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Compliance
Regulation and restricted items in cold-chain procurement
Records of rules that can affect refrigeration equipment, refrigerant gases, installation services, storage and transport, by country of origin, destination and transit. Each record links to its official source and shows when ColdMatch checked it.
This register is not exhaustive. If a rule, country or product is not listed, or the official position is unclear: regulatory review is required before publication or a transaction.
General information only, not legal advice. Verify with the competent authority or a qualified adviser before acting.
Sanctions and restricted-party rules can prohibit or restrict dealings with particular countries, regions, companies, individuals, goods or end uses, and they change often. ColdMatch screens the buyer, end user, destination, transit route and any proposed supplier against official lists before supplier contact; a possible match or an unclear result pauses the request for human review.
Lists are updated frequently; every screening uses the list as published on the day of the check.
Applies at
origin / export · destination / import · transit
Competent authority
US Treasury (OFAC); Council of the EU and European Commission; UN Security Council; UK FCDO / OFSI; national authorities
Council Regulation (EU) No 833/2014 prohibits, among other measures, selling, supplying, transferring or exporting goods listed in its annexes — including Annex XXIII, goods that could enhance Russian industrial capacities — to persons in Russia or for use in Russia. Council Regulation (EC) No 765/2006 sets restrictive measures concerning Belarus. Whether a specific refrigeration item is listed depends on its customs (CN) code and the version of the annexes in force.
Separately from the law, ColdMatch does not accept requests for delivery to Russia. This is a platform policy, not a legal determination.
Applies at
origin / export · destination / import · transit
Competent authority
Council of the EU; national competent authorities of EU Member States
Documents and approvals
CN / HS code of every item
End user and end use
Check against the latest consolidated EUR-Lex version
Checked: Record updated: Source date: not stated on the source pageNext review:
Licence or approval requiredInternational rulesRefrigerants & gases
Import and export licensing for controlled refrigerants (Montreal Protocol)
Article 4B of the Montreal Protocol requires each Party to establish and implement a licensing system for the import and export of new, used, recycled and reclaimed controlled substances. Paragraph 2 bis, added by the Kigali Amendment, extends this to HFCs. Quotas, forms and procedures are national.
Applies at
origin / export · destination / import
Competent authority
National ozone authority (National Ozone Unit) in the exporting and importing country
Documents and approvals
Import licence or permit from the destination's national ozone authority
Export licence where the origin country requires one
Refrigerant designation and quantity on commercial documents
In the UN Model Regulations on the Transport of Dangerous Goods, anhydrous ammonia (R-717) is UN1005, Class 2.3 (toxic gas) with a Class 8 subsidiary hazard; R-134a is UN3159 and carbon dioxide (R-744) is UN1013, both Class 2.2; propane (R-290) is UN1978, Class 2.1. Road (ADR in Europe), sea (IMDG Code), air (ICAO Technical Instructions) and national rules such as US 49 CFR set packaging, marking, documentation and quantity limits. Machines shipped with a refrigerant charge can fall under separate entries, for example UN2857 or UN3358.
National rules can classify the same gas differently in detail; the carrier and the modal regulation in force decide.
Applies at
origin / export · destination / import · transit
Competent authority
National transport authorities; IMO (sea); ICAO (air); UNECE (ADR)
Documents and approvals
Dangerous goods declaration for the transport mode
Checked: Record updated: Source date: not stated on the source pageNext review:
Case-by-case review requiredInternational rulesStorage, Transport
Storage and transport of temperature-sensitive medicines (WHO model guidance)
WHO Technical Report Series No. 961, Annex 9, gives model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products. National medicines regulators decide which requirements are mandatory in their country.
Applies at
destination / import
Competent authority
National medicines regulatory authority in the country of operation
Documents and approvals
Applicable national GDP / storage requirements
Temperature mapping and monitoring records where required
EU placing-on-the-market prohibitions for F-gas equipment
Article 11(1) and Annex IV of Regulation (EU) 2024/573 prohibit placing listed equipment on the EU market from set dates, by equipment type and refrigerant GWP. Examples from Annex IV: self-contained refrigeration equipment, except chillers, containing F-gases with GWP of 150 or more — from 1 January 2025 (point 4); other refrigeration equipment covered by point 5 with F-gases of GWP 2,500 or more — from 1 January 2025, and GWP 150 or more — from 1 January 2030; chillers above 12 kW with F-gases of GWP 750 — from 1 January 2027 (point 7(d)). Safety-requirement and below −50 °C exceptions apply only as worded in the Annex.
Applies at
destination / import
Competent authority
European Commission (DG CLIMA); national market surveillance and customs authorities
Documents and approvals
Refrigerant type, charge and GWP in the technical file and on the nameplate
Which Annex IV point applies and why
Written justification where a safety exception is relied on
Checked: Record updated: Source date: Next review:
Licence or approval requiredEuropean UnionEquipment, Refrigerants & gases
EU F-gas Portal registration and quota coverage for imports
Importing equipment pre-charged with fluorinated gases requires a valid importer registration in the EU F-gas Portal for all customs procedures except temporary storage (Articles 20 and 22). HFCs in pre-charged refrigeration equipment must be covered by the quota system and documented in a declaration of conformity (Article 19), and the customs declaration must state quantities and the F-gas Portal registration number. Bulk HFCs placed on the market fall under the quota system of Article 17 and Annex VII.
Applies at
destination / import
Competent authority
European Commission (F-gas Portal); national customs authorities
Documents and approvals
F-gas Portal importer registration
Declaration of conformity on HFC quota coverage (Article 19)
Customs declaration with quantities and registration number
Article 13(3): from 1 January 2025, F-gases with GWP of 2,500 or more may not be used to maintain or service any refrigeration equipment, except military equipment and equipment designed to cool products below −50 °C; reclaimed or recycled gases may be used under the stated conditions until 1 January 2030. Article 13(5): from 1 January 2032, F-gases with GWP of 750 or more may not be used to service stationary refrigeration equipment other than chillers, subject to the listed exceptions.
Applies at
destination / import
Competent authority
National competent authorities of EU Member States
Documents and approvals
Service records with refrigerant type and quantity
Labelling of reclaimed-gas containers where relied on (Article 12(7))
Checked: Record updated: Source date: Next review:
Licence or approval requiredEuropean UnionInstallation & service
EU certification for refrigeration technicians
Article 10 of Regulation (EU) 2024/573 requires natural persons to be certified to install, maintain or service, repair or decommission, leak-check, and recover gas from the equipment it lists, covering fluorinated gases or relevant alternatives including natural refrigerants where relevant. Implementing Regulation (EU) 2024/2215 sets minimum requirements for the certificates.
Applies at
destination / import
Competent authority
Certification bodies designated by EU Member States
Documents and approvals
Technician certificate valid in the Member State
Certificate scope matching the equipment and refrigerant
EU prohibition of ozone-depleting refrigerants (for example HCFC R-22)
Regulation (EU) 2024/590 prohibits the production, placing on the market, use, import and export of the ozone-depleting substances listed in its Annex I, which include HCFCs such as R-22, and prohibits placing on the market products and equipment containing or relying on them — subject only to the narrow exemptions set out in the Regulation.
Applies at
origin / export · destination / import
Competent authority
European Commission; national customs and competent authorities
Documents and approvals
Refrigerant identification in technical documents
ODS Licensing System registration for any exempted trade
Pressure equipment and assemblies within the scope of Directive 2014/68/EU — which can include refrigeration vessels, piping and assemblies above its pressure and volume thresholds — must pass the conformity assessment for their category, carry CE marking and come with an EU declaration of conformity and instructions. Higher categories involve a notified body.
Applies at
destination / import
Competent authority
National market surveillance authorities; notified bodies
Documents and approvals
EU declaration of conformity
CE marking
Instructions for use
Notified body certificate where the category requires it
Electrical equipment designed for use between 50 and 1,000 V AC or 75 and 1,500 V DC must meet the safety objectives of Directive 2014/35/EU, carry CE marking and have an EU declaration of conformity before being placed on the EU market. Other EU acts, such as machinery and electromagnetic compatibility rules, can apply to the same equipment.
EU ecodesign rules for professional refrigeration products
Professional refrigerated storage cabinets, blast cabinets, condensing units and process chillers within the scope of Commission Regulation (EU) 2015/1095 must meet its ecodesign and product-information requirements when placed on the EU market. Check the current consolidated text before specifying.
Applies at
destination / import
Competent authority
European Commission; national market surveillance authorities
Documents and approvals
Product information sheet / technical documentation required by the Regulation
Checked: Record updated: Source date: not stated on the source pageNext review:
Licence or approval requiredEuropean UnionStorage, Transport
EU wholesale distribution of medicines (GDP)
Wholesale distribution of medicinal products in the EU requires a wholesale distribution authorisation (Directive 2001/83/EC, Article 77). Distributors follow the EU Good Distribution Practice guidelines (2013/C 343/01), which cover qualified temperature-controlled storage and transport. The authorisation concerns the operator distributing medicines, not the purchase of refrigeration equipment itself.
Applies at
destination / import
Competent authority
National medicines competent authority of the Member State
Documents and approvals
Wholesale distribution authorisation
GDP quality system records, including temperature control and qualification
Checked: Record updated: Source date: not stated on the source pageNext review:
Licence or approval requiredUnited StatesRefrigerants & gases
US HFC consumption allowances for bulk imports
Under the AIM Act phasedown rules in 40 CFR Part 84, Subpart A, importing bulk HFCs into the United States requires expending EPA consumption allowances; recordkeeping and reporting obligations are set in the same Subpart.
Checked: Record updated: Source date: not stated on the source pageNext review:
Restricted (conditions apply)United StatesEquipment, Installation & service
US refrigerant limits for new cold storage warehouse systems
Under 40 CFR 84.54(c)(9), as amended in 2026, cold storage warehouse systems using a regulated HFC, or a blend containing one, with a GWP of 700 or greater are restricted from 27 July 2026. From 1 January 2032 tighter limits apply: GWP 150 for systems with a refrigerant charge capacity of 200 pounds or more that are not the high-temperature side of a cascade, and other limits for smaller charges and cascade high sides set out in the rule.
Amended in 2026; earlier published dates for this subsector no longer apply.
Applies at
destination / import
Competent authority
US Environmental Protection Agency (EPA)
Documents and approvals
Refrigerant designation and GWP
Charge capacity
Installation date / building-permit evidence where relevant
Checked: Record updated: Source date: Next review:
Licence or approval requiredUnited StatesInstallation & service
US Section 608 technician certification
Technicians who maintain, service, repair or dispose of equipment that could release refrigerants into the atmosphere must be certified under EPA's Section 608 programme; the certification type depends on the equipment.
Applies at
destination / import
Competent authority
US Environmental Protection Agency (EPA)
Documents and approvals
Section 608 technician certification of the type matching the equipment
US energy standards for walk-in coolers and freezers
Walk-in coolers and freezers in the United States are subject to DOE energy conservation standards and test procedures (10 CFR Part 431, Subpart R), and manufacturers of walk-in panels, doors and refrigeration systems must certify compliance to DOE (10 CFR 429.53).
Shippers, loaders, carriers by motor or rail vehicle and receivers transporting human or animal food in the United States must meet FDA's sanitary transportation requirements (21 CFR Part 1, Subpart O), including temperature conditions where needed for food safety. Separately, FDA states it will not enforce the Food Traceability Rule (FSMA 204) before 20 July 2028.
Applies at
destination / import
Competent authority
US Food and Drug Administration (FDA)
Documents and approvals
Written procedures and training records required by the rule
Temperature specifications agreed between shipper and carrier
Checked: Record updated: Source date: not stated on the source pageNext review:
How ColdMatch screens requests and suppliers
Before a supplier is listed or an RFQ moves forward, the team identifies the product or service, its origin, destination, transit route and intended use.
We check sanctions, trade bans, licences and permits, standards, labelling, safety, customs and transport rules that appear relevant, using official sources.
If an official source confirms an item is prohibited, it is blocked. Restricted or unclear items are paused until verified. The source, decision, reviewer and date are recorded.
Commercial introductions happen only after the request has been collected and reviewed. Suitable B2B projects start from USD 250,000.
Who is responsible for what
Global B2B Group and its platforms, including ColdMatch, are committed to conducting their own activities in accordance with applicable laws and regulations. Each participant remains responsible for the legal requirements that apply to its own role. Requirements differ by product, route and jurisdiction, so no single checklist applies everywhere.
ColdMatch's role: ColdMatch facilitates sourcing and RFQs for refrigeration and cold-chain projects. It does not itself manufacture, sell, import or export the listed equipment, refrigerants or services, and it is not a regulatory authority or certification body.
Suppliers, manufacturers and exporters: they are responsible for ensuring that the products and services they offer and supply meet the requirements that apply in the countries of origin and destination, where relevant. Depending on the product and jurisdiction, these can include product safety, electrical and pressure-equipment conformity, energy-efficiency rules, refrigerant restrictions, quotas or licences, technician certification, labelling, traceability, export controls, customs classification and shipping documents.
Cold storage, transport and logistics providers: they are responsible for the licences, handling rules, temperature records and any sanitary or phytosanitary documents that apply to the goods they store or move, where relevant.
Buyers and importers: they remain responsible for their own import permissions and registrations, local installation, building and environmental requirements, and their own due diligence before ordering. Buyers and suppliers must provide accurate information and documents.
Limits: the ColdMatch team makes reasonable checks of requests and suppliers using the information provided and official sources. These checks do not guarantee that any supplier, product or shipment complies, do not replace an authority's approval or legal advice, and no contract term can remove obligations that applicable law places on a party.
Report incorrect or outdated information
If a record is wrong or out of date, tell us which record and the official source. We review reports before the next scheduled check.
