Environment Agency charge proposal: fluorinated greenhouse gases (F gas) and ozone depleting substances (ODS): summary of consultation responses
Updated 1 April 2025
Introduction
The Environment Agency administers the fluorinated greenhouse gases (F gas) and ozone depleting substances (ODS) online services on behalf of England, Scotland and Wales.
Our role is to manage businesses registering on these services. This involves:
- calculating quota and managing quota transactions
- determining licence applications
- reviewing annual reports
- working with businesses and HM Revenue and Customs to ensure ongoing compliance with the scheme
- providing guidance and a helpdesk
The government funding we receive to manage these services is no longer sufficient. We will not be able to continue to provide the same level of service without introducing charges to fully recover our costs.
The consultation set out our new charging proposals for F gas and ODS and we invited businesses to share their views.
How we ran the consultation
The consultation ran for 8 weeks from 19 December 2024 to 13 February 2025. It was hosted on 伊人直播 and our consultations website (Citizen Space). It was open to anybody to take part. Those who preferred to respond by email or post were able to request a copy of the consultation document and response form instead of responding online.
We ran the consultation in line with our legal requirements to consult following the Cabinet Office鈥檚 consultation principles guidelines. We notified ministers of our intention to consult.
It was important for us to give our customers the opportunity to understand the proposals and the impact they will have. We encouraged our customers to give us their views through the consultation and publicised it openly.
In the run up to the consultation, our staff engaged with over 2,000 businesses. We directly contacted each registered business advising them of our consultation, when it launched, and again before the end of the consultation period.
Key findings and actions we will take
This section includes an overview of responses to the consultation, key points we identified within those responses and a summary of our response to each of these.
Overview of consultation responses
We received a total of 144 responses to the consultation. Of these responses,143 were submitted using our Citizen Space consultation tool and one was sent using our consultation response form.
The 144 responses were submitted by:
- 18 individuals
- 122 organisations or groups
- 1 other
- 3 who provided no information
You can find detailed information on the responses to each question in Annex 1. This includes analysis of the comments we received. Annex 2 gives a list of organisations and groups that participated in the consultation. These organisations represent a broad range of the businesses that use the service.
The overall response to this consultation represents approximately a 7% response rate from our over 2,000 registered customer base. We are really pleased with this response. We would like to thank all those who participated in the consultation and took time to provide this valuable feedback.
Consultation outcome
We conducted a thorough review of comments to identify the key points from the themes and considered whether it may be appropriate to make changes to our original proposals. The consultation feedback was very helpful in understanding any concerns or issues relating to our proposals. It was also valuable to hear from those who expressed their support for the changes we proposed.
After careful consideration, we will implement all the proposed charges as outlined in the consultation document. A summary of feedback we received and our response to the key points are set out under separate headings.
Key themes and our response
The overview of all the feedback to the consultation is provided in Annex 1.
Respondents commented on how we have designed the proposed charging scheme and how the proposed charges may impact our customers. Specific points raised by respondents and our response follow.
Impact to customers 鈥 charges are too high
Businesses did not support the introduction of these new charges, and some considered the charges too high.
鈥淚t is a high service fee for our company鈥
鈥淐harge is way too high鈥
Although the majority of responses were against introducing charges for the provision of these services, we noted that there was support from a minority of businesses for their introduction.
鈥淲e believe that the proposed charges for F gas annual subsistence are reasonable and necessary to maintain the high standards of environmental protection and compliance.鈥
鈥淎s per the registration fee it seems reasonable, provided charges don鈥檛 escalate and keep in line with the value of services and support provided.鈥
Our response
We need to make sure we fully recover our costs, and in line with other regulatory regimes will apply the polluter pays principle. We have designed our charges in line with managing public money rules to reflect the distinct items of work we need to undertake.
The design of the scheme has been made to make sure that we recover the appropriate costs for each component of our work.
Charge scheme design 鈥 seek other funding sources
Many comments asked why the customer now had to pay for the service including a subsistence charge.
鈥淭his is a statutory requirement, not a voluntary one. On that basis, the service should be fully funded by government. Statutory requirements should not be directly chargeable鈥
鈥淚 do not agree with annual fee. This is a government organisation and government policy and is funded by the government. From company taxes we already pay鈥
Our response
Since EU exit, the funding for F gas and ODS services have been directly from government; businesses have not had to contribute to the costs of delivery.
The majority of companies did not support the proposal to introduce charges to those businesses that utilise the service.
The polluter pays principle applies to our other regulatory regimes, and we are introducing charges to this service to abide by that principle.
We would also like to make it clear that the registration charge does not apply to existing F gas, ODS and LabODS registered businesses. The registration charge will only apply to companies who decide they need to start to use these services and register for the first time.
Also, the subsistence charges will only apply to businesses that are:
- required to submit reports on their F gas activities
- ODS businesses holding a licence within the calendar year
- ODS business who are required to submit a report for the calendar year
The Environment Agency will invoice the appropriate companies at the end of the calendar year.
Charge scheme design 鈥 other suggestion that charges should be based on substance use
The majority of businesses did not agree with the introduction of these new charges. Several respondents suggested that the charge should be based on the quantity of the substances used.
鈥淎gain, apply a levy per tonne - this isn鈥檛 anti-competitive, whereas your proposed system is. More income will be generated with a levy per tonne model.鈥
鈥淎 suggestion of a tiered subsistence charge based on annual reported quantities may be beneficial.鈥
Our response
Our regulatory work is not linked to the quantities of substances used by individual businesses but relates to distinct items of service delivery. Therefore, applying a sliding or tiered charge based on usage would not be compliant with managing public money rules.
Next steps
We have considered all consultation feedback and assessed whether we need to make changes to our proposals.
We have now published the聽updated charging scheme聽on 伊人直播. The charges are effective from 1 April 2025.
We have also published a guide on how we calculate our charges.
Annex 1: Detailed summary of consultation responses
This annex sets out the responses we received to our consultation on Environment Agency charge proposal: fluorinated greenhouse gases (F gas) and ozone depleting substances (ODS).
The consultation questions were divided into several topics:聽
- about you and additional questions鈥
- F gas charging proposals
- ODS charging proposals
- additional comments about the charging proposals鈥
We received 144 responses through the online tool and consultation response form.
About you鈥
Within the online tool and response form, we included an 鈥榓bout you鈥 section to provide us with an understanding of who responded and to help us better analyse the consultation feedback.
We asked if consultees were giving a personal response as an individual or providing their response on behalf of an organisation. The 144 responses (143 online and one using our consultation response form), stated:
- responding as an individual 鈥 18
- responding on behalf of an organisation, group or trade association 鈥 122
- other 鈥 1
- no answer given 鈥 3
We asked those responding to tell us which section of the consultation they were responding to聽
- F gas only 鈥 102
- ODS only 鈥 16
- both F gas and ODS 鈥 23
- no answer given 鈥 3
We asked how respondents found out about the consultation and they said:聽
- from the Environment Agency 鈥撀131
- from another organisation 鈥 1
- press article 鈥 3
- social media, for example, Facebook 鈥 2
- through a meeting you attended 鈥 1
- through an organisation, group or trade association you are a member of 鈥撀1
- not answered 鈥 2
- other 鈥 3
The 3 responses who said 鈥榦ther鈥, found out about the consultation from:
- email from colleague
- Linkedln network
- word of mouth
Consultation questions
Questions are set out in the same format as they were presented in the online consultation tool and response form. Multiple choice questions gave respondents the option to select one response. These were followed by a free text box for comments.
For each question, we report the multiple choice options selected and the 鈥榯hemes鈥 identified in free text comments.
Themes or key points: We reviewed the free text comments and used content analysis to define and group recurrent ideas or concerns. We used descriptive labels (called 鈥榯ags鈥) to summarise specific ideas. More than one 鈥榯ag鈥 can be used in a comment. We then grouped 鈥榯ags鈥 of a similar nature within a 鈥榯heme鈥. These 鈥榯hemes鈥 help us to describe the overall response to each question and show where particular feedback was given about the consultation, environment or Environment Agency. The tag 鈥榥ot applicable鈥 is used if a comment does not include any relevant themes.
Themes are given in descending order with the most frequently identified first. Any 鈥榯ags鈥 identified more than 3 times are noted alongside themes to give additional detail about the feedback we received. The number of times a tag is identified is given in brackets. When the number of each individual tag identified in a theme are added together, and is less than 10, we report the theme only.
F gas charging proposals
Question 1: Do you agree or disagree with the proposed F gas registration charge?
This question received more negative (70) responses than positive (24) responses:
- strongly agree 鈥 3
- agree 鈥 21
- neither agree nor disagree 鈥 14
- disagree 鈥 20
- strongly disagree 鈥 50
- do not know 鈥 4
- not applicable 鈥 11
- did not answer 鈥 21
Free text comments were submitted by 56 respondents to the consultation (39%):
- charge scheme design聽鈥 鈥榗harging and permitting policy鈥 (20); 鈥榦ther suggestion for proposal鈥 (14); 鈥榮eek other funding鈥 (3)
- impact for customers 鈥 鈥 economic impact for customers鈥 (16); 鈥榗harge is too high鈥 (7)
- support for proposal 鈥 鈥榩artially agree with proposal鈥 (14); 鈥榓grees with proposal鈥 (3)
The following themes of 鈥榦ur business approach鈥, 鈥榩rotecting the environment鈥 and 鈥榮ervice we provide鈥 were identified fewer times. Three comments were 鈥榥ot applicable鈥.
Question 2: Do you agree or disagree with the proposed F gas annual subsistence charge?
This question received more negative (87) responses than positive (20) responses:
- strongly agree 鈥 1
- agree 鈥 19
- neither agree nor disagree 鈥 10
- disagree 鈥 22
- strongly disagree 鈥 65
- do not know 鈥 2
- not applicable 鈥 3
- did not answer 鈥 22
Free text comments were submitted by 64 respondents to the consultation (44%):
- charge scheme design 鈥 鈥榗harging and permitting policy鈥 (35); 鈥榦ther suggestion for proposal鈥 (28); 鈥榮eek other funding鈥 (3)
- impact for customers 鈥 鈥榚conomic impact for customers鈥 (31); 鈥榗harge is too high鈥 (14)
- support for proposal 鈥 鈥榩artially agree with proposal鈥 (9); 鈥榓grees with proposal鈥 (4)聽
The following theme of 鈥榦ur business approach鈥 was identified fewer times. One comment was 鈥榥ot applicable鈥.
ODS charging proposals
Question 3: Do you agree or disagree with the proposed charge for registering on the ODS service?
This question received slightly more negative (19) responses than positive (17) responses:
- strongly agree 鈥 1
- agree 鈥 16
- neither agree nor disagree 鈥 15
- disagree 鈥 8
- strongly disagree 鈥 11
- do not know 鈥 5
- not applicable 鈥 68
- did not answer 鈥 20
Free text comments were submitted by 34 respondents to the consultation (24%):
- charge scheme design 鈥 鈥榗harging and permitting policy鈥 (12); 鈥榦ther suggestion for proposal鈥 (5)
- impact for customers 鈥 鈥榚conomic impact for customers鈥 (8); 鈥榗harge is too high鈥 (8)
- other issues 鈥 鈥榗ustomer is not affected by charge鈥 (9)
The following themes of 鈥榮upport for proposal鈥 ,鈥榦ur business approach鈥 and 鈥榦ther issues鈥 were identified fewer times.
Standard import or export licence application charge
Question 4: Do you agree or disagree with the proposed ODS standard import or export licence application charge?
This question received slightly more negative (19) responses than positive (18) responses:
- strongly agree 鈥 4
- agree 鈥 14
- neither agree nor disagree 鈥 13
- disagree 鈥 9
- strongly disagree 鈥 10
- do not know 鈥 3
- not applicable 鈥 70
- did not answer 鈥 21
Free text comments were submitted by 30 respondents to the consultation (21%):
-
charge scheme design 鈥 鈥榗harging and permitting policy鈥 (14); 鈥榦ther suggestion for proposal鈥 (5)
-
impact for customers 鈥 鈥榚conomic impact for customers鈥 (5); 鈥榗harge is too high鈥 (5); 鈥榠ncreased regulatory burden鈥 (1)
The following theme of 鈥榮upport for proposal鈥 and 鈥榦ther issue鈥 were identified fewer times.
Multi-shipment import or export licence application charge
Question 5: Do you agree or disagree with the proposed ODS multi-shipment import or export licence application charge?
This question received slightly more negative (17) responses than positive (13) responses:
- strongly agree 鈥 2
- agree 鈥 11
- neither agree nor disagree 鈥 17
- disagree 鈥 9
- strongly disagree 鈥 8
- do not know 鈥 3
- not applicable 鈥 74
- did not answer 鈥 20
Free text comments were submitted by 24 respondents to the consultation (17%):
- impact for customers 鈥 鈥榚conomic impact for customers鈥 (6); 鈥榗harge is too high鈥 (6);
- charge scheme design 鈥 鈥榗harging and permitting policy鈥 (8)
The following themes of 鈥榮upport for proposal鈥, 鈥榦ther issue鈥 and 鈥榦ur business approach鈥 were identified fewer times. Four comments were 鈥榥ot applicable鈥.
ODS charging proposals: LabODS declaration charge
Question 6: Do you agree or disagree with the proposed LabODS declaration charge?
This question received more negative (22) responses than positive (10) responses:
- strongly agree 鈥 3
- agree 鈥 7
- neither agree nor disagree 鈥 11
- disagree 鈥 10
- strongly disagree 鈥 12
- do not know 鈥 5
- not applicable 鈥 77
- did not answer 鈥 19
Free text comments were submitted by 27 respondents to the consultation (19%):
- impact for customers 鈥 鈥榗harge is too high鈥 (9) 鈥榚conomic impact for customers鈥 (7)
- charge scheme design 鈥 鈥榗harging and permitting policy鈥 (8); 鈥榦ther suggestion for proposal鈥 (3)
The following themes of 鈥榮upport for proposal鈥, 鈥榦ur business approach 鈥 and 鈥榦ther issues鈥 were identified fewer times.
ODS charging proposals: quota application charge
Question 7: Do you agree or disagree with the proposed ODS quota applications charge?
This question received more negative (19) responses than positive (9) responses:
- strongly agree 鈥 4
- agree 鈥 5
- neither agree nor disagree 鈥 11
- disagree 鈥 12
- strongly disagree 鈥 7
- do not know 鈥 6
- not applicable 鈥 80
- did not answer 鈥 19
Free text comments were submitted by 25 respondents to the consultation (17%):
- impact for customers 鈥 鈥榚conomic impact for customers鈥 (8); 鈥榗harge is too high鈥 (6)
- charge scheme design 鈥 鈥榗harging and permitting policy鈥 (10); 鈥榦ther suggestion for proposal鈥 (3)
The following themes of 鈥榦ther issues鈥 and 鈥榮upport for proposal鈥 were identified fewer times.
ODS charging proposals: annual subsistence charge
Question 8: Do you agree or disagree with the proposed ODS annual subsistence charge?
This question received more negative (32) responses than positive (7) responses:
- strongly agree 鈥 3
- agree 鈥 4
- neither agree nor disagree 鈥 9
- disagree 鈥 11
- strongly disagree 鈥 21
- do not know 鈥 4
- not applicable 鈥 72
- did not answer 鈥 20
Free text comments were submitted by 35 respondents to the consultation (24%):
- impact for customers 鈥 鈥榗harge is too high鈥 (13); 鈥榚conomic impact for customers鈥 (13); 鈥榮eek other funding鈥 (2)
- charge scheme design 鈥 鈥榗harging and permitting policy鈥 (15); 鈥榦ther suggestion for proposal鈥 (4)
- other issues 鈥 鈥榦ther issues鈥 (7) 鈥榗ustomer is not affected by charge鈥 (4);
The following themes of 鈥榮upport for proposal鈥, 鈥榦ur business approach鈥 and 鈥榯he consultation design鈥 were identified fewer times.
Additional comments about the F gas and ODS charging proposals
Question 9: Please share any additional comments or suggestions you may have about our F gas and ODS charging proposals.
Free text comments were submitted by 70 respondents to the consultation (49%):
- charge scheme design 鈥 鈥榗harging and permitting policy鈥 (49); 鈥榦ther suggestion for proposal鈥 (31); 鈥榮eek other funding鈥 (2)
- impact for customers 鈥 鈥榚conomic impact for customers鈥 (46); 鈥榗harge is too high鈥 (16)
- other issues 鈥 鈥榦ther issues鈥 (17)
- support for proposal 鈥 鈥榩artially agree with proposal鈥 (8); 鈥榓grees with proposal鈥 (5)
The following themes of 鈥榦ur business approach鈥 and 鈥榮ervice we provide鈥 were identified fewer times. Three comments were 鈥榥ot applicable鈥.
Annex 2: List of consultation participants
The number of respondents in the consultation who said they were an organisation or business will differ from the number of organisations named in this list. This is because some respondents indicated they did not want their response to be published.
List of organisations or businesses that gave a name
Apex Molecular Limited
Apollo Scientific Ltd
ARKEMA
Automated Environmental Systems Ltd
Avtrade Ltd
Azur Aviation Limited
Baotou Daozheng trading Co.LTD
Beijing Daozheng international tax consulting Co.LTD
Capelo Limited
Capes Consulting Ltd
Charles River Labs
Chengdu Daozhengxingyuan trading Co.LTD
China Tesa Appliance Co., Limited
Chongqing Daoxin trading Co.LTD
Clivet S.p.A. Group, including:
-
CLIVET S.P.A. (FG72UA63NE)
-
CLIVET GMBH (FG00LD46AB)
-
CLIVET AIRCONDITIONING SYSTEMS PRIVATE LIMITED (FG62RO37VR)
-
OOO CLIVET (FG80QB33GA)
-
CLIVET MIDEAST FZCO (FG72HZ70KS)
-
CLIVET GROUP UK LIMITED (FG07AF60GW)
-
CLIVET AIR S.R.L. (FG79AV04KH)
-
CLIVET FRANCE SAS (FG88BF51RW)
-
CLIVET SOUTH-EAST EUROPE D.O.O. (FG17PT52CU)
Colmenar Associates Ltd
Concept Life Sciences IDDS Ltd
Cormica Bradford Ltd.
CRUK Scotland Institute
Daikin Applied (UK) Ltd
Daozheng (Changchun) flourine trade Co.LTD
Daozheng (Haikou) trading Co.LTD
Dola (Guangzhou) Chemical trade Co.LTD
Dometic UK Ltd
F and R Products Limited
FG EUROPE UK LIMITED
Fireboy Xintex UK Operations Ltd.
Fl盲ktGroup UK Limited
Fluorochem Ltd
Foodservice Equipment Association
Fraser Technologies Limited.
Fuzhou city Gulou Zhongshuidaozheng trading Co.LTD
Glasgow Scientific Services
Global energy systems & technology
Guangzhou luoxin flourine Co.LTD
Guangzhou Tengan fluorine trade Co.LTD
Guangzhou Xingmeng fluorine trade Co.LTD
Haerbin daozheng flourine trading Co.LTD
HD Hyundai Construction Equipment
Honeywell Advanced Limited
Huayuefengxing(Guangzhou)trade Co.LTD
IDS Refrigeration Limited T/A Climalife
Jingji fluorine chemical (Guangzhou) Co.LTD
Khorgos DZDL Corporate Consulting Service Co.,LTD
Lancer UK
Lanzhou Zhongshui trading Co.LTD
LGL LENNOX BV
Loughborough University
MeridianXP Limited
Mexichem UK Limited
Mitsubishi Heavy Industries
National Refrigerants Ltd
Pitkin & Ruddock Ltd
Powermaster
Puyang city Daozheng trading Co.LTD
Qingdao zhongshuidaozheng trading Co.LTD
Quotient Sciences (Alnwick) Ltd
Rapiscan Systems Ltd
REACH24H Consulting Group
Scott-Drummond Ltd
Shen County Wenshui Trading Co.,Ltd.
Shenchuang Industrial Zone Co., Ltd
Shenxian Xisheng Corporate Consulting Center
Shenxian ZSZD Technology Innovation Development Center(LLP)
Shijiazhuang daozheng flourine trading Co.LTD
Shizuishan Daozheng trading Co.LTD
Solvay France
Taian city taian district Zhongshuidaozheng trading Co.LTD
TaiyuanDaozheng trading Co.LTD
Temperature Applied Sciences Ltd
The F-Gas Register
The Institute of the Motor Industry
The University of Plymouth
Thermofisher Scientific
Thermofrost Cryo Ltd
ThermOzone Ltd
THT Anshuo chemical technology Co., LTD
THT Jifeng chemical technology Co.,LTD
THT Jitai chemical technology Co.,LTD
THT Lekangan chemical technology Co., LTD
THT Ruidaan chemical technology Co., LTD
THT Taifu chemical technology Co.,LTD
THT Tengming chemical technology Co.,LTD
Tianjin Daoeryuan Chemical trading Co.LTD
Tianjin Daohe Chemical trading Co.LTD
Tianjin Daoyi Chemical Trading Co.LTD
Tianjin Daozheng Chemical trading Co.LTD
Tianjin dola fluorine trade Co.LTD
Tianjin Weitai trading Co.LTD
Tianjin Yutai trading Co.LTD
University of York
Vectura Group Limited
Veolia ES (UK) Ltd
WEIFANG Changwen Chemical Co.LTD
Weifang Tianyue Chemical Co.LTD
Wilhelmsen Ships Service UK Ltd
Wirtgen Limited
Xian Zhongshuidaozheng trading Co.LTD
Zhengzhou Daozheng trading Co.LTD
Zhongshui(Beijing) Chemical Co.LTD