HVAC/R Market Strategy · September 2026
Since 2025, receiving an allocation of HFC quota in Europe has cost €3 for each tonne of CO₂ equivalent. The payment does not buy refrigerant: it secures the regulatory capacity to place HFCs on the European market.
By Michele Cadoni · European Market Entry & Distribution Strategy Partner
Since 2025, receiving an allocation of HFC quota in the European Union has had an explicit price: €3 for each tonne of CO₂ equivalent allocated.
This payment does not purchase refrigerant. It is the amount due to receive the regulatory capacity to place a defined quantity of HFCs on the European market.
The €3 charge therefore makes explicit the initial value of a regulatory capacity whose economic significance extends beyond the allocation process.
The F-Gas quota system does not only reduce the volume of HFCs entering Europe. It also shapes the conditions and costs of accessing the market.
The HFC phase-down is not new. The previous F-Gas Regulation already established a progressively declining ceiling for HFCs placed on the European market.
Regulation (EU) 2024/573 added a new element. From 2025, annual quota allocation became subject to a payment of €3/tCO₂e, with the possibility of future adjustment for inflation.
The Regulation recognises that quota already has a market value. Charging for allocation gives an official price to a regulatory capacity that could previously be assigned free of charge and then acquire value through private transactions.
A producer or importer can pay for all or only part of the maximum allocation offered. Until the end of 2027, unpaid quota can still be redistributed under specified conditions among operators that paid their offered allocation in full and submitted the required declaration. From 2028, the decision not to pay will remove that capacity from the annual market because unpaid quota will instead be cancelled.
The European ceiling is not expressed in tonnes of refrigerant. It is expressed in tonnes of CO₂ equivalent.
The physical quantity of an HFC is multiplied by its global warming potential. One tonne of R32, with a GWP of 675, consumes 675 tonnes of CO₂-equivalent quota. One tonne of R410A, with a GWP of 2,088, consumes 2,088 tonnes.
The same quota capacity can therefore support very different physical volumes depending on the refrigerant selected. Higher-GWP products consume more of a resource that is becoming progressively more limited.
For 2025 and 2026, the European ceiling is 42,874,410 tCO₂e. It falls to 21,665,691 tCO₂e for 2027-2029, a reduction of almost 50%, and then to 9,132,097 tCO₂e for 2030-2032. The scheduled ceiling reaches zero from 2050.
This does not mean that the physical quantity of every HFC will fall at the same rate. The market can respond through lower volumes, lower-GWP refrigerants and technologies that no longer depend on quota-controlled HFCs.
The phase-down therefore acts both on supply and on product selection. The GWP of a portfolio increasingly determines how efficiently an importer can use its available market-access capacity.
The European Commission allocates quota annually to eligible HFC producers and importers through the F-Gas Portal.
For established operators, the starting point is a reference value, calculated from the average quantities of HFCs lawfully placed on the market during the relevant previous years. Reference values are recalculated at least every three years, allowing more recent activity to enter the system.
The reference value is not the annual allocation itself. The allocation mechanism applies the declining European ceiling to that historical position. Under the current system, 89% of the relevant reference value forms the basis of the calculation for established operators, adjusted according to the maximum quantity available for the year concerned.
An established position therefore provides continuity, but it does not guarantee a fixed volume. As the European ceiling contracts, the capacity generated by that reference value also decreases.
The framework also maintains a reserve for producers and importers that submit the required declaration through the Portal. This gives companies without an established reference value a route into the system and allows existing operators to seek additional capacity.
The reserve consists of the volume remaining after allocations based on reference values have been deducted from the annual ceiling. It is shared among the undertakings that submitted valid declarations.
Access is therefore possible, but the available quantity depends on the residual volume and the number of applicants. A new entrant can identify demand and secure a distributor without knowing whether ordinary allocation will support the intended import volume.
This is the first point at which quota becomes a market-entry issue. Commercial opportunity does not automatically create the regulatory capacity required to supply it.
An operator whose allocation does not cover its intended bulk-HFC volumes may seek additional quota from another quota holder.
Regulation (EU) 2024/573 allows a producer or importer with an established reference value to transfer all or part of its allocation to another eligible producer or importer. The transaction must be recorded and accepted through the F-Gas Portal. Once transferred, the quota cannot be transferred a second time.
The Regulation creates the legal mechanism, but the commercial conditions are agreed between the parties. Quota can therefore acquire a private-market value separate from the physical refrigerant.
A company may be able to purchase gas outside the European Union but remain unable to place it legally on the EU market without sufficient quota. Another operator may hold capacity that it does not intend to use and transfer it.
Market access consequently depends on two separate availabilities: the physical product and the regulatory capacity covering it.
HFCs contained in imported pre-charged refrigeration, air-conditioning and heat-pump equipment are also included in the phase-down, but through a different route.
The equipment importer does not require a transfer of bulk-HFC quota. It needs an authorisation to use quota from an eligible quota holder. This prevents the refrigerant contained inside finished equipment from bypassing the European ceiling.
An authorisation may also be delegated once:
quota holder → authorisation recipient or manager → equipment importer
A delegated authorisation cannot be delegated again. The transaction becomes valid only when accepted through the F-Gas Portal, and sufficient authorisation must be available before the equipment is released for free circulation.
The Commission's guidance also recognises a specific manager-of-authorisations role. This means that the company managing regulatory access may not be the commercial distributor or even the importer itself.
This creates a form of authorisation dependency within the route to market. A manufacturer may have one company providing or managing the authorisation, another importing the equipment and a third distributing it.
Changing a commercial distributor may leave the regulatory chain intact if the importer remains unchanged. Replacing a distributor that is also the importer can require a new authorisation arrangement, customs process and reporting structure.
For pre-charged equipment, quota access therefore becomes part of distribution architecture rather than a compliance formality added after the channel has been selected.
The European Commission's Q1 2026 monitoring survey reported an average purchase price of approximately €17.19/tCO₂e for quota authorisations, 7% above Q4 2025 and 5% above Q1 2025.
During the same period, respondents described the European refrigerant market as broadly stable in terms of supply, apart from isolated regional constraints.
This combination is significant. The value of regulatory access was increasing before a general shortage of physical product had become visible.
The €17.19 figure must not be presented as the resale price of quota allocated for €3. The two amounts refer to different operations. The comparison is useful because it shows the difference between an official allocation charge and the value that access can acquire within a private authorisation relationship.
GWP determines the impact on the equipment concerned. At €17.19/tCO₂e, the authorisation corresponding to one kilogram of R32 represents approximately €11.60. For one kilogram of R410A, it represents approximately €35.90.
These amounts are not the price of the refrigerant and are not necessarily passed through the supply chain unchanged. They show how a price expressed in CO₂ equivalent places a heavier economic burden on equipment using a higher-GWP refrigerant.
The near-halving of the European ceiling from 2027 represents the next major pressure point. Its effects will depend on how rapidly equipment and servicing demand move towards lower-GWP alternatives and quota-free technologies.
Several market consequences are likely.
Demand for transfers and authorisations may increase as ordinary allocations contract. Established quota holders could gain greater strategic weight, not only as suppliers of gas but also as providers of regulatory capacity.
The GWP of product portfolios will become more decisive. Lower-GWP products allow a given quota volume to support a larger physical quantity, while high-GWP strategies consume capacity more rapidly and become more exposed to access costs.
New entrants may face particular pressure. A competitive product and an interested distributor will not be sufficient if the import structure cannot secure quota or authorisations over the full market-development period.
Reclaimed refrigerants should also gain importance in servicing the installed base. Reclaimed HFCs are not subject to the placing-on-the-market quota in the same way as virgin material. Collection, treatment and redistribution capacity will therefore become part of market resilience as virgin quota contracts.
These developments will not be determined by quota alone. Equipment prohibitions, safety, installer competence, technological development and market acceptance will continue to influence the transition. Quota acts alongside them by limiting volume and pricing regulatory access.
For manufacturers introducing HFCs or pre-charged equipment into Europe, quota cannot be treated as a final customs check after the commercial strategy has been decided.
The company must determine which mechanism applies, who holds or provides the required capacity, how secure that access is over time and how its cost affects the product's position.
The manufacturer, quota holder, importer and distributor may be different entities. Their roles and dependencies must be mapped before volumes begin to move.
The €3 allocation charge makes the initial regulatory price visible. The market value of quota transfers and authorisations shows that the economics of access extend beyond that amount.
As the European ceiling contracts, the quota system will increasingly determine which products, operators and supply structures can remain viable.
It is not simply reducing HFC supply. It is progressively restructuring the conditions for participating in the European market.