Can R-22 be imported into India?
How the import regime works
Import of ozone-depleting substances is not open. Under the ODS Rules, an importer must be registered with the designated authority, and quantities are allocated against India's Montreal Protocol consumption ceiling for the year.
Consumption in the Protocol's sense is production plus imports minus exports, which is why import licensing is the practical control point. The Ozone Cell administers registration and allocation, and customs clearance depends on the paperwork matching.
The ceiling steps down on the HPMP schedule: 67.5% below baseline by 2025, 97.5% by 2030, with a 2.5% servicing allowance to 2040. Import allocation follows that curve down.
Feedstock is a different category
Where R-22 is used as a feedstock, meaning it is chemically transformed into something else rather than released, the Montreal Protocol does not count it as controlled consumption. The main industrial route is R-22 converted to tetrafluoroethylene for PTFE production.
This is why R-22 continues to be produced in significant quantities while the refrigerant supply tightens. The two streams are legally distinct even though the molecule is identical, and the exemption attaches to the use rather than the substance. Our feedstock guide covers the mechanism.
What this means for a buyer
Almost nothing directly, and that is the point. A servicing buyer does not import R-22. They buy it domestically from a seller registered under Rule 6, and the import licensing has already happened upstream.
What it does explain is why R-22 pricing behaves the way it does. Supply is capped administratively rather than set by demand, so when servicing demand exceeds the allocation, price moves rather than volume. That is a different market structure from an ordinary industrial chemical.
Trade in used and reclaimed material
Reclaimed refrigerant does not escape the regime. Import of used or reclaimed ODS is controlled in the same way, and India has no organised domestic reclamation industry of the kind the US or EU operates. See reclamation in India.
We do not buy back old refrigerant and we do not sell reclaimed gas.
Quick answers
Is importing R-22 into India legal?
Only under licence and against an allocated quota, by an importer registered under the ODS Rules. It is not an ordinary commercial import.
Why is R-22 still produced if it is being phased out?
Feedstock use, where R-22 is chemically converted into another product such as PTFE, is exempt from Montreal Protocol control. That production is separate from refrigerant supply.
Do I need an import licence to buy R-22?
No. A servicing buyer purchases domestically from a seller registered under Rule 6. Import licensing happens upstream.
Can reclaimed R-22 be imported?
Import of used or reclaimed ozone-depleting substances is controlled in the same way as virgin material.
- ODS (Regulation and Control) Rules, 2000 · import registration and quota allocation · ozonecell.nic.in.
- UNEP Ozone Secretariat · Montreal Protocol feedstock exemption and consumption definitions · ozone.unep.org.
- Ozone Cell, MoEFCC · HCFC Phase-out Management Plan Stage III · PDF.
This guide is general information compiled from the cited sources — not legal, safety or engineering advice. Read our full disclaimer.
Related: The feedstock exemption · Availability after 2025 · HPMP Stage III · Reclamation in India