Hangrui Holdings A chemicals trading group — refrigerants, chloromethanes, intermediates & specialty gases

Supplying R410A and R134a into the EU: What the Supplier Does, and What Stays With the Buyer

· HANGRUI HOLDINGS LIMITED

The short answer: we can supply R410A and R134a into the European Union where the buyer holds the EU F-gas import quota and the REACH registration (or an equivalent compliant arrangement). Those two are the importer’s; the goods, the grade, the packing and the documents are ours. This page sets out exactly where the line runs — because a border stop is almost never about the refrigerant, it is about which side of that line a duty was assumed to be on.

QuestionWhose responsibilityWhat it means in practice
EU F-gas quota and licenceBuyer / importer of recordThe quota and the licence attach to the undertaking placing the HFCs on the market under Regulation (EU) 2024/573; the volume is placed against the buyer’s quota (own quota or an authorisation accepted in the F-gas Portal)
REACH registrationBuyer / importer of record (or an only representative appointed by the supplier)Registration is the importer’s obligation; we supply the product identity, composition and SDS data it relies on
Product, grade and specificationUsThe grade supplied, the contractual parameters and the COA that states them
Packing, cylinders and marksUsCylinder data for the specific units, UN marks, water capacity and tare, packing list net weight (net = gross − tare)
Transport documentsUsTransport document, packing certificate and stowage/segregation for the actual load
Customs and import declarationBuyer or their agentThe import entry, the F-gas position and any duty or VAT treatment

Where the quota actually sits

Under the F-gas framework the quota is not a property of the goods; it is attached to the undertaking that places them on the EU market. Since 11 March 2024 a licence is required for importing the HFCs listed in the Regulation and for products containing them, and the volume moves against quota in the Commission’s F-gas Portal — either the importer’s own quota or an authorisation accepted by it.

⇒ Consequence for an order: the question is not “does the supplier have quota”, it is “whose quota is this volume placed against, and is that undertaking the importer of record”. We ask for that answer in writing before the shipment is fixed (the licence, quota and packing checks in detail).

What travels with the goods

A refrigerant cylinder shipment arrives with four document sets, and each has a job at the border:

DocumentWhat it statesWho produces it
Transport documentUN number and class per cylinder group — R134a: UN 3159 (Class 2.2); R410A: UN 3163, liquefied gas n.o.s. (Class 2.2)Us
Packing certificateStowage and segregation for the actual combinationUs
Packing listNet weight per unit, consistent with cylinder capacity and densityUs
COA + SDSThe grade as shipped, and its hazards and handlingUs

The F-gas licence, the quota reference and the REACH registration sit in the same shipment file but belong to the importer — they are the buyer’s documents, not ours, and we do not sign them (document consistency across a multi-entity chain).

Why the condition is stated and not glossed over

Two failure modes exist, and they are opposites:

  1. A supplier who implies they hold the quota. The shipment is stopped, and the importer discovers the duty was never on the supplier’s side.
  2. A buyer who assumes the condition is a formality. Quota is a quantity with a cap; a purchase order placed late in a year can meet an exhausted position.

Writing the split down on the quotation — who is importer of record, whose quota the volume is against, who registers REACH — costs one paragraph and removes both.

FAQ

Can you supply R410A or R134a into the EU? Yes — where the buyer holds the EU F-gas import quota and the product’s REACH registration (or an equivalent compliant arrangement). Those two sit with the importer of record; the goods, the grade, the packing and the documents sit with us.

Do you hold the F-gas quota yourself? No. Under Regulation (EU) 2024/573 the quota and the licence attach to the undertaking that places the HFCs on the EU market — the importer of record. We supply the goods and the documentation; the quota basis for that volume is the buyer’s, and we ask for it before the shipment is fixed.

Who is responsible for REACH? The REACH registration obligation sits with the EU importer, or with an only representative appointed by a non-EU supplier. Where the buyer is the importer, we provide the product identity, composition and SDS data the registration relies on.

What documents travel with the goods? The transport document and packing certificate (UN number and class per cylinder group), the packing list with net weight per unit (net = gross − tare), the COA for the grade, and the SDS for the product as shipped.

Why write the split down before the order? Because quota and REACH are licence-side facts that belong to the importer, while the goods and their documentation are ours — writing it down stops a shipment being packed and then stopped on a duty that was never the supplier’s to hold.

What we can provide

For shipments of R410A and R134a into the EU, where the buyer is the importer of record with the F-gas quota and REACH registration, the group’s operating companies can supply the goods with the documentation that has to agree with itself: UN number and class per cylinder group, cylinder data for the specific units, packing list net weight, COA for the grade, and SDS for the product as shipped — plus the supplier-side statements the importer’s file needs.

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, the volume, and who the importer of record will be.

Sources

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 supply statement above is conditional on the buyer being the importer of record holding the F-gas quota and REACH registration; the licensing position for any specific shipment remains a matter for the parties and their advisers.

采购实操 · Hangrui Holdings can provide.
Need current specs, quota status, or a mixed-load quote for What the Supplier Does, and What Stays With the Buyer? Contact tom@hangr.hk with your spec & destination port.