F-Gas Regulation, vehicle import, refrigerant R12, refrigerant R134a, refrigerant R1234yf, CO₂ equivalent, customs declaration, proof of disposal, F-Gas Portal

Regulation (EU) No. 517/2014, known as the F-Gas Regulation, governs the import of vehicles with fluorinated refrigerants such as R12, R134a, and R1234yf to reduce the emission of climate-damaging gases. This article explains what private individuals and commercial importers must consider to comply with the law.

1. Refrigerant R12: Import Ban and Legal Consequences

The import and transportation of classic cars with an air conditioning system that requires refrigerant R12 is illegal. It does not matter:

• whether the air conditioning system is operational or defective,

• whether it could be converted to another refrigerant using an adapter in the domestic market,

• whether the refrigerant has already been removed and the system cleaned.

In all cases, this constitutes a violation of the Chemicals Act and the Chemical Sanctions Ordinance. The import of such vehicles also qualifies as smuggling, a customs offense.

Recommendations for Action
Economic operators in the supply chain are required to correctly declare vehicles with R12 air conditioning systems in customs declarations, as they are subject to bans and restrictions.

To import a vehicle legally, either the air conditioning system must be converted in the country of departure, or it must be removed entirely.

For further details, see: Warning Notice on the Import of Classic Cars.

2. Requirements for Refrigerant R134a

• Private individuals: When importing, private individuals must declare R134a without having to specify the net mass or CO₂ equivalent.
• Commercial importers: Commercial importers must register in the F-Gas portal. They must also specify the net mass of the refrigerant and the CO₂ equivalent value (calculated from GWP 1,430) in the customs declaration.

3. Reporting Requirements for R1234yf from 2025

From 2025, extended requirements for the refrigerant R1234yf must be observed:

• Private individuals: From January 2025, private individuals must declare the presence of R1234yf during customs clearance. Net mass and CO₂ equivalent do not need to be specified here.
• Commercial importers: Commercial importers must also be registered for R1234yf and specify the net mass and CO₂ equivalent.

What to Do If No Labeling Is Present?

If the vehicle has no labeling in the engine compartment (as is often the case with vehicles potentially containing R12), this does not mean that no declaration is necessary. In such cases, customs might require proof of disposal. It is always important to ensure that correct information about the refrigerant is provided.

What Happens in Case of Incorrect Information?

Incorrect or incomplete information, such as stating that no air conditioning system exists when one does, can have serious consequences. Customs can order an inspection. If it is discovered that the information was incorrect, delays, additional fees, or even legal consequences may result. Correct declaration helps avoid such problems.

Example: Calculating the CO₂ Equivalent for Refrigerants

Sample calculation for a vehicle with 0.5 kg R1234yf:

CO₂ equivalent = 0.5 kg × 0.501 = 0.2505 tons CO₂ equivalent

This information must be complete and correct in the customs declaration to avoid delays.

Conclusion

The F-Gas Regulation requires clear information for vehicle imports to protect the environment and secure customs processes. From 2025, declaring R1234yf will also be mandatory for private individuals, and commercial importers will remain obligated to provide detailed information and register in the F-Gas portal.