Session 2

Quota allocation, instruments

and country experience

Natasha Kochova
June 14, 2023
UNIDO KIP workshop
Quota allocation (market measure)

• Objective of import quota system

= ensure that the country will not import more of a substance (or group of
substances) than the limit for that country according to its relevant legislation;
• The sum of the quotas allocated to all eligible importers →
equal to or lower than this limit;
• HFCs that can be placed on the market is subject to quantitative limits
(HFC phase-down);
• The cap and phase-down of HFCs is implemented through a quota system
(in CO2 equivalent);
• Aim is to avoid increase of HFCs consumption under the work done with the
HPMPs (HCFC phase out).
Why a quota system?

• Prevent the country from exceeding its HFC annual

consumption limits in the MP
• An effective instrument to implement the HFC phase-down;
- clearly defined obligations
- tailored to national circumstances
• HFCs importers of HFCs safeguarded (conduct businesses)
 • What are the sectors? Who receives the quota?

On the lookout for… • Could quotas be sold?

• Should quotas cost? *
• Do the importers need to pay to apply for the quota?
• What should be the level of country’s HFC import quotas? **
• Is quota required for exports?
• Are the allocated quota tradeable/transferrable among importers?
• Do the license holders need to report back how much they imported? If so, how frequently?
• How is the licensing authority communicating and sharing data with Customs on issued licenses?
• Should HFC imported in products or equipment be included in a quota system? ***
• Do the importers need to declare who their customers (distributors, servicing workshops) are?
• Does the NOU reconcile (crosscheck) data with customs, licensing authority (if different from NOU), and importer?
• What happens in case of discrepancies or missing information?
• What type of HS code is used by the customs?
F-gas polices in the EU:
Implementation of the quota system
and lessons learned
UNIDO Workshop on KIP preparations

Vienna,
14 June 2023
Main logic of the EU F-gas Regulation

Reducing HFC use

• Phase-down of HFCs (Quota system)
• Additional specific prohibitions on use, products & equipment

Reducing HFC losses

• Emission prevention, Leak checks, Certification/Training of Technicians, Recovery
Obligation, Venting prohibition, End-of-Life Treatment, …

Controlling & enforcement

• Trade licensing, Custom rules, Market surveillance, Labelling, Penalties, Reporting
 Possible EU Phase Down Profile
100%

Main Policy Driver: Quota System 90%

% of baseline EU sales permitted

80%
70%
60%
50%
40%
30%
20%
10%
0%
2015 2020 2025 2030
Year

Upstream Market Measure: Reduce EU (initial) HFC placing on the

market (measured in CO2eq.!) in 3 year steps by 80% (2015- 2030)

➢Companies importing or producing HFCs (bulk!) get HFC quota every year (in
CO2eq) → more metric tonnes for climate-friendlier substances can be sold
➢A company can only place quantities of HFCs on the EU market up to their anual quota
limit
➢All HFCs in pre-charged RAC equipment need to be accounted for in the quota system
 Implementation of quota system

• Fgas Portal & Licensing System:

• Registration of companies (importers, exporters, producers, etc) → Trade License
• Application for quota/ Allocation of quota, Transfer of quotas, Authorise quota use for Equipment
• Store amounts placed on the market
• Penalties

• Elaborate electronic reporting system (EEA presentation)

• Ex post verification (independent auditors)

 Border Control, Market Surveillance

➢EU Single Window Environment for Customs

• mandatory participation of all 27 EU countries, from 3/2025

• connects customs offices (ca. 2500) in 27 Member States to EU-central database on

fluorinated gases (incl HFCs) and Ozone-Depleting Substances

• Less burden for economic operators, customs and authorities, but better control
o real-time license check
o quota debit system
o flagging of suspicious activties
o tracking of shipment data
2014 F-gas Regulation
 Quota System
Incentive for innovation

Market measure: Quota system creates scarcity

→ Prices for high GWP gases rise strongly

→Flexibility: Reaction of market players where, how and as soon as possibl3

→ Achieve by avoing HFCs in new equipment, smaller charges/retrofitting, reducing leakage,

recover & reclaim gas

"Stay low, move fast …"

and you will still be cool !

Some Lessons learned
• Quota system is flexible and readily acceptable to industry, but results in some administrative
burden for authorities and its effects are less foreseeable
o EU is a Union of 27 countries with a common market → special challenges for external border controls and market surveillance

• Prohibitions are easier to implement and predictable, but more difficult to design (need for
exemptions, timing of the dates, definitions of scope..)

→ A combination of quota system and add. prohibitions („signpost“) has worked well in the EU

• Today feasible in many areas to eliminate HFCs, or at least reduce GWP significantly
o R404A/R507A/R410A is obsolete today!
o One-way cylinders should be banned!

• HFC fees implemented in some countries (ES; FR;..); additional fiscal measures may be useful, but
charge at upper level (imports/production), not at enduser level

• Awareness raising is crucial for quota system, also with customs; close cooperation with competent
authorities important
 Refrigeration – EU market situation today
Supermarket systems Transcritical CO2 systems with high energy efficiency are now the
standard solution for new supermarket refrigeration systems.
Components and specialized technical personnel are widely available.

Stand-alone commercial Systems running on R290 as a refrigerant are the standard solution
systems for small shops and discounters (refrigerated shelves, freezers etc.)

Transport refrigeration Research and development as well as market introduction of CO2 and
propane solutions for refrigerated trucks and vans

Refrigerant recycling and Specialized refrigerant handling companies collect recovered refrigerants
reclaim from service companies and gas distributors and perform analytical
checks. On the basis of the analysis, reclamation is carried out in
dedicated facilities or the refrigerant is sent for destruction.
 AC & heatpumps – EU market situation today
Moveable room AC Hydrocarbons (R290; propane) are the standard refrigerant is small moveable air
conditioning systems in the EU since 2020
Split AC HFC reduction through the use of the interim solution R32, with the prospect of a broader use
of natural refrigerants in line with the revised safety standard IEC 60335-2-40.
Market introduction of hydrocarbons (R290; propane) in split air conditioners.
Conventional HFC refrigerants are hardly used any more.

Chillers Mini-chillers with R290 (5-30 kW; 2-4 kg charge, with a secondary glycol/water loop) represent
a solution for various applications.
For large chillers, ammonia (R717) has long been established on the market (high efficiency).
Propane (R290), CO2 (R744) and water (R718) are also entering the market.

Bus AC CO2 heat pumps systems in electric and hybrid buses are common

Passenger car AC CO2 heat pumps systems in electric passenger cars (AC and range extension) are common

Heat pumps Research and development of low-charge R290 systems (12.8 kW heating capacity with 124 g
of R290 → refrigerant charge ca. 10 g/kW). Many EU suppliers offer propane solutions,
especially in the heating capacity range <12 kW.
Increasing use of heat pump solutions also in larger applications.
 New European Commission Proposal

• Proposal for a new EU F-gas

Regulation on 5 April 2022
• Negotiated between EU Member
States (“Council”) and the European
Parliament
• The final law will be directly
applicable in all 27 EU Member
States
• Aiming to have a new law in place
[Link]
by 2024
The proposed new HFC phase-down / quota
system
Quantities HFCs supplied to the EU market to be reduced by 98% from 2015 to
2050

Note: This includes quantities imported in pre-charged equipment

New ambition of phase-down

50

45

40
millition tonnes CO2 equivalent

35

30

25
Current law

20

15

10
Newly proposed
phase-down
5

0
2024 2027 2030 2033 2036 2039 2042 2045 2048
 Some newly proposed, additional prohibitions
• Refrigeration sector mostly covered by existing Regulation

• NEW: AC/heatpumps:

• Self-contained with GWP>150 (2025)

• Splits up to 12kW capacity with GWP>150 (2027)
• Splits above 12kW capacity with GWP>750 (2027)

• Extension of placing on the market ban of non-refillable containers to prohibit import,

subsequent supply, use or export (empty, partially filled, or filled)

• On SF6: Different types of switchgear with GWP>10, as feasible (2026-2031)

• Personal care products (2024), skin-cooling equipment (2024), desflurane (anaesthetic,

2026), fire protection (2024)
 A crucial sector: Split AC

Purohit et al. (2022). PNAS.

Other relevant changes to the F-gas Regulation
• Quota allocation: Quota holders need to…
- fulfill certain conditions, e.g. experience in trade in chemicals
- pay for their quota
• Customs
- Digitisation and automation of custom controls: Every relevant shipment counter-checked
with EU-central database
- Reinforced custom rules, controls of trade
• Control
- Reinforced inspections, penalties and cooperation between authorities, independent
verification of data

• Export bans? …not in the Commission proposal, but now on the table…
 What do we expect out of this?
• Emission reductions: By 2050, avoid (cumulatively) 310 MtCO2eq (ca. total annual emissions of
Belgium, Luxemburg and Netherlands together), on top of 430 MtCO2eq to be saved by the existing
Regulation

• Climate neutrality: Remaining EU F-gas emissions in 2050 will be only ca 14 MtCO2eq (2019:
92MtCO2eq)

• Modest Costs: In most cases will be low compared to those asked of non-Fgas sectors on the road to
climate neutrality, and will in all cases be proportionate

• Energy savings for end-users of refrigeration and air conditioning equipment

• Stimulating effects (output, innovation, employment), particularly on the equipment sector and its
supply industry,

• Significantly improved control over the policy, allowing effective enforcement in the Member States,
at a moderate increase in administrative burden to companies and authorities

• Better trained personnel to handle climate-friendly technologies

Thank you
[Link]@[Link]

[Link]
UNIDO Kigali Implementation Plan workshop. Session 2: Quota allocation, instruments and country experiences | 14 June 2023 | Vienna | Peder Gabrielsen

Data management and reporting system on European Union level

EU F-gas Regulation (EU) 517/2014 – main elements
Measures to avoid the use of F-gases

HFC phase-
Bans Labelling Reporting
down
Reporting

Recovery &
Leakage Training &
waste
control certification
management

Measures to prevent leakage of F-gases

Context of reporting – Ozone-depleting substances

Source: EEA indicator ‘Consumption of ozone-depleting substances’

[Link]
Data viewer ‘Ozone-depleting substances 2022’
[Link]
Context of reporting – EU F-gas emissions

3% of total EU27 emissions in 2014

Source: Annual European Union greenhouse gas inventory 1990–2021 and inventory report 2023. Submission to the
UNFCCC Secretariat, 15 April 2023. EEA greenhouse gases — data viewer
[Link]
HFC phase-down (under the EU F-gas Regulation)
Data from the past is used as basis for designing a system to allocate HFC quota
Reporting used as basis for tracking progress of the EU HFC phase-down
Reference period 2009-2012
Initial total quota allocation
183.1 Mt CO2e in 2015
(baseline)
EU-wide placing on the
market (POM) of HFCs in
2021 was 4 % below the
market limit.

Source: EEA indicator ‘Hydrofluorocarbon phase-down in Europe’

[Link]
HFC phase-down (EU27 under the Montreal Protocol)
Reporting used as basis for tracking progress of the Montreal Protocol HFC phase-down
1st Kigali Amendment HFC submission
in 2020 on transactions for 2019

Reference period 2011-2013

Initial total quota allocation
184.2 Mt CO2e (baseline)
In 2021 the HFC consumption
went down from 79.4 to 59.0 Mt
CO2e compared to 2020 (-26%)
HFC consumption in 2021
amounts to 40% of the limit for
the EU27

Source: EEA indicator ‘Hydrofluorocarbon phase-down in Europe’

[Link]
The European Environment Agency (EEA)
European Environment Agency
• Decentralised EU agency
• ~250 staff
• Provide regular reports on the status of Europe’s
environment ->
[Link]
• Managing environmental reporting across thematic areas
e.g. climate, water, biodiversity, air pollution >100 data
flows
• European Environment Information and Observation
Network (Eionet). Network of 38 countries and ~400
institutions
[Link]

• Elements to consider when establishing a dataflow:

✓ Legislation
✓ Reporting tools and need for IT-development
✓ Data reporting and communication with providers
✓ Data publication
EU F-gas Regulation Article 19 reporting
requirements (I)
• Annual reporting on F-gases is required from companies

HFCphase-down – Producing, importing and exporting of one metric tonne or 100

tonnes CO2e or more (bulk gases)
– Destroying one metric tonne or 1 000 tonnes CO2e or more
– Using 1 000 tonnes CO2e or more as feedstock
– Placing 500 tonnes CO2e or more contained in imported products
and equipment on the market
– Authorised to use HFC quotas (importers of pre-charged equipment)
• By 31 March each year for the previous calendar year (year-1)
EU F-gas Regulation Article 19 reporting
requirements (I)
• Verification by an independent auditor needed for companies placing 10 000

HFCphase-down tonnes CO2e or more of bulk HFCs on the market

• Verification by an independent auditor needed for companies placing 100
tonnes CO2e or more of RAC (refrigeration, air conditioning and heat pump)
equipment containing HFCs on the market
• Information is reported to the EU Commission via the Business Data Repository
(BDR) that is managed by the European Environment Agency (EEA)
Reporting-related responsibilities at different levels
• EU-wide F-gas Portal, including HFC Registry
EU Commission • Manage license/quota system (allocations)

• Design and maintenance of reporting tool

European Environment
• Providing support to reporting companies
Agency (EEA) • Compilation of the annual F-gas reports + MP A7 submissions

• Assist DG Climate Action via F-gas Committee

EU Member States • Market surveillance and custom controls, enforcement
• Reporting on illegal trade

Companies • Annual reporting under F-gas Regulation Article 19

Increase in number of F-gas reporting companies
requirements (I)
Companies
distributed across all
EU Member States
Companies are
mainly from Poland,
Italy, France,
Germany and other
non-EU countries
(mainly from China)
Reporting companies and their activities

Reporters in 2021
• 2213 data reports
• 2377 NIL reports
(no reportable activity)

Number of bulk HFC

importers decreased

Number of equipment
importers stabilised during
the last few years
Non-electronic vs. electronic reporting
Example 1: Non-electronic reporting Example 2: Electronic reporting
Companies report using different data formats Companies report via an electronic webform

Company Company

2 Company 2
Company Company
1
1 3

Company
3

Central Data
Repository

National Reporting National Reporting

Agency (e.g. NOU) Agency (e.g. NOU)
Comparison of reporting data flows: budgetary aspects
Non-electronic reporting Electronic reporting

Company
Company 2 Company
1 3

National Reporting
Agency (e.g. NOU)

 Low investment costs  High investment costs

 High running costs  Low running costs
 Technical personnel have to gather  Once implemented the
and check data for each reporting operational costs are on a
year manageable level

31
Comparison of reporting data flows: communication
Non-electronic reporting Electronic reporting

Company
Company 2 Company
1 3

National Reporting
Agency (e.g. NOU)

 Communication has to take place  All communication with companies

individually can be handled within one central
 No automated communication system (e.g. open source)
with multiple companies

32
Comparison of reporting data flows: data quality
Non-electronic reporting Electronic reporting

Company
Company 2 Company
1 3

National Reporting
Agency (e.g. NOU)

 Data have to be manually digitalised and converted  Data are automatically

into common format gathered in a common format
 Upon data submission, no automated data quality  Numerous automated data quality checks upon data
checks possible submission
 Data quality remains at low level  Reporters can copy previous deliveries
 Manual data handling prone to errors  Possibility to link gathered data
 E.g. reported import / export data can be
33
compared with licensed amounts
 EU F-gas reporting and database system
Electronic reporting
Gradual developement of the reporting system during 10+ years
Companies report via an electronic webform
Data quality
 Data are automatically gathered in a common format
Company  Numerous automated data quality checks upon data
Company 2
1 submission
 Reporters can copy previous deliveries
Company
3  Possibility to link gathered data
 E.g. reported import / export data can be
compared with licensed amounts
Central Data Communication
Repository
 All communication with companies can be handled
within one central system (e.g. open source)
National Reporting
Agency (e.g. NOU)
Database system
 Allow for integration of ODS and HFCs
Reporting system – data flow management

Data flow management

Helpdesk support
• Reporting by companies via electronic webform
Webform • Support by Helpdesk on all issues concerning
reporting
• Communication with companies via email
Automated
Resubmissions (ticketing/management system) →
quality checks
documentation of all correspondence
• Lesson learned -> automatise instead of
Clarifications
individual handling (+4000 companies registered
Manual quality since 2019)
with MS or EU
checks
Commission
EU HFC Registry and F-gas Regulation Article 19 reporting

‘One-stop-shop’ principle for companies and

Database for tracking
stakeholders (e.g. NOUs and chemical inspectors)
placement on the market,
quota allocations and [Link]
transfers
[Link]
Data assessments and reports
F-gases/HFCs:
✓ EEA indicator ‘Hydrofluorocarbon phase-down in Europe’
✓ [Link]
✓ Underlying report ‘Fluorinated greenhouse gases 2022’
✓ [Link]
Ozone-depleting substances
✓ EEA indicator ‘Consumption of ozone-depleting substances’
✓ [Link]
✓ Data viewer ‘Ozone-depleting substances 2022’
✓ [Link]
Thank you very much

Questions or comments very welcome

[Link]@[Link]
Reporting system – how do checks improve the data
quality Repository
I: General checks upon data entry (BDR)
– Do number/text fields contain numbers/text?
Registry
– Are there negative values?
– Do reported stocks match data from the previous reporting year?
II: Checks on business logic
– Size of the company: only big companies should report big amounts
– Commonly used substances
• R134 (GWP100 = 1100) reported → should this be R134a (GWP100 = 1430)?
– Unlikely use types
• e.g. R404A as feedstock
III: Checks considering the company profile
– Use of historical data to assess data plausibility
– In case of implausible reported data: urge reporter to provide explanations
Reporting as basis for compliance checks
I: General checks upon data entry Incentive system
– Do number/text fields contain numbers/text?
– Are there negative values?
– Do reported stocks match data from the previous reporting year? Year 1
allocated HFC
II: Checks on business logic quota
– Size of the company: only big companies should report big amounts
– Commonly used substances Reported
• R134 (GWP100 = 1100) reported → should this be R134a (GWP100 = 1430)? amount is
compliant
– Unlikely use types
• e.g. R404A as feedstock
III: Checks considering the company profile Full access in
year 2
– Use of historical data to assess data plausibility
– In case of implausible reported data: urge reporter to provide explanations
Origin of reporting companies

Companies distributed
across all EU Member
States
Companies are mainly
from Poland, Italy,
France, Germany and
Other non-EU countries
(mainly China)
Institutional arrangements and products
1st Kigali
Amendment
HFC
submission
in 2020
43
 HFC LICENSING, QUOTA AND REPORTING
-TÜRKİYE-

ECEM ERSOY
June 14, 2023
Vienna International Center
OUTLINE
1. Country Profile
2. Legislative background
3. HFC annual reporting
4. HFC licensing
5. HFC quota allocation

45/14
 Country Profile

NOU is located under the Department of Monitoring of

Greenhouse Gas Emissions of the Directorate of Climate Change
under the MoEUCC

46/14
 Country Profile

Türkiye ratified the Vienna Convention and Montreal Protocol in 1991 and
accepted its all amendments.
o On 10 November 2021, Türkiye ratified the Kigali Amendment and
entry into force on 8 February 2022.
HFC Phase-Down Schedule
A5 Group 1 Countries 10%
30%

50%

80%

2024 2029 2034 2039 2044 2049

47/14
 Country Profile

ROAD MAP THROUGH HFC PHASE-DOWN

2022 2024

Publishling New Freeze Year

Regulation on F-gases. HFC Quota Allocation

2021 2023 2029

Ratification of Kigali Annual F-gas Reporting First Reduction – 10%

Amendment Import/Export Licensing

48/14
 Legislative background
REGULATION
➢ Regulation on Substances that Deplete the Ozone Layer - 2017
➢ Regulation on Fluorinated Greenhouse Gases - 2018 (Repealed)
➢ Regulation on Fluorinated Greenhouse Gases – 2022 (New)

COMMUNIQUE
➢ Communiqué on Certification of Natural and Legal Persons Interfering with Equipment
Containing Fluorinated Greenhouse Gases or whose Operation Relies on These Gases –
2020
➢ Communiqués on HFC trades by the Ministry of Trade – 2022/2023

CIRCULAR
➢ Halon Circular - 2017
➢ Circular on Import and Use of Ozone Depleting Substances – 2016
➢ Circular on the Management of F-gases - 2023
49/14
 Legislative background
REGULATION
➢ Regulation on Substances that Deplete the Ozone Layer - 2017
➢ Regulation on Fluorinated Greenhouse Gases - 2018 (Repealed)
➢ Regulation on Fluorinated Greenhouse Gases – 2022 (New)
517/2014 EU
KIGALI
COMMUNIQUE
➢ Communiqué on Certification of Natural and Legal Persons Interfering with Equipment
Containing Fluorinated Greenhouse Gases or whose Operation Relies on These Gases –
2020
➢ Communiqués on HFC trades by the Ministry of Trade – 2022/2023

CIRCULAR
➢ Halon Circular - 2017
➢ Circular on Import and Use of Ozone Depleting Substances – 2016
➢ Circular on the Management of F-gases - 2023
50/14
 Legislative background
Regulation on Fluorinated Greenhouse Gases – 2022 (New)

CERTIFICATION
OF NATURAL LEAK
AND LEGAL CONTROLS
PERSONS

HFC QUOTA
AND LABELLING
LICENSING

ANNUAL RULES AND PLACING ON

REPORTING PRINCIPLES THE MARKET

51/14
 Legislative background
Regulation on Fluorinated Greenhouse Gases – 2022 (New)

ANNUAL HFC QUOTA AND

REPORTING LICENSING

RULES AND
PRINCIPLES

52/14
 Online System

130
Registered Company

70+
Annual Reporting

60+
Licensing
Licensing

Quota
50+
Quota Request
Annual Reporting

53/14
 F-gas Reporting
By 31 March each year, f-gas activities during preceding year shall be reporting through the online system.

• Importer/Exporter Country
• Types of product/equipment
• Amount of product/equipment
• F-gas in product/equipment

• Importer/Exporter Country
• Amount of F-gas

• Types of product/equipment
• Amount of
product/equipment
• F-gas in product/equipment
• Intended use

• Amount of f-gases
• Destruction method
• Waste code

54/14
 HFC Licensing
• Licensing system for import & export of bulk HFCs is activated as of 10 May 2023
• Licensing is required per import & export
• The system is integrated single-window system of Customs Directorates

• NOU reviews and approves/declines applications

• Needed information and documents:
- Import/export countries + country of origin
- Commercial invoice
- Official letter of application
- HFC name and quantity for requested license
- Label
- SDS

55/14
 HFC Licensing

HFC type
- New HFCs list tons CO2e Label SDS
- Recycled HS codes Country
- Reclaimed of Origin
Quantity

56/14
 Licensing, Reporting and Quota Allocation via Online System
OPPORTUNITIES

Digitalization – less paper work CHALLANGES

New application for HFC

importers/exporters/users
Awareness/Knowledge
Easier tracking of obligations dissemination
under the legislation
(quota, licensing and reporting)
Increasing workload/efforts
within transition period

Recording each import/export

to prevent illegal trade

57/14
 HFC Quota

• As of 2024, HFC quota will be allocated for bulk HFC importers

• License system link to allocated quota for each company

• Allocation will be based on grandfathering in tons of CO2eq.

➔ Average imports (2020 + 2021 + 2022)
from declaration through online system and double check with the Ministry
of Trade
➔ 90% of baseline for incumbents + 10% of baseline for new entrants
➔ Efforts on determination of percentages

58/14
THANK YOU !
W W W. İ K L İ M . G O V.T R

W W W. O Z O N T U R K I Y E . C S B . G O V.T R

@TC_İKLİM
Country experiences and
achievements: HFC licensing,
quota system and reporting

Tatjana Boljevic
Environmental Protection Agency
Montenegro
 Relevant legislation

Montreal Kigali
Protocol: October 2006 Amendment On April 23, 2019
ratified the
Montenegro has
Vienna Convention
became a party to
and Montreal
the Kigali
Protocol and four
Amendment
Amendments

63
 National Legislation

Law on the Protection against Adverse Impacts of Climate Change

• (Off Gazz MNE, no. 073/2019)

Regulation on ozone depleting substances and alternative substances (Fgases)

• (Off Gazz MNE, no 079/2021)

Rulebook on the closer manner and necessary documentation for issue permits for
import/export ODS and alternative substances
• (Off Gazz MNE, no 69/2020)

64
Competent authority for issuing permits

2006-2009 • Ministry for environment

2009- today • Environmental Protection Agency (EPA)

65
 ODS LICENSING/QUOTA SYSTEM

• ODS licensing system (CFC, HCFC, others)

2004

• Quota for ODS/CFC was established in 2007 by Government decision as a new Party to the Montréal
Protocol in 2007 was prepared and approved CP, TPMP, IS
2007

• Quota for HCFC (HPMP stage I, 2011-2020)

2011

66
 HFC LICENSING/QUOTA SYSTEM

2011
• Licencing system for import/export of HFC was established

2021
• HFC phase down schedule in accordance with the Montreal
protocol provision for A5 group 1 country;
• Quota system for HFC is prescribed and will start from 1 January
2024 (first control measure), will be in tones CO2eq;

67
 Steps before import/export HCFC/HFC

◈ Importer of HCFC/HFC submits an application, for setting annual quota, to the

Agency until 1st December of the current year for the next year.

◈ The annual import quota is determined by the Agency based on the share in the
total amount of imported substances in the period of base consumption.

◈ A quota in the amount of 10% of the total annual quota is determined for legal
entities (importers) who imports HCFC/HFC for the first time.

◈ Annual quota for HCFC is in Mt, and for HFC is in tones CO2eq;

◈ Permits for imports and exports of HCFC/HFC are issued for each shipment
68
separately
 Documentation for import/export

Application for import and / or export permit contain data on:

1) applicant (name and surname, identification number, address, telephone..)
2) substances, for each substance individually:
name of the substance (chemical name and trade mark);
tariff code;
quantity of the substance expressed in unit of measure;
name of the country of import or export of the substance;
name of the country of origin of the substance;
substance manufacturer.
69
 …documentation…

The application for import/export shall be accompanied by the following documentation:

proof of entry in the Central Register of Business Entities;
invoice or proforma invoice of the supplier;
notification of the border crossing at which the import / export will take
place;
notification on the purpose of import / export;
notification of end users;
safety data sheet for the substance;
a statement that the storage of the substance is carried out in
accordance with the safety data sheet for the given substance;
proof of payment of the administrative fee; 70
 Reporting system

Reporting on import/export of HCFC/HFC:

importer /exporter are obligated to submit Agency:
• a proof of imported or exported amounts of ODS / HFC substances (Unified Customs
Document) within the three days after the imports or exports of such substances is
realized.
• yearly report on import/export of HCFC/HFC (until 31st January current year, for
previous year)

New provision introduced in 2021 :

• reporting on import/export of equipment containing HFC
substances (pre loaded equipment) 71
 New tariff codes in 2022

Controlled ASHRAE Chemical

Chemical name HS Code
Substance designation formula
HCFC-22 R-22 chlorodifluoromethane CHF2Cl 2903 71 00 00

HFC-134a R-134a 1,1,1,2-tetrafluoretan CH2FCF3 2903 45 00 00

HFC-32 R-32 difluorometan CH2F2 2903 42 00 00

Mixture R-125 (44.0%)/R- 143a (52.0%)/R -134a
R-404A R-404A 3827 61 00 00
(4.0%)
R-407C R-407C Mixture R-32 (23.0%)/R-125(25.0%)/R-134a (52.0%) 3827 64 00 00

R-410A R-410A Mixture R-32 (50%)/R-125(50%) 3827 63 00 00

R-507A R-507A Mixture R-125(50.0%)/R-143a (50.0%) 3827 61 00 00

72
THANK YOU!

73
For possible consideration…

• Time-stamp (calendar year or allocated in xx year periods) “use it or lose it”

• HFC registry (electronic tool for quota allocation)
• Incumbents/new comers; percentage of quota *
• Prohibitions vs. phase-down (quota system) **
• Quota exceedance and penalties
• Quota exemptions ***
• Fees (free, auctioning, etc.)
• Could be accompanies by other measures ****
Decisions, decisions, decisions…
• HFC phase-down steps
• Quota distribution
• Treatment of equipment imports
• Licensing system*
• Accompanying measures?
• Country’s annual HFC import quotas expressed in tons of CO2 eq.
must be included in country’s legislation
• “Placing on the market” has to be defined in the national legislation
in order to avoid confusion**
• Awareness raising