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.
| Question | Whose responsibility | What it means in practice |
|---|---|---|
| EU F-gas quota and licence | Buyer / importer of record | The 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 registration | Buyer / 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 specification | Us | The grade supplied, the contractual parameters and the COA that states them |
| Packing, cylinders and marks | Us | Cylinder data for the specific units, UN marks, water capacity and tare, packing list net weight (net = gross − tare) |
| Transport documents | Us | Transport document, packing certificate and stowage/segregation for the actual load |
| Customs and import declaration | Buyer or their agent | The 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:
| Document | What it states | Who produces it |
|---|---|---|
| Transport document | UN 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 certificate | Stowage and segregation for the actual combination | Us |
| Packing list | Net weight per unit, consistent with cylinder capacity and density | Us |
| COA + SDS | The grade as shipped, and its hazards and handling | Us |
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:
- 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.
- 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.
Related
- Importing R410A and R134a into the EU: the F-gas licence, quota and packing checks — the checks the importer runs, in detail.
- Sourcing chemicals from China: six checks before the first order — the buyer-side verification list.
- Document Consistency Across a Multi-Entity Supply Chain — the four names that must match across contract, goods and invoice.
Sources
- Regulation (EU) 2024/573 on fluorinated greenhouse gases — licence requirement and quota system for placing HFCs on the EU market; in force 11 March 2024 (EUR-Lex): https://eur-lex.europa.eu/eli/reg/2024/573/oj/eng
- EU rules on fluorinated greenhouse gases — licensing and quota overview (European Commission, Climate Action): https://climate.ec.europa.eu/eu-action/fluorinated-greenhouse-gases/f-gas-legislation_en
- Guidelines on how to authorise quota in the F-gas Portal — Article 21(2)–(4): eligibility, acceptance, delegation (European Commission, PDF): https://climate.ec.europa.eu/document/download/2a97e45c-4812-4af2-b777-ed52c5c05235_en?filename=policy_f-gas_guidance_providing_authorization_en.pdf
- REACH — registration obligations and the role of the only representative (European Chemicals Agency): https://echa.europa.eu/regulations/reach/registration
- R410A safety data sheet — UN 3163, liquefied gas n.o.s., 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
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.
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.