Which refrigerants require ODS/HFCs filing?

HCFC refrigerants such as R22 are in the phase-out stage, with production and use under quota licensing. HFCs including R32, R134a, R125, R143a and R23 have been under quota management since 2024. Blends containing controlled substances — R404A, R407C, R410A, R507A, R449A, R452A — are also within the scope of control. Hydrocarbons and inorganic compounds such as R290, R600a and R744 are not on China's controlled ODS list and require no ODS/HFCs filing.

Which authority handles the filing, and where is it submitted?

Sales, use, maintenance and disposal entities file with the ecology and environment bureau of the prefecture-level city where they are located; recovery, recycling and destruction entities file at provincial level; production quotas are applied for at the Ministry of Ecology and Environment. All quota applications and filings go through the online ODS Information Management System (new-ods.ozone.org.cn).

What materials are needed for filing?

First-time filers register a corporate user, complete company information (legal name, unified social credit code, registered and office addresses, legal representative and contact person, plus business licence upload), select the business type, and submit the filing application form, business licence and a description of operations for review by the prefecture-level authority. Existing filers should apply for the next year's filing between 1 December and 31 January.

What ongoing obligations follow filing?

Production, sales and use entities must report controlled-substance data within 15 working days after each quarter; original records must be kept for at least 3 years; changes to company name, addresses, premises or legal representative require timely amendment, and entities leaving the business must deregister promptly.

How can buyers verify a supplier's filing status?

Query the supplier's quota and filing information by company name in the Public Information section of the ODS Information Management System, or ask the supplier directly for a filing statement. Retaining transaction records for at least 3 years is a statutory obligation of the buyer.

Refrigerant ODS HFCs Filing Guide_Environmental Compliance Procedure

Under the Kigali Amendment, R22, R134a, R404A, R410A and their blends are all controlled substances. Based on MEE Huan Daqi [2026] No. 8 and current policies, this guide covers filing categories, procedures, required materials and key deadlines for sellers, users, servicers and recyclers of refrigerants.

Since China accepted the Kigali Amendment to the Montreal Protocol in 2021, hydrofluorocarbons (HFCs) have been brought under national control. The revised Regulation on the Administration of Ozone Depleting Substances, promulgated in December 2023 and effective from March 1, 2024, is now joined by the Notice on Further Strengthening the Management of Ozone Depleting Substances and Hydrofluorocarbons (Huan Daqi [2026] No. 8, effective March 1, 2026), which extends full-chain oversight to the production, sale, use, servicing, scrapping, recovery, reclamation and destruction of controlled substances. Common refrigerants such as R22, R134a, R404A and R410A and their blends are all on the controlled list, making environmental filing a precondition for operating in this business.

1. Legal Basis

China's refrigerant environmental regime follows an international convention - regulation - controlled list - implementation plan framework. The current principal instruments are:

Montreal Protocol on Substances that Deplete the Ozone Layer and its Kigali Amendment: HFCs were brought under control in 2016, and China accepted the amendment in 2021
Regulation on the Administration of Ozone Depleting Substances: revised in December 2023, effective March 1, 2024, applying quota licensing or filing across production, sale, use, servicing, recovery, reclamation and destruction
List of Controlled Ozone Depleting Substances in China (Announcement No. 44 of 2021 by MEE, NDRC and MIIT): nine categories of controlled substances, blends included
China's National Plan for the Implementation of the Montreal Protocol (2025-2030): the national compliance timetable and roadmap
Notice on Further Strengthening the Management of Ozone Depleting Substances and Hydrofluorocarbons (Huan Daqi [2026] No. 8) and Notice on Filing Administration of Hydrofluorocarbons (Huan Bianhan [2025] No. 85): detailed full-chain oversight and filing requirements

Quota applications and filings are handled online through the ODS Information Management System (new-ods.ozone.org.cn), under the supervision of the Ministry of Ecology and Environment (MEE) and ecological environment authorities at all local levels.

2. Which Refrigerants Are Controlled

The List of Controlled Ozone Depleting Substances in China covers both single substances and blends, in nine categories: CFCs, halons, carbon tetrachloride (CTC), methyl chloroform (TCA), HCFCs, hydrobromofluorocarbons, bromochloromethane, methyl bromide and HFCs. The mapping for common refrigerants is as follows:

R22 (HCFC-22): an HCFC in the phase-out stage, subject to production and use quota licensing
R32, R134a, R125, R143a, R23, R245fa and similar: HFCs under quota management since 2024
R404A, R407C, R410A, R507A, R449A, R452A and similar blends: controlled as blends containing controlled substances
R290 (propane), R600a (isobutane) and R744 (CO2): hydrocarbons and inorganic compounds, not on the list, no ODS/HFCs filing required

It is worth noting that HFCs do not deplete ozone but are non-CO2 greenhouse gases. China's HFC production and consumption have been frozen at baseline since 2024 (the 2020-2022 average plus 65% of the HCFC baseline, in CO2 equivalent), with reductions of 10%, 30% and 50% against baseline due in 2029, 2035 and 2040 respectively, and no more than 20% of baseline after 2045. This timetable is the international legal background of the quota and filing system and shapes the long-term supply and demand of refrigerants.

3. What Each Type of Entity Must Do

Control measures fall into two categories: quota licensing for production entities and certain use entities, and filing administration for sale, other use, servicing, scrapping, recovery, reclamation and destruction entities.

Sellers (refrigerant trading, repackaging, wholesale): file with the districted-city-level ecological environment authority where they are located; producers selling their own controlled substances and blends need no sale filing
Users (feedstock use; manufacture, construction or installation services of refrigeration or air-conditioning equipment or systems using controlled substances or blends): file with the districted-city-level ecological environment authority
Servicing and scrapping entities: file with the districted-city-level ecological environment authority; one-time filing, valid long term
Recovery, reclamation and destruction entities: file with the provincial-level ecological environment authority; one-time filing, valid long term
Producers (synthesis or by-production of controlled substances): production quota licensing; apply to MEE for the next year's production quota before October 31 each year

Servicing, scrapping, recovery, reclamation and destruction entities must promptly update information such as name, registered address, business premises or legal representative when it changes, and cancel filing when they cease the relevant business.

4. Filing Procedure: Sale Filing as an Example

Filing is handled entirely online. The main steps are:

Visit the ODS Information Management System (new-ods.ozone.org.cn) and register an enterprise user from the top right of the homepage
Complete account setup and account type selection (business entities choose 'Enterprise User')
Register enterprise information: full name, ownership type, unified social credit code, office and registered addresses, postcode, legal representative and contact details, and upload the business license
Select the business type (sale filing, use filing, servicing filing, etc.) and complete the business configuration
Fill in the filing application form and submit the materials: filing application form, business license and a description of the relevant business
Filing is completed once approved by the districted-city-level ecological environment authority; review timelines follow local requirements

Entities filing for subsequent years should apply through the system between December 1 and January 31 of the following year, submitting the application form and materials for any changes; new businesses arising mid-year can file at any time. The system's Information Disclosure section allows quota and filing records to be searched by year, region, business type and company name, so purchasers can verify the filing status of upstream suppliers.

5. Key Deadlines and Data Reporting

Before October 31 each year: production entities apply for the next year's production quota; use quota applications and adjustments follow the same timing and material requirements
December 1 to January 31 of the following year: sale and use entities apply for the next year's filing
Within 15 working days after each quarter: production, sale and use entities report controlled substance data through the system
Within 30 working days after each year-end: servicing, scrapping, recovery, reclamation and destruction entities report controlled substance data
Ongoing: retain original business records for at least 3 years and apply for updates promptly when basic information changes

Local authorities may differ slightly in implementation; follow the latest notices of the system and the local ecological environment authority.

6. Compliance Red Lines

Do not sell controlled substances or blends to individuals; do not sell to or buy from entities that do not meet the prescribed conditions
Provide buyers with accurate information on the variety, quantity, intended use and specification of controlled substances sold, and keep complete and accurate original records
Report filing information and business data truthfully; no refusal, falsification, omission or concealment
Retain original records for no less than 3 years
Producing or selling without a production quota license or beyond quota, operating without required filing, and failing to report data on time are all listed as key enforcement targets

Refrigeration and air-conditioning equipment manufacturers should also note the industry prohibition timetable: from January 1, 2026, the production of household refrigerators and freezers using HFCs as refrigerant is prohibited (MEE Announcement 2025 No. 27), and HCFC-141b blowing agent prohibitions have been phased in as well, pushing OEM refrigerant selection toward natural working fluids and low-GWP alternatives.

7. Recommendations for Purchasers

Verify supplier filing status through the system's Information Disclosure section or request a filing statement from the supplier
Keep transaction records on variety, quantity, intended use and specification for at least 3 years
Plan long-term supply against the HFC phase-down timetable and prioritize suppliers with the required qualifications in place
Watch the substitution window: the range of low-GWP and natural working fluids is widening, and new projects can plan ahead

Anhui Kelvins Refrigeration Technology Co., Ltd. continuously tracks ODS and HFCs policy developments and can assist customers in meeting filing and compliance requirements. Contact us for supply arrangements for specific products.

Disclaimer: This article is compiled from publicly released policy documents of MEE and other authorities for reference only and does not constitute legal advice; specific filing and quota requirements are subject to the latest regulations and local implementation.

Refrigerant Environmental Filing Guide: ODS and HFCs Compliance Procedures