New compliance and audit requirements for F-Gas equipment in the EU

The European Union continues its legislative progress towards the reduction of emissions and the strict control of substances that deplete the ozone layer and contribute to global warming. The Official Journal of the European Union has recently published the Implementing Regulation (EU) 2025/2155 of the Commission of October 23, 2025.

The objectives of this Implementing Regulation are to demonstrate compliance with the quota regime referred to in Chapter IV of Regulation (EU) 2024/573 on Fluorinated Gases, to specify the different types of documents required for importers and manufacturers to reflect the different types of activities carried out by their companies and to establish a list of documents that importers and manufacturers must keep.

It also provides guidance for third-party verification of the declaration of conformity and documentation and determines the scope of verification by an independent auditor.

It is important to mention that within Annex I of this new Implementing Regulation there is a standard declaration of conformity to unify the way of demonstrating that the hydrofluorocarbons introduced contained in the products placed on the market are included in the quota system referred to in the Fluorinated Gases Regulation. 

In order to provide sufficient time for importers and manufacturers to comply with the new rules, this new Implementing Regulation provides that declarations of conformity established under the previous Implementing Regulation (EU) 2016/879, repealed with this new Implementing Regulation, remain valid until the December 31, 2025.

This Regulation came into force twenty days after its publication in the Official Journal of the European Union on November 13, 2025, and will be applicable as of that date.

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