ROHS Compliance

Since the implementation of the new Fluorinated Greenhouse Gases Regulation (EU) 2024/573 on March 11, 2024, reporting thresholds have been lowered and corporate compliance obligations have increased compared to the previous framework. 

Key updates include: 

  • Annual Reporting (from 2025):  

  • Producers and importers of HFCs (regardless of tonnage) or other fluorinated greenhouse gases exceeding 1 tonne or 100 tonnes CO₂ equivalent must submit annual reports by March 31.  

  • Equipment manufacturers placing pre-charged HFCs above 10 tonnes CO₂ equivalent, or other fluorinated gases above 100 tonnes CO₂ equivalent, on the market must also report annually by March 31.  

  • Audit Requirements (from 2025):  

  • By April 30 each year, producers or importers placing HFCs exceeding 1,000 tonnes CO₂ equivalent on the market must submit an audit report along with their annual report.  

  • Importers of equipment containing pre-charged HFCs above 1,000 tonnes CO₂ equivalent (not previously placed on the market before charging) must also submit an audit report by April 30.  

  • F-gas Portal Registration:  

  • All importers and exporters of F-gas-related products are required to register on the official F-gas Portal. Around 2,000 new companies register each month, many of which are small car dealers handling vehicles with F-gas-based air conditioning systems.  

Proposed Policy Developments 

  • The European Parliament has supported introducing a new category of Small-Medium Companies (SMCs), extending certain SME exemptions to avoid a sharp increase in compliance obligations once companies surpass SME thresholds.  

  • Proposed SMC definition: companies with fewer than 1,000 employees and either turnover up to €200 million or total assets up to €172 million (higher than the European Commission proposal).  

  • The proposal emphasizes continued prioritization of SMEs and periodic review of thresholds every five years.  

  • The Commission has also proposed raising the F-gas Portal registration threshold for SMCs. Under this, only:  

  • Equipment manufacturers exceeding specified CO₂ equivalent thresholds, or  

  • Exporters of restricted products 
    would be required to register.  

  • The amendment was approved by key parliamentary committees with strong majority support, and negotiations proceeded following no objections during the March 9–12 plenary session.  

Expected Impact 

  • If adopted, the proposal could exempt approximately 10,000 companies from F-gas Portal registration requirements in 2026 alone, significantly reducing the administrative burden on smaller businesses.