F-gas audit for importers of equipment containing fluorinated greenhouse gases
F-gases, which include fluorinated greenhouse gases such as HFCs and PFCs, are commonly used in air conditioners, heat pumps, and other devices. These gases contribute significantly to global warming and pose a serious threat to the environment. As such, reducing the amount of F-gases and substances that deplete the ozone layer is crucial for protecting our planet. To this end, the European Commission has proposed new regulations aimed at reducing the use of F-gases in Europe.
Import regulation
General rules
In the sector of fluorinated greenhouse gases (fluorocarbons), European regulations apply. Regarding F-gas, the 'F-gas Regulation (Regulation (EU) No 2024/573 on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014)' is in effect. A particular part of this Regulation relates to reporting and documentation requirements, such as registration, declaration of conformity when placing equipment containing F-gas on the market for refrigeration, air conditioning, and heat pumps, and verification of the same by an independent auditor.
For the purpose of phasing out the use of fluorinated greenhouse gases, individual producers and importers are allocated a quota for placing fluorocarbons on the market. The purpose of this measure is to ensure that the overall quantitative limit for placing fluorocarbons on the market was not exceeded.
Quota, license and declaration of conformity
Quota amounts are allocated to producers and importers of bulk F-gas (in containers and gas cylinders). The importer of equipment containing these substances must have a permit. This permit is an agreement between the quota holder (producer or gas importer) and the equipment importer. In this way, the 'quota holder' transfers part of the quota to the importer. Companies must enter their permits into the HFC registry (registration tool); otherwise, they are not valid for equipment import.
The equipment importer prepares a Declaration of Conformity, confirming that they have the necessary permits and quota.
Why is F-gas audit necessary?
The importer maintains documentation on deliveries with details about the shipments (type of model, number of units per model, amount of substances in grams, total quantity in CO2 equivalent, etc.). This information must be entered into the EU reporting system (F-gas web portal). If the fluorocarbons contained in products or equipment are not placed on the market before the product or equipment is filled, importers of those products or equipment must ensure that, by April 30, 2025, and annually thereafter, the accuracy of this documentation and Declaration of Conformity, as well as the accuracy of the report for the previous calendar year, is verified with a reasonable level of assurance by an independent auditor registered on the F-gas portal.
Please note: Any equipment importer that has placed previously filled equipment containing fluorocarbons in a quantity of at least 1,000 tonnes CO2 equivalent on the market, if these fluorocarbons were not placed on the market before the equipment was filled, must ensure that the EU Commission receives a verification report from an independent auditor.
Forvis Mazars in Croatia has extensive experience in performing F-gas audits and will gladly help with coordinating the necessary work and audit approach to ensure compliance with these regulations.
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