HFC Quotas 2027-2029: What Refrigerant Producers and Importers Must Do

Key data

Producers and importers of hydrofluorocarbons (HFC) in the European Union have, from 1 January 2027, an individual legal limit on what they can market. Commission Implementing Decision (EU) 2026/1382, published on 30 June 2026, establishes the individual reference values for the period 2027-2029, calculated on the basis of quantities lawfully placed on the market between 1 January 2022 and 31 December 2024.

These reference values are the basis on which the Commission assigns marketing quotas. It is not a recommendation: it is the legal ceiling for each company's operation. Anyone exceeding it faces sanctions and restrictions on access to the EU market.

What does this regulation establish?

The Regulation (EU) 2024/573 on fluorinated gases establishes a quota system to progressively reduce the amount of HFC that can be placed on the European market. Implementing Decision 2026/1382 is the practical implementation of that system: it sets, company by company, what its reference value is for the three-year period 2027-2029.

The mechanism works as follows:

• The quantities of HFC that each company lawfully introduced on the EU market between 2022 and 2024 are taken into account.
• Those quantities are converted into the individual reference value of each company.
• Based on that value, the Commission assigns marketing quotas for 2027-2029.
• Companies can only introduce on the market the amount of HFC equivalent to their assigned quota.

The progressive reduction of quotas is the central mechanism of European decarbonization policy in this sector. With each new three-year period, the ceiling drops. The objective is to accelerate technological substitution towards refrigerants with low global warming potential.

Economic and operational impact

The impact is not only regulatory: it is directly commercial and operational. Companies that have reduced their activity between 2022 and 2024 will see that decline reflected in a lower reference value, leaving them less room to operate in 2027-2029. Conversely, those who have maintained or increased volumes in that period start with a larger quota.

The concrete effects on business are:

• Sales restriction: You cannot market more HFC than your quota allows, regardless of market demand.
• Sanctions for exceeding quota: Exceeding the assigned quota exposes the company to administrative sanctions and restrictions on access to the EU market.
• Pressure on margins: Scarcity of quota on the market raises the price of available HFCs, increasing costs for equipment manufacturers that use them as refrigerants.
• Acceleration of technological substitution: Companies that have not begun the transition to alternative low-GWP refrigerants will be forced to do so in a shorter timeframe and at greater cost.

The sectors with the greatest operational exposure are hospitality, refrigerated transport and construction, where refrigeration and air conditioning equipment with HFC is still predominant.

Who does it affect?

• HFC producers with activity in the EU market between 2022 and 2024.
• HFC importers that have lawfully introduced these gases on the EU market in that same period.
• Manufacturers of refrigeration and air conditioning equipment that use HFC as a refrigerant (including heat pumps).
• Hospitality sector companies with large industrial refrigeration installations.
• Refrigerated transport operators that depend on HFC-based systems.
• Developers and construction companies that install air conditioning systems in buildings.
• Distributors and wholesalers of refrigerant gases that act as intermediaries in the supply chain.

Practical example

An importing company that between 2022 and 2024 introduced a certain amount of HFC on the EU market will see that volume converted into its individual reference value. If, for example, it reduced its imports in 2023 due to supply problems or a drop in demand, that decline will be reflected in a lower reference value for 2027-2029.

This means that, even if demand from its customers recovers in 2027, that company will not be able to supply more HFC than its quota allows. If its competitors have larger quotas because they maintained higher volumes in 2022-2024, they will lose market share with no way to compensate in the short term.

For a manufacturer of air conditioning equipment that buys HFC from its suppliers: if its usual suppliers have tight quotas, the price of the gas will rise or supply will be restricted, which directly impacts its production costs and delivery times to its end customers.

What should companies do now?

1. Verify the assigned reference value: Check in the official text of Decision 2026/1382 what individual reference value the Commission has set for your company. It is the starting point for all planning.
2. Compare the quota with demand forecasts for 2027-2029: If the assigned quota is lower than anticipated needs, you must act in advance: seek commercial agreements with companies that have surplus quota or accelerate technological transition.
3. Initiate or accelerate the transition to alternative low-GWP refrigerants: The progressive reduction of quotas is structural. Companies that do not substitute technology now will have less room and higher costs in the next regulatory cycles.
4. Review contracts with suppliers and customers: Quota restrictions affect the entire chain. Long-term supply contracts must include clauses that account for HFC availability limitations.
5. Establish a quota consumption tracking system: Exceeding the assigned quota entails sanctions and market access restrictions. It is essential to monitor in real time the volume marketed against available quota.
6. Consult with a specialist advisor in fluorinated gas regulations: Quota management, possible transfers between companies and sanctioning implications require specific technical-legal advice.

Official source

Consult full regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026D1382