The year 2025 brings new equipment-specific bans related to F-gases, restrictions on the maintenance of refrigeration equipment, and obligations concerning the handling of building insulation waste, product labeling, and F-gases in metered dose inhalers.
The new placing on the market prohibitions apply to certain refrigeration, air conditioning, and heat pump equipment, fire protection equipment, as well as personal hygiene products and skin cooling equipment, based on the type of F-gas or its global warming potential (GWP). Placing on the market refers to the import of products and equipment from outside the European Union and the manufacture within the EU for the EU market.
The prohibitions apply to new products and equipment and do not affect products or equipment already in use. The prohibitions do not apply to military equipment. From 12 March 2025, the prohibitions also apply to the export of foams, technical aerosols, stationary refrigeration and stationary air conditioning equipment and stationary heat pumps equipment outside the EU if the GWP of the F-gas contained in the equipment or product is 1000 or more (F-gas Regulation, Article 22(3), eur-lex.europa.eu).
The servicing and maintenance of refrigeration equipment with F-gases with a GWP of 2500 or more (e.g., R-404A) is prohibited from 1 January 2025 (F-gas Regulation, Article 13(3), eur-lex.europa.eu). However, regenerated or recycled F-gases may be used for maintenance until the end of 2029. The maintenance ban does not apply to military equipment or equipment that cools products to temperatures below -50 °C.
The Finnish Environment Institute (Syke) is the competent authority for the F-gas Regulation and the market surveillance authority in Finland. This news article briefly describes the content of the F-gas Regulation, but the F-gas Regulation is the only text with legal force.
Equipment and products prohibited from being placed on the market from 1 January 2025
- Refrigerators and freezers for commercial use (self-contained equipment) that contain F-gases with a GWP of 150 or more (F-gas Regulation Annex IV, point 3(c), eur-lex.europa.eu)
- Any self-contained refrigeration equipment, except chillers, that contains F-gases with a GWP of 150 or more, except if required to meet safety requirements at the site of operation (F-gas Regulation Annex IV, point 4, eur-lex.europa.eu)
- Refrigeration equipment (except chillers and equipment covered in points 4 and 6 of Annex IV) containing or or whose functioning relies upon F-gases with a GWP of 2500 or more, except for equipment intended for applications designed to cool products to temperatures below – 50 °C (F-gas Regulation Annex IV, point 5(b), eur-lex.europa.eu)
- Single split systems containing less than 3 kg of F-gases listed in Annex I to the Regulation that contain, or whose functioning relies upon, F-gases listed in Annex I to the Regulation with a GWP 750 or more (F-gas Regulation Annex IV, point 9(a), eur-lex.europa.eu)
- Fire protection equipment that contain or rely on F-gases listed in Annex I to the Regulation, except when required to meet safety requirements at the site of operation (F-gas Regulation Annex IV, point 11(c), eur-lex.europa.eu)
- Personal care products (e.g. mousse, creams, foams, liquids or sprays) that contain F-gases (F-gas Regulation Annex IV, point 20, eur-lex.europa.eu)
- Equipment used for cooling the skin that contain, or whose functioning relies upon, F- gases with GWP of 150 or more except if used for medical applications (F-gas Regulation Annex IV, point 21, eur-lex.europa.eu)
There are some time-limited derogations to the above prohibitions. The derogations apply to the product group regardless of the manufacturer or brand and are valid in all EU countries. The EU Commission's implementing regulations on derogations can be found on the EU Commission's website (climate.ec.europa.eu).
Other new obligations
From 1 January 2025, foam insulation removed during building repair, renovation, and demolition work must be handled so that the ozone-depleting substances or F-gases contained in them are recovered or destroyed. However, intact insulation boards or products containing them can be reused. Read more about this in Syke's news article (syke.fi).
The labeling requirements for equipment and products containing F-gases will be clarified from 1 January 2025, and a new implementing regulation on labeling (eur-lex.europa.eu) has been issued. To ensure the uninterrupted continuity of medicine distribution, Syke and Fimea have provided guidelines to operators concerning metered dose inhalers (ymparisto.fi).
The quantity of HFC substances imported from outside the EU and manufactured within the EU for the EU market is regulated by a quota system. From 1 January 2025, this also applies to HFC substances in metered dose inhalers (F-gas Regulation, Article 19, eur-lex.europa.eu) and HFC compounds manufactured or imported for the manufacture of inhalation sprays (F-gas Regulation, Article 16, eur-lex.europa.eu). Guidelines for the import of metered dose inhalers containing a total of more than 10 t CO2-eq. of HFC substances can be found on the environmental administration's website (ymparisto.fi).
The operator must prepare an installation certificate for stationary refrigeration, air conditioning, and heat pump equipment, identifying the installed equipment and describing the tests and other measures carried out to verify functionality. The installation certificate, signed by the operator's responsible person, is handed over to the owner of the equipment. (Environmental Protection Act, 162 a §, finlex.fi (in Finnish))
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More Information
Finnish Environment Institute, f-gas@syke.fi