when a buyer asks “can you supply 20 t into the EU this quarter?”, the real question is whose quota, registered to whom, accepted when. Ask for the Portal position in writing before the order, not after the vessel sails.
Check 3 — R410A and R134a are not one line item
| Product | UN number | Class | Note |
|---|---|---|---|
| R134a | UN 3159 | 2.2 (non-flammable, non-toxic gas) | Single-substance entry, 1,1,1,2-tetrafluoroethane |
| R410A | UN 3163 (LIQUEFIED GAS, N.O.S.) | 2.2 | Blend of difluoromethane (R32) and pentafluoroethane (R125) — no dedicated UN entry |
| R32 | UN 3252 | 2.1 (flammable gas) | Handled differently again, and an A2L charge-limit question at the equipment end |
Under the quota system the quantity that counts is calculated from the global warming potential of the substance, not its mass alone — so the figure the Regulation attaches to a product is the one to use when quoting a quota-facing volume, rather than a GWP from an older assessment report.
Check 4 — The document set has to agree with the licence
Four things have to line up, and a defect in any one of them surfaces at the border rather than at the quotation stage:
- Licence and Portal registration of the importer of record.
- Quota basis for the volume — own quota, authorisation accepted in the Portal, or a delegation.
- UN number and class per cylinder group on the transport document and marks (UN 3159 for R134a, UN 3163 for R410A).
- Packing list net weight consistent with format and density — the same net = gross − tare check that applies to any cylinder shipment.
The surrounding documentation is the ordinary dangerous-goods set (the document set for a shipment), with the F-gas position added to it.
FAQ
Can R410A or R134a be imported into the EU without an F-gas licence? No. Since 11 March 2024 a licence is required for the import and export of the substances listed in Annexes I–III of Regulation (EU) 2024/573, and for products and equipment containing them — regardless of quantity. The licence is issued by the European Commission and requires registration in the F-gas Portal.
Who is allowed to authorise HFC quota to another company? Only producers or importers that hold a reference value under Article 17(1) of Regulation (EU) 2024/573 may authorise all or part of their quota. The authorisation is made in the F-gas Portal and only becomes valid when the receiving undertaking accepts it; if it is not accepted within 30 days the system cancels it automatically.
How is R410A classified compared with R134a? They are different entries. R134a travels as UN 3159, Class 2.2 (non-flammable, non-toxic gas). R410A is a blend and travels as UN 3163, LIQUEFIED GAS, N.O.S., also Class 2.2. A document set that treats both as one line item is defective before it reaches customs.
Does the EU quota system apply to reclaimed refrigerant? Recycled and reclaimed HFCs are not subject to quota — the quota system covers HFCs placed on the market. That is why a documented reclamation chain can matter commercially in a phase-down market.
What has to be in the document set for an F-gas shipment? Four things have to agree: the licence and Portal registration of the importer, the quota basis for that volume, the UN number and class per cylinder group, and the packing list net weight. Any mismatch is a customs question, not a paperwork delay.
What we can provide
When you buy from one of the group’s operating companies, we can put the compliance position on the record before the goods move: which undertaking is the importer of record, the UN number and class per cylinder group, the packing list net weight, and — where the destination is in the EU — the F-gas position that the import depends on.
On supplying into the EU: the group’s operating companies can supply R410A and R134a into the European Union where the buyer holds the F-gas import quota and the REACH registration — those two sit with the importer of record; the goods, the grade, the packing and the documents sit with us. The split is set out in full on what the supplier does and what stays with the buyer. We do not claim to hold EU quota or to be the importer of record.
Who contracts and ships: every shipment is contracted, invoiced and shipped by the group operating company named on the quotation and on the documents for that shipment. This page is the group’s technical reference material; it does not itself contract, invoice, or act as shipper of record.
Contact us with: the product, the destination market, and the volume you intend to place.
Related
- Supplying R410A and R134a into the EU: what the supplier does, what stays with the buyer — the responsibility split on one page.
- Document Consistency Across a Multi-Entity Supply Chain — the four names that must match when the contract, the goods and the invoice sit in different entities.
- Incoterms 2020 and Dangerous Goods — where risk, cost and the declaration duty actually transfer.
Sources
- Regulation (EU) 2024/573 on fluorinated greenhouse gases — adopted 7 February 2024, entered into force 11 March 2024, repealing Regulation (EU) No 517/2014; labelling/product information and quota allocations apply from 1 January 2025 (EUR-Lex): https://eur-lex.europa.eu/eli/reg/2024/573/oj/eng
- Guidelines on how to authorise quota in the F-gas Portal — Article 21(2)–(4): eligibility limited to holders of a reference value under Article 17(1); acceptance required; automatic cancellation after 30 days; delegation permitted once (European Commission, Climate Action, PDF): https://climate.ec.europa.eu/document/download/2a97e45c-4812-4af2-b777-ed52c5c05235_en?filename=policy_f-gas_guidance_providing_authorization_en.pdf
- EU rules on fluorinated greenhouse gases — licence requirement for import/export covering Annexes I–III substances and products containing them (European Commission, Climate Action): https://climate.ec.europa.eu/eu-action/fluorinated-greenhouse-gases/f-gas-legislation_en
- F-gas Regulation 2024/573 — licensing, quota thresholds and reclamation (German Environment Agency, Umweltbundesamt): https://www.umweltbundesamt.de/en/topics/climate-energy/fluorinated-greenhouse-gases-fully-halogenated-cfcs/statutes-regulations/eu-regulation-concerning-fluorinated-greenhouse
- R410A safety data sheet — UN 3163, liquefied gas n.o.s. (difluoromethane; pentafluoroethane), class 2.2 (Messer Canada SDS, PDF): https://www.master.ca/media/akeneo_connector/asset_files/S/D/SDS_AZ20_R410A_UN3163__MESSER__en_CA_5f3b.pdf
- Refrigerant R134a safety data sheet — UN 3159, class 2.2 (Linde/AFROX SDS, PDF): https://static.prd.echannel.linde.com/wcsstore/ZA_AFROX_Industrial_Ntl_Store/Attachment/Corporate/AFX-SDS-0060_v01_Refrigerant_R134a_Safety_Data_Sheet%28003%29%282%29tcm266-6472.pdf
- Difluoromethane (R32) — UN 3252, division 2.1 flammable gas (PubChem CID 6345 / 49 CFR 172.101): https://pubchem.ncbi.nlm.nih.gov/compound/Difluoromethane
Prepared by Hangrui Holdings Limited (Hong Kong) — the group holding company. Shipments are contracted, invoiced and shipped by the group’s operating companies: HARMONY TECHNOLOGY (ZHEJIANG) CO., LTD. (trading), QUZHOU HUAFU NEW REFRIGERATION MATERIAL CO., LTD. (storage and cylinder filling), and RIBOLUO CHEMICALS (ZHEJIANG) CO., LTD. (distribution). This page is group reference material — the holding company does not contract, invoice or ship. The above references public regulation and guidance; the F-gas position for any specific shipment remains a matter for the importer of record and its advisers, and applicable law.
Need current specs, quota status, or a mixed-load quote for The F-gas Licence, Quota and Packing Checks a Buyer Should Make? Contact tom@hangr.hk with your spec & destination port.