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China HFO Regulations

China’s HFO import rules are shaped by its dual goals of phasing down high-GWP refrigerants under the Kigali Amendment and promoting low-carbon alternatives. 

1. Regulatory Frame Work

  • ODS Regulation: Governed by the Regulation on the Management of Ozone-Depleting Substances(ODS Regs), though HFOs (with near-zero ODP) face fewer restrictions than HFCs.

  • HFC Import Quotas: While HFOs aren’t directly quota-controlled, imports are monitored under broader fluorochemical regulations (e.g., Measures for HFC Import/Export Management, 2021).

2. Key Requirements

  • Approval from MEE: Importers must register with the Ministry of Ecology and Environment (MEE) and obtain permits for fluorinated chemicals.

  • HS Codes: HFOs fall under HS Code 2903.39 (“fluorinated derivatives of acyclic hydrocarbons”).

  • Documentation:

    • Proof of GWP (< 150 for many applications).

    • Safety Data Sheets (SDS) compliant with Chinese standards (GB/T 16483).

    • Certificates of origin and environmental compliance.

3. Bans & Restrictions

  • High-GWP Blends: HFOs mixed with HFCs (e.g., R-448A) may face scrutiny under HFC phase-down rules.

  • Customs Inspections: Random checks for undeclared/restricted substances.

4. Compliance Steps

  • Register with MEE’s HFC Management Platform.

  • Apply for import licenses (if blending with regulated substances).

  • Label packages with Chinese hazard warnings and GWP data.

  • Partner with certified customs brokers familiar with fluorochemicals.

5. Recent Trends

  • Carbon Neutrality Drive: China’s 2060 net-zero goal accelerates HFO adoption in refrigeration, EVs, and foam.

  • Stricter Enforcement: Increased audits of refrigerant imports to curb illegal HFC smuggling.

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