Fluorinated Gases Details
📊 Environmental Tax Calculation Breakdown
The Tax on Fluorinated Greenhouse Gases (Impuesto sobre los Gases Fluorados de Efecto Invernadero) is an indirect environmental state tax in Spain introduced by Law 16/2013, of October 29, and reformed by Law 14/2022, of July 8. It targets the emission and commercialization of fluorinated gases due to their high global warming impact. The tax applies to the first delivery or use of these gases in Spain (e.g., for servicing vehicle air conditioning, commercial food refrigeration, or domestic heat pumps). The tax rate is calculated by multiplying the gas’s Global Warming Potential (GWP) by a coefficient of €0.015 per kilogram, subject to a maximum cap of €100 per kilogram.
🔍 Common Gases and Effective Tax Rates
The tax rate per kilogram is calculated using the formula: GWP × €0.015. Here are the tax rates for common F-gases:
- HFC-134a (GWP = 1430): Mainly used in automotive air conditioning and small refrigeration units. Tax rate:
1430 × €0.015 = €21.45/kg. - HFC-410A (GWP = 2088): Common in residential air conditioners and heat pumps. Tax rate:
2088 × €0.015 = €31.32/kg. - HFC-404A (GWP = 3922): Historically used in supermarkets and industrial cold storage. Tax rate:
3922 × €0.015 = €58.83/kg. - HFC-32 (GWP = 675): A modern, eco-friendlier gas for home A/C units. Tax rate:
675 × €0.015 = €10.125/kg(approximate).
📝 Worked examples
Example 1: Recharging bus air conditioning with HFC-134a
Profile: An automotive workshop purchases 50 kg of gas HFC-134a to service city bus climate control systems.
- F-gas type: HFC-134a (GWP = 1430)
- Quantity purchased: 50 kg
- Tax rate per kg: €21.45/kg
Example 2: Servicing supermarket refrigeration with HFC-404A
Profile: A commercial supermarket chain purchases 120 kg of gas HFC-404A for cold storage display maintenance.
- F-gas type: HFC-404A (GWP = 3922)
- Quantity purchased: 120 kg
- Tax rate per kg: €58.83/kg
Example 3: Installing home A/C with gas HFC-32 (Eco-friendly choice)
Profile: Purchase of 15 kg of HFC-32 gas for charging a new home climatization unit.
- F-gas type: HFC-32 (GWP = 675)
- Quantity purchased: 15 kg
- Tax rate per kg: €10.125/kg
Choosing HFC-32 instead of HFC-410A reduces the tax liability to one-third, encouraging the use of more sustainable gases.
⚠️ Common mistakes
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Forgetting the 95% foam manufacturing exemption: Companies that buy F-gases to incorporate them into polyurethane insulation foams are eligible for a 95% reduction in the tax. Missing this credit will significantly increase production costs.
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Neglecting VAT on top of the tax: The F-gas tax is added to the base price of the gas before calculating VAT (21%). Therefore, distributors apply VAT to the combined total of the gas price plus the tax, increasing cash outlay.
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Failing to claim refunds on recycled or destroyed gas: If you recover F-gas from old machinery and send it to an authorized waste manager for destruction or recycling, you are entitled to a 100% refund of the tax paid, subject to submitting the official destruction certificate.
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Confusing reclaimed refrigerants with virgin gas: Reclaimed or recycled refrigerants benefit from reduced tax rates or exemptions in certain circular economy cases. Using reclaimed gas helps reduce the tax burden for servicing older installations.
❓ Frequently Asked Questions (FAQ)
Following the 2022 reform, the taxpayer is the **authorized warehousekeeper or distributor** making the first sale of virgin gas in Spain, or the importer bringing it into the EU. Final workshops and customers pay the tax passed on in their purchase invoice.
Authorized warehousekeepers file and pay the tax using **Form 587** (*Modelo 587*) on a monthly or quarterly basis.
Yes. The law sets a maximum tax cap of **€100 per kilogram**. Any gas whose GWP multiplied by €0.015 exceeds €100 (e.g., experimental gases with GWP > 6667) will only be taxed at the €100/kg limit.
Yes. The law grants a full exemption to F-gases loaded for use in international commercial marine navigation or aviation (excluding private leisure craft).
Global Warming Potential (GWP) measures the warming impact of one kilogram of gas compared to one kilogram of CO₂ over 100 years. A higher GWP means the gas causes more environmental damage, resulting in a higher tax.
Yes. F-gases used to manufacture metered-dose pharmaceutical inhalers (such as asthma inhalers) are fully exempt for medical reasons.
EU F-gas regulations ban the use of virgin gases with a GWP > 2500 for servicing refrigeration systems. Only reclaimed HFC-404A is allowed, which is taxed at specific rates to encourage system upgrades.
Yes. Since the 2022 reform, the tax also applies to gases contained within imported machinery or devices (e.g., pre-charged heat pumps or A/C units imported from Asia). The importer must pay the tax based on the gas charge inside the equipment.