On April 20, 2026, the New Zealand Environmental Protection Authority (EPA) issued an important reminder that all importers of hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs) must hold an import permit and be registered as participants in the Emissions Trading Scheme (ETS), unless specific exemptions apply.
The EPA stated that HFCs and PFCs have harmful effects on the environment and must be strictly controlled to ensure New Zealand meets its international obligations to reduce greenhouse gases. Under the Kigali Amendment to the Montreal Protocol, countries are required to phase down the use of HFCs.
Exemption
The only exemption is when these gases are used solely for servicing the refrigeration systems of containers intended for export. The purpose of this exemption is to ensure that New Zealand's bulk HFC importers do not have to pay for emissions occurring outside the country. Therefore, the exemption does not apply if the container is used within New Zealand. The country receiving the exported container will take its own measures to contribute to the global reduction of HFC use.
For those qualifying for the exemption, importers must keep the following records when using imported bulk HFCs to service refrigeration systems in refrigerated containers:
- Records demonstrating that the sale of bulk HFCs corresponds to the specific container;
- Records demonstrating that the serviced refrigerated container is intended for export.
Refrigerated Containers and HFCs
Refrigerated containers commonly use HFCs as coolants. Any business importing bulk HFCs into New Zealand must hold an EPA import permit and fulfill related responsibilities, and must also participate in the Emissions Trading Scheme and pay the corresponding fees or levies to offset the significant climate impact of HFCs.
Bulk HFCs refer to any quantity of HFCs stored in containers (such as new or recovered large cylinders or small containers) before being charged into equipment (e.g., heat pumps or refrigerators).
As New Zealand advances its HFC phase-down schedule under the Kigali Amendment, associated compliance costs are expected to rise, and businesses are being guided toward alternative refrigerants with lower climate impact.Notably, alternatives such as hydrofluoroolefins (HFOs) have a much lower climate impact than HFCs, and importing these alternatives currently does not require a permit.
Importers are advised to understand the rules in advance and keep proper records to avoid unexpected costs or fines due to non-compliance.
