Refrigerant Procurement Compliance Checklist: From Supplier Verification to Record Keeping

Refrigerant procurement compliance is about more than price and lead time. With Huan Daqi [2026] No. 8 in force, controlled substances are under full-chain supervision: selling to or buying from entities that do not meet the prescribed conditions is a key enforcement target, and retaining complete original records for at least three years is a legal obligation of the purchaser. This checklist covers supplier verification, our own filings, transaction documents and post-transaction record keeping.

1. Before Purchasing: Verify Supplier Qualifications

• □ Confirm the supplier's status: producers selling their own controlled substances and blends need no sale filing; trading, repackaging and wholesale businesses should have completed sale filing
• □ Search the supplier's filing and quota records by company name in the Information Disclosure section of the ODS Information Management System (new-ods.ozone.org.cn)
• □ Blends such as R404A, R407C, R410A, R507A, R449A and R452A are equally controlled - verification is not waived because a product is a blend
• □ Request a filing statement before first cooperation; for producer-direct purchases, a copy of the production quota license may be requested
• □ Do not accept individual channels or goods of unknown origin - controlled substances must not be sold to individuals, and unverifiable sources carry both quality and legal risk

2. Before Purchasing: Confirm Our Own Filings

• □ Manufacture, construction or installation services of refrigeration or air-conditioning equipment or systems using controlled substances or blends: use filing required (districted-city level)
• □ Servicing or scrapping of refrigeration or air-conditioning equipment, refrigeration systems or fire-extinguishing systems: servicing filing required (districted-city level, one-time, valid long term)
• □ Recovery, reclamation or destruction of controlled substances: provincial-level filing required
• □ Enterprises purchasing for own use (not engaged in the above activities) are generally outside the filing scope, but must not resell - reselling makes you a seller requiring sale filing
• □ If unsure whether you fall in the filing scope, consult the districted-city-level ecological environment authority

3. During Transactions: Contracts and Documents

• □ Require accurate information on variety, quantity, intended use and specification of the controlled substances sold - a legal obligation of the seller that purchasers are entitled to request
• □ For blends, request the SDS (16-section safety data sheet) and batch information with the goods; check cylinder labels, composition and UN number
• □ Specify variety, quantity and specification in contracts or orders and verify against the physical goods batch by batch
• □ Keep invoices, delivery notes, weighing slips and inspection certificates complete so every batch is traceable
• □ When receiving refrigeration or air-conditioning construction or installation services, request information on the variety and quantity of controlled substances used and the upstream producer or seller

4. After Transactions: Records and Data Reporting

• □ Maintain a procurement ledger for controlled substances: variety, quantity, source, intended use and specification, batch by batch
• □ Retain original records (including electronic records) for at least 3 years - a legal obligation, not a recommendation
• □ Report data through the system as required: production, sale and use entities within 15 working days after each quarter; servicing, recovery, reclamation and destruction entities within 30 working days after each year-end
• □ Update filings promptly when company name, registered address, business premises or legal representative changes; cancel filing when ceasing the relevant business

5. Use and Storage

• □ Store by chemical management requirements, keep cylinders away from heat and open flame, avoid violent impact
• □ Filling and transfer operations performed by trained personnel with appropriate protective equipment
• □ Do not resell surplus material to unqualified entities; return it to the supplier or hand it to qualified recovery or reclamation entities

6. Policy Timetable Notes

• □ HFCs compliance schedule: frozen at baseline since 2024, reduced by 10% in 2029, 30% in 2035 and 50% in 2040, and no more than 20% of baseline after 2045 - plan long-term supply agreements and inventory strategy accordingly
• □ From January 1, 2026, production of household refrigerators and freezers using HFCs as refrigerant is prohibited (MEE Announcement 2025 No. 27); affected equipment makers should switch refrigerant selection
• □ HCFC-141b blowing agent prohibitions phased in: January 2026 for pre-blended polyols and polyurethane products (except spray foam), July 2026 for spray polyurethane foam products
• □ Put two annual windows on the internal calendar: before October 31 each year (production quota application) and December 1 to January 31 (sale and use entity annual filing)

7. One-Page Summary

Before purchasing, do three things: check the filing, verify the documents, keep the records. As an operating entity, do four things: file where required, report data on time, retain records for 3 years, and update or cancel filings promptly. Pinning this checklist to the procurement office saves digging through regulations after a problem occurs.

Anhui Kelvins Refrigeration Technology Co., Ltd. holds the required qualifications and can provide customers with filing statements and compliant shipping documents to support procurement-side compliance checks. 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 requirements are subject to the latest regulations and local implementation.