China's 2026 HFC Quota Allocation: What the MEE Notice Means for Refrigerant Buyers

Tue, 15 Sep 2026 · regulatory update · HANGRUI HOLDINGS LIMITED

The short answer: China’s 2026 HFC quotas are allocated. The Ministry of Ecology and Environment (MEE) issued 797,845 tonnes of HFC production quota across 34 companies and 5,992,594 tCO2e of import quota across 36 companies, while the national ceiling stayed frozen at the Kigali Amendment baseline. The practical consequence for buyers is simple: quota belongs to named companies and specific species — so verify the quota behind an offer, not just the price.

What was published, and when

Two documents set the 2026 picture. Both are public:

The allocation notice covers 34 companies for HFC production and domestic-use quota, and 36 companies for HFC import quota. The attached tables are the authoritative record of who holds what.

The 2026 numbers

Two notes on how to read this. First, the ceiling is set in CO2-equivalent tonnes, while production quota is allocated in physical tonnes by species — a bulky high-GWP gas consumes far more of the cap than the same weight of a lower-GWP one. Second, the allocation tables list individual companies per species, which is exactly why a quota check is an entity check.

Why the total does not grow

China’s obligation under the Kigali Amendment is a freeze, not yet a cut. According to MEE’s own drafting note for the 2027 scheme, the schedule for major developing countries is: freeze production and use at baseline level in 2024, then −10% in 2029, −30% in 2035, −50% in 2040 and −80% in 2045 (MEE, 2027 scheme drafting note).

MEE states that the 2024, 2025 and 2026 allocations have kept production and domestic use at the baseline, so 2026 is by design a flat year. The first real squeeze is 2029 — which is the year any multi-year supply agreement should already be priced for.

Where quota was added in 2026

The 2026 scheme keeps continuity and only responds to two specific industrial needs (MEE scheme, 24 Oct 2025):

• HFC-245fa: +3,000 tonnes of production quota (and +3,000 t domestic-use), to support the replacement of HCFC-141b as that substance exits polyurethane foam.
• HFC-41: +50 tonnes, to serve semiconductor demand for electronic gases.

Both additions are described as annual allocations valid only for 2026. Everything else carries over from the 2025 allocation as adjusted.

Enforcement tightened during 2026

On 9 February 2026 MEE published a notice strengthening supervision of ODS and HFC management, including automatic monitoring and data links for chloromethane units producing CTC by-product above set thresholds, and a named enforcement list: producing or selling without a quota licence or beyond the licensed volume, selling to buyers that do not qualify, failing to keep records or filing false data (MEE notice, 9 Feb 2026).

The takeaway is not that quota is scarce in 2026 — it is that quota is a licence, and licences are checked.

What to verify before you order

1. Which entity holds the quota. Quota sits with the named company in the allocation table, not with the brand or the trading channel.
2. Which species, and how much. Coverage is species-by-species; a quota licence for one HFC says nothing about another.
3. That the contracting entity and the documents match. The supplier on the contract, the entity on the invoice and the quota holder should line up. A COA issued by a different legal person than the one you are paying is a question worth asking early.
4. The date. Annual quota is annual. A licence for the current year does not cover shipments in the next.
5. The long contract. If you buy on a multi-year basis, model the 2029 step now rather than discovering it in a price negotiation.

Trading suppliers are a normal and useful part of this chain — small lots, mixed loads, several species on one shipment — but the quota check does not disappear because the supplier is a trader. It just moves one step up the chain.

Sources

• MEE, 《2026年度氢氟碳化物配额总量设定与分配方案》(24 Oct 2025) — mee.gov.cn and scheme PDF
• MEE, 《关于核发2026年度消耗臭氧层物质和氢氟碳化物生产、使用和进口配额的通知》(16 Dec 2025) — notice and allocation tables PDF
• MEE, 《2027年度氢氟碳化物配额总量设定与分配方案（征求意见稿）》编制说明 (Aug 2026) — PDF
• MEE, 《关于进一步加强消耗臭氧层物质和氢氟碳化物管理的通知》(9 Feb 2026) — notice

For general information only — not legal or regulatory advice. Quota, F-gas and dangerous-goods rules vary by jurisdiction and change; verify current obligations with qualified advisers before ordering.