CO₂ TAX ON F-GASES AS OF JAN. 1, 2026

CO₂ TAX ON F-GASES

AS OF JANUARY 1, 2026

The European Union has made significant changes that will affect companies working with fluorinated greenhouse gases (F-gases). The new CO₂ tax will be introduced on Jan. 1, 2026, which will result in increased costs for affected industries. Companies working with F-gases should prepare for increased reporting requirements and stricter regulations.

Important Changes

01

Mandatory Registration in the F-gas Portal.

All producers, importers, exporters, recoverers (reclaimers), exempt users and MDI manufacturers must register in the EU F-gas portal.

02

Stricter Quota & Production Rights

  • Hydrofluorocarbons (HFCs) require approved quota allocations before they can be released for free circulation.
  • Producers will need official production rights starting in 2025.
03

Statements & Documentation

Each shipment must contain the following documents:

  • Declaration of Conformity
  • Proof of agreements to return refillable containers
  • Evidence of destruction/recovery of R23 byproducts.
  • Proper labeling according to the Labeling Implementation Act
  • Accurate customs declarations
04

Complete Ban on Non-Refillable Cylinders

Non-refillable containers will be illegal to import, export, transport or use as of 2026.

05

Annual Reporting & Verification

  • Deadline for reporting: March 31 of each year
  • Independent verification required for companies handling ≥ 1000 t CO₂eq.
  • Exporters and producers must report all quantities (no more HFC threshold from 2025).

Duties by Role

Overview of obligations for all parties involved in F-gases.

Importers of Bulk HFCs

  • Must have an import license and sufficient quota.
  • Required declarations and customs details.
  • Annual reporting and audits.

Importers Using Special Customs Procedures.

  • Registration required.
  • Labeling and customs obligations.
  • Reporting is mandatory.

Producers of F-gases

  • Must have production rights.
  • Quotade coverage for all HFCs placed on the market.
  • Treatment of R23 byproducts required.
  • Annual reporting.

Exporters

  • Export license required.
  • Non-refillable cylinders are prohibited.
  • Additional restrictions on countries that have not ratified the Montreal Protocol.
  • Complete annual reporting.

Non-HFC F-gas handlers.

  • Registration required.
  • Labeling and conformity statements.
  • Reporting at ≥ 100 t CO₂eq.

Reclaimers (Reclaimers) & Destroyers (Destroyers)

  • Only approved destruction processes allowed.
  • Reporting of quantities above 1 ton or 100 t CO₂eq required.

Feedstock Users.

  • Registration required.
  • Reporting at ≥ 1 ton or 1000 t CO₂eq.

Distributors

  • Need to prevent emissions.
  • Must keep proof of return of containers.
  • No reporting or registration required.

Purpose of the CO₂ tax

Overview of the main goals of the carbon tax on F-gases and the impact on companies.

Accelerate the phase-out of high-GWP F-gases

Encourage switching to low-GWP refrigerants

Supporting the EU's climate goals

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