For companies buying or supplying refrigerants and cooling equipment across the English Channel, one assumption can create a compliance gap: that meeting F-gas requirements in one market automatically covers the other.

The EU and Great Britain (GB) operate separate F-gas regimes. The EU’s current framework is Regulation (EU) 2024/573. Great Britain continues to apply its own version of Regulation (EU) No 517/2014, as amended for the GB market. The rules cover some of the same activities, including HFC quotas and equipment restrictions, but use separate systems and schedules. GB here means England, Scotland and Wales. climate.ec.europa.eu

That distinction matters when a company imports bulk refrigerant, brings in pre-charged equipment, or moves products between the EU and GB. A shipment may trigger obligations in the destination market even if the gas or equipment has already been covered by procedures elsewhere. Procurement and compliance teams need to identify the market where the product will be placed, the company responsible for the transaction and the rules that apply there.

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The quota schedules are not the same

Both systems limit the quantity of HFCs that may be placed on their respective markets, measured in tonnes of CO₂ equivalent (CO₂e). But the schedules differ.

Under the EU F-gas Regulation, the maximum quantity for the 2027–2029 period is 21,665,691 tonnes of CO₂e. This follows the 2025–2026 maximum of 42,874,410 tonnes of CO₂e. The Regulation sets these figures in Annex VII. eur-lex.europa.eu

Great Britain’s existing schedule sets the 2027–2029 phase-down step at 24% of its baseline. In May 2026, Defra confirmed that it would not legislate during 2026 to change the step taking effect on 1 January 2027. The existing Annex 5 step therefore remains in place for 2027. legislation.gov.uk

The figures should not be treated as directly interchangeable. The EU and GB schedules use separate regulatory frameworks and baselines. A percentage of one market’s baseline is not a direct comparison with a total CO₂e quantity in the other. Businesses should use the figure and allocation rules for the market where the HFCs will be placed.

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Identify who is importing the gas

The first operational question is whether the transaction involves bulk HFCs or equipment already charged with HFCs.

In the EU, producers and importers placing bulk HFCs on the market are subject to the EU quota system. The European Commission manages quota and related authorisations through its F-gas Portal. The portal also contains the registration and transaction records used for quota transfers and equipment authorisations. climate.ec.europa.eu

In Great Britain, an undertaking must have GB quota to produce or import bulk HFCs for the GB market. The Environment Agency allocates incumbent quota and administers the GB service. An equipment importer or authorisation manager does not apply for bulk quota through that process; instead, equipment importers may need quota authorisations or delegations from a GB quota holder or authorisation manager. GOV.UK

The importer’s location alone does not settle the question. The transaction’s destination and customs route matter. For example, UK government guidance states that an EU-based producer or importer must have GB quota to import bulk HFCs into Great Britain. If a company in Great Britain imports bulk HFCs to pre-charge equipment that will then be exported to the EU, it needs the relevant EU quota authorisations for that export. GOV.UK

This is why a supplier’s quota status in one system should not be taken as proof that a separate import or placing-on-the-market requirement has been met in the other.

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Check pre-charged equipment separately

Equipment containing HFCs can bring a different set of obligations from bulk refrigerant. Refrigeration, air-conditioning and heat-pump systems may be subject to requirements concerning registration, quota coverage, authorisations, declarations and customs information.

For EU imports, the Commission’s guidance covers importers of refrigeration, air-conditioning and heat-pump equipment containing HFCs. It identifies requirements around portal registration, quota authorisations, documentation and customs declarations. The specific obligations depend on the equipment and transaction. climate.ec.europa.eu

For Great Britain, companies importing pre-charged equipment may need to register on the GB F-gas service and obtain quota authorisations or delegations. The UK guidance says this applies where the HFC quantity imported reaches 100 tonnes of CO₂ equivalent or more in a calendar year. It also states that the importer must have enough authorisations or delegations in its account before the end of the calendar year for the goods placed on the GB market during that year. GOV.UK

The EU and GB processes should be checked independently. An EU portal authorisation should not be assumed to satisfy the GB process, or vice versa. When a shipment crosses the Channel, confirm which undertaking is the importer, what quantity of HFC is contained in the equipment, which market the product will enter and which system must record the relevant authorisation.

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Compare product restrictions by market

Quota availability and product restrictions are separate compliance checks. A product may have quota coverage and still be restricted by a rule governing which gases may be used in a particular type of new equipment.

The EU Regulation contains equipment restrictions in Article 13 and Annex IV. For example, from 1 January 2027, certain self-contained air-conditioning equipment and heat pumps with rated capacities up to 50 kW are subject to restrictions on fluorinated greenhouse gases with a GWP of 150 or more, subject to the conditions and safety exceptions in the Regulation. The exact rule depends on the equipment category and rated capacity. Climate Action

Great Britain has its own product-ban guidance and schedule. Its current guidance, last updated on 27 August 2026, lists a ban from 2025 on F-gases with a GWP above 750 in certain single-split air-conditioning systems containing less than 3 kg of refrigerant, alongside specified exceptions. That is a different rule from the EU’s 2027 restrictions for covered self-contained equipment. GOV.UK

The practical check is product-specific. Confirm the equipment type, capacity, refrigerant and intended market, then consult the current restriction for that jurisdiction. “Compliant in the EU” or “compliant in GB” is not enough detail to establish that a product can be placed on the other market.

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Keep reporting and records aligned with each regime

A cross-border compliance process should also distinguish reporting and customs records. The EU F-gas Portal supports quota management, import and export requirements, and reporting under Regulation (EU) 2024/573. EU customs declarations require specified information, including the F-gas Portal registration number and the quantity in metric tonnes and CO₂ equivalent. Fluorinated Greenhouse Gases – Climate Action

Great Britain uses its own F-gas service and reporting arrangements. UK government guidance requires relevant operators to record and report imported F-gases and equipment pre-charged with F-gas. For applicable equipment imports, it also describes declaration-of-conformity requirements. GOV.UK

Businesses should maintain records that connect the product, gas, quantity, supplier, importer, destination market and applicable authorisation. This helps teams answer a basic but important question: which regulator’s system contains the evidence for this transaction?

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A practical cross-border checklist

Before ordering or shipping refrigerants or equipment between the EU and Great Britain, procurement and compliance teams should:

• Identify the destination market. Determine where the gas or equipment will be placed on the market and whether the route involves EU, GB or onward export.

• Classify the product. Establish whether it is bulk HFC, pre-charged equipment or a product using another F-gas.

• Calculate the relevant CO₂e quantity. Use the gas type, mass and applicable GWP to assess quota coverage and any relevant thresholds.

• Confirm the responsible importer. Record which legal entity handles the import, customs release and placement on the market.

• Check quota and authorisations in the correct system. Verify EU requirements in the F-gas Portal and GB requirements through the GB F-gas service.

• Review product restrictions separately. Check the equipment category and refrigerant against the rules in the destination market.

• Agree documentation responsibilities. Confirm who supplies authorisations, declarations, customs details and records needed for the transaction.

• Recheck the rules before shipment. EU and GB guidance and legislation can change; use current official requirements for the date and route of the transaction.

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Plan for the market the product enters

The EU and Great Britain share the objective of phasing down HFCs, but companies cannot treat their quota schedules, portals and equipment restrictions as one system. The EU’s 2027 quota maximum and Great Britain’s existing 2027 phase-down step are set under different frameworks. Imports, authorisations and product restrictions must be checked against the rules that apply in the destination market.

AFS Cooling supports businesses with refrigerant procurement, quota management, compliance and documentation. For help reviewing your cross-border requirements, contact AFS Cooling.

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