New Environmental Import/Export Controls on HFCs in Hong Kong
- mdatiknawaz
- Dec 1, 2025
- 11 min read
1. The Global and Local Context for HFC Regulation
Hong Kong is introducing a comprehensive new regulatory framework to control the trade and use of hydrofluorocarbons (HFCs). This action is not occurring in isolation; it is a critical part of a coordinated global effort under the Montreal Protocol's Kigali Amendment to combat climate change by phasing down these potent greenhouse gases. This document serves as a comprehensive guide for businesses to understand the drivers behind these changes, the specific legal requirements being implemented, and the necessary steps to ensure compliance and a smooth transition to sustainable alternatives.
The international impetus for HFC regulation stems from a successful, yet incomplete, environmental transition. Initially, HFCs were adopted as a replacement for chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), which were phased out by the original Montreal Protocol for their damaging effect on the stratospheric ozone layer. While HFCs are harmless to the ozone layer, it was subsequently discovered that they are powerful greenhouse gases with a high Global Warming Potential (GWP), trapping thousands of times more heat in the atmosphere than carbon dioxide. This realization led to the Kigali Amendment to the Montreal Protocol in 2016, a legally binding international accord designed to mandate the progressive phasedown of HFCs. The successful implementation of this amendment is projected to avoid up to 0.5 degrees Celsius of global warming by the end of the century.
In response, Hong Kong is implementing its international obligations through the Ozone Layer Protection (Amendment) Ordinance 2025, which was introduced as the 2024 Amendment Bill and amends the existing Ozone Layer Protection Ordinance (Cap. 403) to create the legal basis for HFC controls. By taking these measures, Hong Kong aligns its environmental standards with other developed economies, strengthens its contribution to international climate goals, and supports its own target of achieving carbon neutrality. The new framework establishes a clear timetable, enabling the trade and relevant industries to adjust their operations and reduce their reliance on high-GWP HFCs in an orderly manner.
This legislative action sets the stage for a three-pronged control strategy designed to manage HFCs across their entire lifecycle.
2. Hong Kong's Three-Pronged HFC Control Strategy
The Hong Kong government's approach to HFC regulation is strategically multi-faceted, targeting these substances at every stage of their local lifecycle. By implementing controls on import and export, regulating the supply of new equipment at its source, and mandating the responsible handling of refrigerants at their end-of-life, this strategy ensures a comprehensive and orderly transition away from high-GWP chemicals and toward more sustainable alternatives.
2.1 Control Strategy 1: Licensing and Quota System for Imports and Exports
The cornerstone of the new regulations is a robust system to control the volume of HFCs entering the local market. Starting December 1, 2025, a licensing and quota system will be implemented for the 18 scheduled HFCs. This strategy is designed to meet the legally mandated phasedown targets established under the Kigali Amendment.
For businesses, this introduces direct operational requirements. Any person or company intending to import regulated HFCs for local consumption must first hold a valid import quota allocated by the Environmental Protection Department (EPD). Furthermore, a specific import license must be applied for and granted for each consignment of HFCs.
The quota will be allocated to manage the transition for both established businesses and new market participants. Quotas will be divided into two categories in a 7:3 ratio: "normal quota," allocated to existing importers based on their historical market share, and "free quota," reserved for new entrants or for existing importers who have already used their normal quota allocation for the year.
Several key exceptions and specific prohibitions are built into this system:
Local Manufacturing: The local manufacture of any of the 18 scheduled HFCs is prohibited.
Re-export: Scheduled HFCs that are imported into Hong Kong solely for the purpose of re-export are exempt from the quota system. However, these shipments still require a valid license to ensure proper tracking and supervision.
HFC-23: The import of HFC-23, an HFC with an extremely high GWP of 14,800, will be fully banned. Limited exemptions will be granted for essential uses, such as maintaining existing ultra-low temperature refrigeration systems and for specific laboratory research purposes.
2.2 Control Strategy 2: Regulation of Products and Equipment (P&Es)
To complement the control of bulk HFC imports, the second strategy aims to drive down local HFC consumption at the source by restricting the supply of new equipment that relies on high-GWP refrigerants. This measure encourages the market to shift toward technologies that use lower-GWP alternatives, aligning consumer and commercial purchasing decisions with Hong Kong's environmental goals.
The regulations will prohibit the manufacture, import, sale, and supply of specified "Regulated HFC Products" that contain or are designed to operate on refrigerants exceeding prescribed GWP limits. These prohibitions will be implemented progressively, with the first wave of restrictions taking effect from mid-2026. This phased approach provides the industry with sufficient time to adapt supply chains and clear existing stock of affected equipment. Importantly, these controls do not apply to second-hand equipment or to the import, manufacture, and supply of parts and components needed for repairing and maintaining existing P&Es.
2.3 Control Strategy 3: Mandated Refrigerant Recovery and Handling
The final prong of the strategy focuses on responsible end-of-life management to prevent the release of HFCs into the atmosphere. This approach serves a dual purpose: it directly mitigates climate impact by preventing the venting of potent greenhouse gases and helps create a stock of recycled refrigerants that can be used to service existing equipment during the phasedown period, reducing the demand for new HFC imports.
Taking effect in Q4 2026, this strategy introduces several core requirements for owners and handlers of large-scale equipment:
Mandatory Recovery: The recovery of HFC- and ozone-depleting substance (ODS)-containing refrigerants and fire suppressants from "Regulated Equipment" will be mandated. The intentional venting of these substances will be prohibited.
Regulated Equipment Thresholds: "Regulated Equipment" is defined as:
Air-conditioning or refrigeration equipment with a refrigerant charge over 50 kg.
Fire extinguishing equipment with a fire suppressant charge over 30 kg.
Registration & Certification: A mandatory registration scheme will be introduced for owners of Regulated Equipment. Additionally, contractors handling these refrigerants or fire suppressants must be registered, and individual technicians performing the handling work must complete specified training and obtain certification.
Safety Guidelines: Recognizing that many low-GWP alternatives may have different safety profiles, the new regulations will stipulate clear handling guidelines. This is crucial as popular low-GWP alternatives like R32 are classified as mildly flammable, while others like propane (R290) are highly flammable, requiring new risk management protocols for technicians and property managers.
To ensure compliance, businesses must first understand precisely which substances and equipment fall under these new controls.
3. Scope: Controlled HFCs and Regulated Equipment
For businesses to achieve full compliance, it is essential to have absolute clarity on which specific substances and product categories fall under the new regulations. This section provides the definitive reference tables based on the schedules and annexes of the Ozone Layer Protection (Amendment) Ordinance 2025 and its associated legislative brief.
Table 1: The 18 Scheduled HFCs and their 100-Year Global Warming Potential (GWP)
Substance (Chemical Name) | 100-Year GWP |
HFC-134 (CHF2CHF2) | 1,100 |
HFC-134a (CH2FCF3) | 1,430 |
HFC-143 (CH2FCHF2) | 353 |
HFC-245fa (CHF2CH2CF3) | 1,030 |
HFC-365mfc (CF3CH2CF2CH3) | 794 |
HFC-227ea (CF3CHFCF3) | 3,220 |
HFC-236cb (CH2FCF2CF3) | 1,340 |
HFC-236ea (CHF2CHFCF3) | 1,370 |
HFC-236fa (CF3CH2CF3) | 9,810 |
HFC-245ca (CH2FCF2CHF2) | 693 |
HFC-43-10mee (CF3CHFCHFCF2CF3) | 1,640 |
HFC-32 (CH2F2) | 675 |
HFC-125 (CHF2CF3) | 3,500 |
HFC-143a (CH3CF3) | 4,470 |
HFC-41 (CH3F) | 92 |
HFC-152 (CH2FCH2F) | 53 |
HFC-152a (CH3CHF2) | 124 |
HFC-23 (CHF3) | 14,800 |
Table 2: Regulated HFC Products, GWP Limits, and Effective Dates
Category of Regulated HFC Product | GWP Limit | Effective Date for Prohibition of Import or Manufacture | Effective Date for Prohibition of Supply |
1. Household air-conditioner (See Note 4) | 750 | 1 July 2026 (See Note 1) | To be determined (See Note 6) |
2. Household refrigerator or household freezer (or combination of both) | 150 | 1 July 2026 (See Note 1) | To be determined (See Note 6) |
3. Commercial stand-alone refrigeration equipment (See Note 5) | 150 | 1 July 2026 (See Note 1) | To be determined (See Note 6) |
4. Commercial condensing unit refrigeration system | 1500 | 1 July 2026 | |
5. Commercial multipack centralised refrigeration system | 1500 | 1 July 2026 | |
6. Cold storage warehouse refrigeration system | 1500 | 1 July 2026 | |
7. Air-cooled chiller (for comfort cooling) | 750 | 1 July 2026 (See Note 1) | See Note 2 |
8. Water-cooled chiller (for comfort cooling) | 750 | 1 July 2026 (See Note 1) | See Note 2 |
9. Fire extinguishing installation | 15 | 1 July 2026 | |
10. Private car air-conditioner | 150 | Manufacture year 2029 |
Notes:
Category 1, 2, 3, 7 and 8 will be exempted from the prohibition of import if the supply agreement has already been entered into before the commencement of the regulation.
Subject to the same condition set out in item (1) above, Category 7 and 8 will also be exempted from the prohibition of supply.
The prohibition of supply will not apply to second-hand P&Es, i.e. those already owned by a local end user. Import, manufacture and supply of parts and components that are used for repairing and maintenance of existing P&Es are also not subject to control.
Category 1 refers to single package window type or single split type air-conditioner that has a rated cooling capacity not exceeding 7.5 kilowatts.
Category 3 refers to a self-contained plug-in refrigeration equipment, which is designed to be installed in premises other than domestic premises. It includes refrigerator, freezer, vending machine, ice machine, display cabinet, and semi plug-in waterloop system.
Category 1, 2 and 3 are widely used in households, offices, retail stores or restaurants. To minimize impacts brought to the trade and the market, we will continue to monitor the market development and work with the suppliers on the way forward for these products.
4.0 Hong Kong's HFC Consumption Phasedown Schedule
The new controls on HFCs are not a one-time measure but are part of a long-term, legally mandated reduction plan that aligns Hong Kong with its obligations under the Kigali Amendment. Understanding this schedule is critical for strategic business planning, investment in new technologies, and ensuring a successful transition to sustainable, low-GWP alternatives over the coming decade.
Hong Kong's baseline for HFC consumption has been established at 1,682 kilotonnes of CO2 equivalent. All future reduction targets are calculated as a percentage of this baseline figure. The ultimate goal is to reduce HFC consumption by 85% by 2036. The following table outlines the specific, legally binding consumption limits for each period.
Hong Kong's HFC Phasedown Schedule
Period | Maximum Consumption Level (% of Baseline and Kilotonnes CO₂e) |
Baseline | 100% (1,682 kilotonnes CO₂e) |
2024–2028 | 60% of baseline (1,009 kilotonnes CO₂e)* |
2029–2033 | 30% of baseline (504 kilotonnes CO₂e) |
2034–2035 | 20% of baseline (336 kilotonnes CO₂e) |
2036 and thereafter | 15% of baseline (252 kilotonnes CO₂e) |
*This figure is based on the Legislative Council Brief (Annex D). Note that some government press releases may cite a slightly different figure for the initial 2025-2026 quota period; this schedule reflects the official long-term phasedown targets.
Adherence to this schedule is mandatory, and failure to comply with the associated import quotas and other control measures will result in significant legal consequences.
5. Compliance, Penalties, and Enforcement
The Hong Kong government considers the implementation of the HFC phasedown a serious regulatory priority. Non-compliance with the provisions of the amended Ozone Layer Protection Ordinance carries significant financial and legal penalties designed to act as a strong deterrent. Enforcement will be a coordinated effort involving multiple government departments to ensure comprehensive oversight.
The following table summarises the key offences under the new regulations and their proposed maximum penalties.
Key Offences and Maximum Penalties
Offence | Proposed Maximum Penalty |
Manufacturing scheduled HFCs | Fine of $1,000,000 and imprisonment for 2 years. For a continuing offence, a further fine of $100,000 per day. |
Importing or exporting scheduled HFCs without a license | Fine of $1,000,000 and imprisonment for 2 years. |
Importing, manufacturing, or supplying Regulated HFC Products that exceed the prescribed GWP limit | Fine of $1,000,000 and imprisonment for 2 years. |
Causing the release of HFCs/ODSs from Regulated Equipment | Fine of $200,000 and imprisonment for 6 months. For a continuing offence, a further fine of $10,000 per day. |
Undertaking refrigerant/fire suppressant handling work on Regulated Equipment without being a registered handler | Fine of $200,000 and imprisonment for 6 months. For a continuing offence, a further fine of $10,000 per day. |
Owner of Regulated Equipment failing to register the equipment with EPD | Fine of $50,000. |
Owner of Regulated Equipment failing to engage registered handlers | Fine of $200,000 and imprisonment for 6 months. For a continuing offence, a further fine of $10,000 per day. |
An interdepartmental task force will carry out enforcement. The Environmental Protection Department (EPD) will manage the licensing, quota, and registration systems. The Electrical and Mechanical Services Department (EMSD) will oversee the technical and safety aspects of refrigerant handling, including technician certification. The Customs and Excise Department (C&ED) will be responsible for inspections at border control points to prevent illegal import and export of controlled substances and products.
These strict penalties and coordinated enforcement underscore the need for businesses to take proactive steps to ensure compliance.
6. Industry Transition and Stakeholder Perspectives
The transition away from high-GWP HFCs presents both challenges and opportunities for industry. While the new regulations impose clear compliance burdens, they also drive innovation, align businesses with growing market demand for sustainable technologies, and support Hong Kong's long-term environmental and economic competitiveness. Industry consultation has been a key part of the legislative process, and stakeholder feedback has helped shape the final framework.
Major industry bodies, such as the American Chamber of Commerce in Hong Kong (AmCham HK), have expressed strong support for the government's proposals. AmCham HK agrees with the core strategies, including the implementation of an import quota system that caters to both existing and new importers, the progressive ban on high-GWP equipment, the certification requirements for technicians, and the mandate for refrigerant recovery. This support reflects a broader industry understanding that these measures are necessary and align with global best practices.
During the consultation process, stakeholders also raised several important recommendations and concerns aimed at ensuring a smooth and effective transition:
Public Education: A strong need was identified to educate the general public on the meaning and importance of GWP. This would empower consumers to make informed purchasing decisions and build market support for low-GWP products.
Scope of Controls: It was suggested that transitional measures should be expanded to prevent Hong Kong from becoming a "dumping site" for outdated, high-GWP equipment being phased out in other markets. Stakeholders also recommended that the government consider extending mandatory recovery requirements to fire suppressants used in large firefighting systems.
Incentives: To accelerate the transition, it was proposed that existing government and power company incentives for energy efficiency be extended to cover the adoption of low-GWP alternatives. This could provide a financial catalyst for businesses and consumers to upgrade their equipment ahead of regulatory deadlines.
The alignment between industry recommendations and the government's phased approach suggests that businesses should view public education and incentive programs not just as support mechanisms, but as key market drivers that will influence customer demand for compliant, low-GWP technologies.
7. Conclusion: Key Dates and Actions for Businesses
The phasedown of HFCs in Hong Kong is a non-negotiable regulatory shift that requires the immediate attention and proactive engagement of all affected businesses. Waiting for deadlines to approach is not a viable strategy. Companies involved in the import, export, sale, installation, and servicing of air-conditioning, refrigeration, and fire suppression systems must act now to understand their obligations, adapt their operations, and plan for the future.
Critical Timeline and Required Actions
Immediate Action (Now - October 17, 2025): Eligible importers must apply for the 2025-2026 HFC import quota. Applications must be submitted to the EPD via its online system or in hard copy by the strict deadline.
Effective December 1, 2025: The HFC import/export licensing and quota system comes into force. From this date, all shipments of the 18 scheduled HFCs will require a valid license to enter or leave Hong Kong, and imports for local consumption must be covered by a quota.
From July 1, 2026: Prohibitions on the import and manufacture of the first wave of regulated products and equipment (e.g., household air-conditioners, chillers, commercial refrigeration systems) that exceed their prescribed GWP limits will begin to take effect.
By Q4 2026: The mandatory refrigerant management system becomes effective. Owners of large-scale "Regulated Equipment" must register their systems with the EPD. Technicians and contractors who handle refrigerants must be registered and certified. The legal requirement to recover HFCs and the prohibition on intentional venting will be in full force.
By taking decisive action now, businesses can navigate this transition smoothly, maintain a competitive edge, and play a vital role in building a more sustainable future for Hong Kong. Proactive engagement with these new regulations is essential for ensuring operational continuity, avoiding significant penalties, and contributing to Hong Kong's critical environmental goals.
Comments