F-gases 2027:
The quota halves, the checking duty grows

Say a grocery store has a refrigeration system from 2012 in its plant room, filled with 40 kilograms of R404A. This refrigerant has a global warming potential, GWP for short, of 3,922, as the European Commission's price monitoring shows. The charge thus equals about 157 tonnes of CO₂ equivalent. If the system loses refrigerant, the technician has not been allowed to top it up with virgin refrigerant since 1 January 2025. Only reclaimed or recycled R404A is still permitted, and only until 1 January 2030. That is what Article 13 of the F-gas Regulation (EU) 2024/573 provides.

The Regulation has applied since 11 March 2024 and replaced its predecessor No 517/2014, according to the Umweltbundesamt (German Environment Agency). In 2027, several of its deadlines come together. On 1 January, the quantity of hydrofluorocarbons (HFCs) that may be placed on the EU market halves, and new equipment bans take effect. On 12 March, the grace period for leak checks on refrigerated containers and on air conditioning in trucks and trains ends.

From January, only half as much HFC may enter the market

The maximum quantities are set out in Annex VII of the Regulation. For 2025 and 2026 they are 42.9 million tonnes of CO₂ equivalent each, for 2027 to 2029 only 21.7 million. After that, the quantity falls in steps to zero in 2050. For the 2015 baseline, the annex gives 176.7 million tonnes. From 2027, about one eighth of that remains. Reclaimed and recycled HFCs are not covered by the quota.

Whether refrigerant becomes more expensive as a result remains unclear. The European Commission's price monitoring has so far reported no shortages. In the first quarter of 2026, R410A and R134a were 4 percent below the previous year, according to Cooling Post. Compared with 2014, both cost 3.3 to 10.9 times as much, depending on the trade level, according to the report for the end of 2025.

If you top up with high GWP, you need reclaimed refrigerant

For existing systems, Article 13 applies. Since January 2025, refrigeration systems of any size may no longer be serviced with F-gases of GWP 2,500 or more. Before that, this applied only from a charge of 40 tonnes of CO₂ equivalent. Since January 2026, this also applies to air conditioning systems and heat pumps. Reclaimed gases in labeled containers remain permitted, as do recycled gases, which only the company that recovered them or its client may use. This exception ends for refrigeration systems on 1 January 2030, and for air conditioning systems and heat pumps on 1 January 2032. From 2032, virgin refrigerant of GWP 750 or more is also banned for servicing stationary refrigeration systems, except for chillers.

This route is getting more expensive. Reclaimed R404A cost 140 percent of the price of virgin product in early 2025, according to the EU price monitoring. In the fourth quarter of 2025, the purchase price for service providers rose by a further 9 percent, and in the first quarter of 2026 by 12 percent, reports Cooling Post.

From 2027, many new units come only with a GWP below 150

From 1 January 2027, Annex IV bans placing on the market new self-contained air conditioners and heat pumps up to 50 kilowatts with F-gases of GWP 150 or more. The same applies to split air-to-water heat pumps up to 12 kilowatts. For chillers up to 12 kilowatts, the limit is also GWP 150, and for larger ones 750. Exceptions apply where safety requirements at the site demand it. Split air-to-air units up to 12 kilowatts follow in 2029.

Installed systems keep running. Since April 2026, § 12i of the German Chemicals Act (Chemikaliengesetz, ChemG) bans acquiring equipment that was placed on the market in breach of Annex IV. This can cost up to €200,000 (§ 26 ChemG). If you sell remaining stock, you must confirm to the buyer in writing or electronically that the unit was placed on the market before the ban date.

Leak checks: old thresholds, more systems

Little has changed in the intervals from Article 5. From 5 tonnes of CO₂ equivalent, systems are checked at least every twelve months, from 50 tonnes every six, and from 500 tonnes every three months. With a leak detection system, the intervals double. From 500 tonnes, such a system is mandatory and must itself be checked annually. Newly covered are unsaturated HFCs from Annex II Group 1, often called HFOs, including HFC-1234yf and HFC-1234ze with a GWP below 2. For them, weight counts: checks are required from 1 kilogram, with shorter intervals from 10 and from 100 kilograms. Labeled hermetically sealed equipment is exempt below 10 tonnes of CO₂ equivalent or 2 kilograms, and in residential buildings below 3 kilograms.

A leak that is found must be repaired without delay under Article 4(5). A certified person checks whether the repair holds, at the earliest after 24 hours of operation and at the latest after one month.

A transitional period ends on 12 March 2027. From then on, the checking obligation also applies to refrigeration systems in light refrigerated vehicles, refrigerated containers and refrigerated railway wagons, and also, among others, to air conditioning systems and heat pumps in heavy commercial vehicles, vans, construction and agricultural machinery, trains, trams and aircraft. For this air conditioning, personnel with a training attestation are sufficient. According to the German Chemicals Climate Protection Ordinance (ChemKlimaschutzV), the German competence and operator rules apply here from 13 March 2027. The EU standard requirements of 2007 for checking stationary refrigeration, air conditioning and heat pump systems were repealed without replacement by the Commission in July 2026.

Germany caps losses and requires refresher courses

Since 17 April 2026, a newly revised ChemKlimaschutzV has applied. It retains a German special feature: limits on the annual refrigerant loss of stationary refrigeration, air conditioning and heat pump systems. For systems installed after June 2008, the limits are 3 percent below 10 kilograms of charge, 2 percent up to 100 kilograms and 1 percent above that. For the example system in the grocery store, that means at most 800 grams a year. Older systems may lose up to 8 percent.

The refresher obligation is new. Competence certificates under the old rules remain valid until 12 March 2029. If you want to keep working, you convert to a new certificate by then through a refresher course and repeat the course every seven years, with no additional exam, as gefahrgut.de summarizes. You may skip the practical part if you declare that you carried out the activities in the two years before. Under Article 10, certification also covers alternatives such as natural refrigerants.

What the logbook must contain and what violations cost

For each system subject to checks, the operator keeps records under Article 7: type and quantity of refrigerant, each top-up with date, recovered quantities, origin of recycled or reclaimed product, the company and person who did the work with certificate number, and dates and results of checks and repairs. The operator keeps them for at least five years, and the service provider keeps a copy for just as long. The Regulation does not prescribe a format.

The operator must also ensure that contracted companies are certified and that checks are carried out by persons with the right competence certificate. Violations of this duty and a skipped leak check can cost up to €50,000 under § 26 ChemG and § 13 of the Chemikalien-Sanktionsverordnung (German Chemicals Sanctions Ordinance), and an incomplete logbook up to €10,000. In case of repeated or serious violations, the state authority can prohibit the handling of F-gases and F-gas equipment for up to 36 months, under the new § 23a ChemG in force since April 2026.

What operators and service providers should settle before March 2027

• Check the asset list: refrigerant, charge in kilograms and tonnes of CO₂ equivalent, check interval, including unsaturated HFCs from 1 kilogram.
• For refrigerants of GWP 2,500 or more, clarify the source and price of reclaimed product and plan the switch before 2030 or 2032.
• Record vehicles, refrigerated containers and machines with air conditioning or refrigeration systems, and plan checks for the period after 12 March 2027.
• File the certificates of service providers and their technicians, and schedule refresher courses before March 2029.
• Buy new air conditioners and heat pumps up to 50 kilowatts with a GWP below 150, and for remaining stock ask for the seller's declaration.

Nobody can say reliably today how strongly the halved quantity will affect prices. The deadlines, by contrast, are fixed. If you operate systems with a GWP of 2,500 or more, you still have a legal route for servicing until 2030 or 2032, and it has recently become more expensive.