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📦 Other, not included in the subheadings above, containing 20 percent or more by mass of difluoromethane (HFC-32) and 20 percent or more by mass of pentafluoroethane (HFC-125)

Other, not included in the subheadings above, containing 20 percent or more by mass of difluoromethane (HFC-32) and 20 percent or more by mass of pentafluoroethane (HFC-125)

HS Code:

📦

Overview

This category, classified under HS Code 3824.78.90 (or similar, depending on regional harmonization), pertains to mixtures of hydrofluorocarbons (HFCs) that contain 20% or more by mass of difluoromethane (HFC-32) and 20% or more by mass of pentafluoroethane (HFC-125), not included in other specific subheadings. These mixtures are commonly used as refrigerants in air conditioning and refrigeration systems due to their thermodynamic properties. They are often marketed under trade names like R-410A, a widely used blend in HVAC systems. This category is significant in global trade due to the high demand for cooling solutions, but it is also subject to strict environmental regulations under agreements like the Montreal Protocol and its Kigali Amendment, which aim to phase down HFCs due to their high global warming potential (GWP).

Total Trade Volume

Approximately $1.2 billion USD

Data from 2022

Source

UN Comtrade Database, ITC Trade Map

Tariff Analysis

Average Rate

5.2% ad valorem

Highest Rate

10% (applied by certain developing countries under WTO schedules)

Lowest Rate

0% (under free trade agreements like EU-Japan EPA or USMCA)

Common Restrictions

  • Import quotas under the Kigali Amendment to the Montreal Protocol
  • Licensing requirements for handling and importing HFCs
  • Environmental taxes or levies on high-GWP substances
  • Phasedown schedules limiting trade volumes over time

Market Trends

Shift towards low-GWP alternatives

Demand for HFC-32 and HFC-125 blends like R-410A is declining in developed markets as regulations push for hydrofluoroolefins (HFOs) and natural refrigerants.

2021-2023

Increased production in Asia-Pacific

Countries like China and South Korea are ramping up production to meet demand in emerging markets where HFC-based systems are still prevalent.

2020-2022

Rising recycling and reclamation programs

Trade in virgin HFC mixtures is being partially offset by initiatives to recover and reuse refrigerants, especially in the EU and US.

2022

Recent Developments

EU F-Gas Regulation Tightening

The European Union revised its F-Gas Regulation, accelerating the phasedown of high-GWP HFCs like R-410A, imposing stricter quotas on imports starting 2024.

October 2023

Reduced market access for exporters to the EU, pushing innovation in alternative refrigerants.

US AIM Act Implementation

The American Innovation and Manufacturing (AIM) Act began enforcing an 85% reduction in HFC production and consumption by 2036, with significant cuts starting in 2022.

January 2022

Decline in US imports of HFC-32 and HFC-125 blends, affecting global exporters like China.

China’s HFC Export Policy Update

China introduced new export controls and subsidies for HFC production to align with Kigali Amendment commitments while supporting domestic manufacturers.

March 2023

Increased export volumes in the short term, but potential long-term reduction as global demand shifts.