Importing F-gas and ODS to the UK – obligations for importers of air conditioners and refrigeration equipment

Importing air conditioners, refrigeration units, heat pumps, and other equipment containing fluorinated greenhouse gases (F-gases) or ozone-depleting substances (ODS) into the United Kingdom is subject to some of the most complex environmental regulations in international trade. After Brexit, the UK built its own independent F-gas control system which — although derived from EU Regulation 517/2014, which in the EU was repealed and replaced from 11 March 2024 by Regulation (EU) 2024/573 — differs in key respects regarding the quota system, importer registration, and reporting obligations. A Polish company exporting air conditioners or refrigeration equipment to the UK, or importing them into the EU via the UK, must understand both regimes. Getting the rules wrong risks detained goods and sanctions on both sides of the border.

What are F-gases and why are they regulated?

F-gases (fluorinated greenhouse gases) are a family of synthetic gases used primarily as refrigerants, insulating foams, and dielectric gases. The main groups are:

Group	Examples	Application
HFC (Hydrofluorocarbons)	R-134a, R-410A, R-407C, R-32	Air conditioners, refrigerators, heat pumps
PFC (Perfluorocarbons)	CF4, C2F6	Electronics, industrial applications
SF6 (Sulphur hexafluoride)	SF6	High-voltage electrical switchgear

The reason for regulation: F-gases have an extremely high Global Warming Potential (GWP). For example: - R-410A: GWP = 2,088 (over 2,000 times more warming than CO2) - SF6: GWP = 23,900

ODS (Ozone Depleting Substances) are older substances — mainly HCFCs and CFCs — that destroy the ozone layer. The most relevant for importers is R-22 (HCFC-22), used in older air conditioners and refrigeration units.

UK F-Gas Regulation 2015 – the legal basis

After Brexit the UK retained The Fluorinated Greenhouse Gases Regulations 2015 (SI 2015/310) with post-Brexit amendments. The regulation is administered by the Environment Agency (EA) in England, SEPA in Scotland, and Natural Resources Wales in Wales.

Key differences: UK vs EU F-Gas after Brexit

Aspect	UK F-Gas	EU F-Gas (2024/573)
Regulator	Environment Agency (EA)	European Commission (F-gas Portal) and national authorities
Quota system	UK HFC Quota (separate from EU)	EU HFC Quota
Registration	UK F-Gas Registry (EA)	EU F-Gas Portal
Reporting	Annual reports to EA	Annual reports to the Commission via the F-gas Portal
GWP thresholds for air conditioners	Similar to EU, with exceptions	Defined in Annex IV
Phase-down schedule	UK-specific (diverging from EU since 2024)	EU phase-down

Key Brexit consequence: A company that holds an HFC quota in the EU system does not automatically have a quota for importing into the UK. A separate quota application must be submitted to the Environment Agency.

UK HFC Quota System – how does it work?

A quota is a quantitative authorisation to place on the UK market a specified amount of HFC expressed in tonnes of CO2 equivalent (CO2e). Amount of CO2e = mass of gas (kg) × GWP.

Example: Importing 100 kg of R-410A: - GWP of R-410A = 2,088 - CO2e = 100 kg × 2,088 = 208,800 kg CO2e = 208.8 tonnes CO2e

An importer must hold sufficient quota in their UK F-Gas Registry account before placing HFC on the UK market. Quotas are allocated by the Environment Agency — to incumbent quota holders by the end of December each year, based on market share, and to new entrants on application between 30 June and 31 August. An importer of equipment pre-charged with HFCs does not apply for quota; it obtains an authorisation from a quota holder.

How to obtain an HFC quota in the UK

1. Register with the UK F-Gas Registry – an online system managed by the EA. Registration is free of charge.
2. Apply for a quota – incumbent quota holders (placed HFCs on the GB market between 2015 and 2022) receive quota based on market share; new entrants apply each year in the 30 June – 31 August window.
3. Transfer and authorise quota – a quota holder can transfer quota to another producer or importer (new entrants cannot) or authorise an equipment importer to use its quota. GOV.UK guidance does not provide for quota auctions.
4. Annual reports – the importer submits an annual report to the EA stating the quantity of HFC actually placed on the market.

Importing without a quota = a breach of the regulations. Sanctions are enforced by the Environment Agency (SEPA in Scotland, NRW in Wales); confirm the type and level of penalty with the relevant regulator.

Labelling obligations for equipment containing F-gas

Every piece of equipment containing F-gas placed on the UK market must be labelled in accordance with the requirements of the UK F-Gas Regulation:

The label must state: 1. The name of the refrigerant (e.g. R-410A or the chemical name: Difluoromethane / Pentafluoroethane) 2. The quantity of refrigerant in the equipment (in kg or grams) 3. The GWP of the refrigerant 4. The amount of CO2e (calculated as above) 5. The graphic symbol required for F-gas (EU/UK flag depending on the market)

Incorrect or missing labelling constitutes a breach even if the quota itself is in place.

ODS – older equipment containing HCFC (R-22)

ODS (ozone-depleting substances) are regulated in the UK by The Ozone Depleting Substances Regulations 2019 (the UK counterpart of EU Regulation 1005/2009, replaced in the EU by Regulation (EU) 2024/590).

The most important points for importers:

Substance	Import status in the UK
CFC (R-12, R-11)	Total import ban
HCFC R-22	Import of new equipment containing R-22 is PROHIBITED; servicing existing installations with recovered R-22 is permitted
HFC	Regulated by the F-Gas Quota System

If you are importing second-hand equipment containing R-22 (e.g. older industrial air conditioners), you must document that the R-22 has been removed prior to transport, or that the equipment will be serviced exclusively by a certified F-gas technician.

F-gas technician certification in the UK

Technicians working with equipment containing F-gas (installation, servicing, repair, recovery) must hold an F-gas certificate issued by EA-accredited certification bodies (e.g. Refcom, City & Guilds, BPEC).

Relevant for importers: If your company imports air conditioners and also offers installation services in the UK, your technicians must hold UK F-gas certificates. EU F-gas certificates (e.g. Polish ones) are not automatically recognised after Brexit.

Thresholds and exemptions – when does F-gas regulation not apply to imports?

Not every import of equipment containing a refrigerant requires an HFC quota. Exemptions include:

1. Small quantities: Equipment with an F-gas content below 3 kg of refrigerant (in the case of hermetically sealed equipment, e.g. small domestic refrigerators) may qualify for an exemption.

2. Military and defence equipment: Excluded from F-gas Regulation.

3. Laboratories and research: Imports for scientific purposes in small quantities.

4. Transit: Goods passing through the UK without being placed on the UK market do not require an HFC quota.

Note: Exemptions are very specific. Always verify with the EA or an F-gas adviser whether your situation qualifies before importing.

How UK F-Gas differs from EU F-Gas in practice – for Polish exporters

If you are a Polish company exporting air conditioners to the UK:

1. Your UK customer must hold an HFC quota in the UK F-Gas Registry. Without it they cannot legally place the equipment on the UK market.

2. Reporting: Your UK customer (the importer) submits an annual report to the EA. As an EU exporter you have no registration obligation in the UK, but you must provide documentation confirming the type and quantity of F-gas.

3. Labels: Equipment must carry labels meeting UK requirements (an EU-format label is not sufficient if it omits required content).

4. Technician certificates: If you send technicians to carry out installation in the UK, they must hold UK F-gas certificates.