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F-gas 3.0: the first year of implementation

Published Date 3/4/2025, 7:00 น.

The revised F-gas regulation (also known as F-gas 3.0) entered into force a little over a year ago, on 11 March 2024 to be precise. However, the European Commission’s work on this version of the regulation for fluorinated gases did not end that day. Indeed, four exemptions and five implementing acts have been published so far, and new implementing acts are expected in the coming months.

The exemptions that have been granted for F-gases are implementing regulations that exclude certain applications from a certain requirement of the regulation where barriers for compliance have been found. These barriers are generally manufacturing conversion delays, tight timelines, or a high economic impact.

Implementing acts are an instrument used to update EU laws to reflect developments in a particular sector or to ensure that it is implemented properly. It should be noted that the Commission usually needs to consult a committee in which every EU country is represented before an implementing act can be adopted.

This post analyses the main new aspects of the F-gas 3.0 implementation one year after coming into force, with the focus on the contents of the exemptions and implementing acts published so far.

“Placing on the market” prohibitions from 2025 and exemptions

The first “placing on the market” prohibitions under F-gas 3.0 came into force on 1 January 2025.
As regards the RACHP sector, the new bans affect all self-contained and non-self-contained refrigeration equipment, both commercial and non-commercial. Added to these is the ban on single split air-conditioning equipment and heat pumps containing less than 3 kg of HFCs, which was already scheduled in the previous F-gas regulation.

The impact of these restrictions has been especially notable in non-commercial self-contained refrigeration appliances, in which the use of fluorinated refrigerants with a GWP above 150 has been prohibited since the start of 2025, unless if required to meet safety requirements at the site of operation. Indeed, for the following applications an exemption that allows the use of fluorinated refrigerants with a GWP above 150 has been approved:

Blast cabinets with a full load capacity from 25 kg to 100 kg of foodstuffs, artisanal gelato ice cream makers with a cooling capacity higher than 2 kW, ice makers with an ice production capacity from 200 kg to 2000 kg per 24 hours, trolleys for preserving and regenerating food with rated power input from 1,5 kW to 10,5 kW, retarder prover cabinets with an absorbed power from 1 kW to 2 kW, frozen drinks dispensers and cold cream dispensers with a chilled full load capacity greater than 3 litres. This exemption is applicable from 1 January 2025 to 30 June 2026.
Blood transport boxes and blood plasma contact shock freezers. This exemption is applicable from 1 January 2025 to 31 December 2026.
Mechanical cryogenic freezers (– 150 °C). This exemption is applicable from 1 January 2025 to 31 December 2028.
Environmental simulation devices consisting of a test chamber used to reproduce a variety of environmental conditions for applications below – 50 °C, laboratory drying equipment used for the drying of liquid samples (by spray-drying or by freeze-drying), and laboratory centrifuges used for separating fluids of different densities or liquids from solids in a rapidly rotating container. This exemption is applicable from 1 January 2025 to 31 December 2028.

The other three “placing on the market” prohibitions that have come into force in 2025 have had less impact on the market for different reasons, and thus no exemptions have been published.

Firstly, the use of fluorinated refrigerants with GWP of 150 of more has been banned for refrigerators and freezers for commercial use (self-contained appliances). However, the GWP limit on these units was already 150 for HFCs. The impact of extending this restriction to all fluorinated refrigerants has been minimum because most of the fluorinated refrigerants currently used that are not HFCs have GWP values below 150.

Moreover, the GWP limit of 2500 has been extended from HFCs to all fluorinated gases for non self-contained refrigeration equipment, except equipment intended for application designed to cool products to temperatures below – 50 °C. However, the greatest impact will most likely be in 2030 when the GWP limit will be reduced to 150.

Lastly, single split air-conditioning equipment and heat pumps, containing less than 3 kg of HFCs with GWP of 750 or more, have been banned. The impact on these applications may be higher in 2027 and 2029, where the GWP limit will be decreased to 150.

Which implementing acts were adopted in 2024?

The “Labelling Act” was the first implementing act on F-gas 3.0 and is applicable from 1 January 2025. It indicates certain details on the positioning of the label that appliances containing (or whose functioning relies upon) fluorinated refrigerants shall use and the information that it shall contain. Some examples of the texts that the label shall include, when applicable, are: ‘contains fluorinated greenhouse gases’, ‘Prohibited to be operated, unless required by safety requirements that have to be applied at the site of operation’, ‘For direct export out of the EU only’.

The second implementing act published last year referred to the reporting format for Article 26 compliance, applicable from 1 January 2025. It specifies the general format of the reporting tool for the sections that shall be filled in by the different players in the supply chain: producers, importers, exporters and certain users of fluorinated greenhouse gases. For instance, section 1 is to be filled in by producers of gases, section 2 is to be filled in by importers of gases, section 3 is to be filled in by exporters of gases, and section 4 is to be filled in by producers and importers of gases and by undertakings that reclaim gases. For each reporting section, the units of measure, the gases covered, the level of detail and an indication of the year in which activities are to be reported are specified.

The implementing act on Certification for refrigeration, AC and heating is applicable from 25 September 2024. Since that day, Member States have one year to establish or adapt certification programmes, including evaluation processes, and ensure that training on practical skills and theoretical knowledge is available according to the requirements included in the implementing act.

The following types of certificates can attest that the holder fulfils the requirements:

Certificate A1: leak checks; installation; repair, maintenance or servicing as well as decommissioning; and recovery in relation to fluorinated greenhouse gases and hydrocarbons.
Certificate A2: leak checks; installation; repair, maintenance or servicing as well as decommissioning; and recovery in relation to fluorinated greenhouse gases and hydrocarbons, limited to equipment with a charge of less than 3 kilograms or, if hermetically sealed systems which are labelled as such are concerned, containing less than 6 kilograms.
Certificate B: leak checks; installation; repair, maintenance or servicing as well as decommissioning; and recovery in relation to carbon dioxide (CO₂).
Certificate C: leak checks; installation; repair, maintenance or servicing as well as decommissioning; and recovery in relation to ammonia (NH₃).
Certificate D: recovery for the equipment containing less than 3 kilograms of fluorinated greenhouse gases or, if hermetically sealed systems which are labelled as such are concerned, containing less than 6 kilograms of fluorinated greenhouse gases.
Certificate E: leak checks, provided that such activity does not entail breaking into the refrigeration circuit containing fluorinated greenhouse gases.

F-gas portal registration rules are already applicable. These specify the requirements for undertakings that need to have a valid registration in the “F-gas Portal” prior to carrying out certain activities, including information on their location, business activities and legal and financial status. Additionally, they shall ensure that the information provided by or on their behalf is kept up-to-date as soon as any such information changes or ceases to be complete or accurate. The information requirements for registration in the F-gas Portal are different for undertakings established in the Union, other than independent auditors; undertakings established outside the Union that have mandated a sole representative; and independent auditors.

The implementing act on the quota reference values for HFCs was published last November and is applicable from 1 January 2025 to 31 December 2026. It includes the reference values for each producer or importer that has lawfully placed hydrofluorocarbons on the Union market from 1 January 2021 to 31 December 2023. It should be note that the names of the companies that receive the quota are listed in the implementing act, whereas the reference values are not, as they are considered as commercially sensitive information.

F-gas 3.0 in 2025: other restrictions and conclusions

In the first section of the post, the bans on the “placing on the market” that apply from 2025 have been mentioned, but there are two other restrictions starting this year that deserve attention.

One of these restrictions is the ban on the export of stationary refrigeration, air-conditioning equipment and heat pumps that contain, or whose functioning relies upon, fluorinated greenhouse gases with a GWP of 1000 or greater. This entered into force on 12 March 2025.

The other is the ban on the use of fluorinated greenhouse gases with a global warming potential of 2500 or more for the maintenance or servicing of any refrigeration equipment, which has been extended to equipment with less than 40 tonnes of CO₂ equivalents from 1 January 2025. To give an example, 40 tonnes of CO₂ equivalents corresponds to 10.2 kg of R-404A.

In conclusion, there are many restrictions that have entered into force in 2025, a year that will be key to understanding the impact of F-gas 3.0, above all in refrigeration applications and on the export of stationary RACHP equipment. It will be interesting also to see how Member States will update their certification programs and whether the need for certification on natural refrigerants will have a significant impact. Stay tuned!