F-gas Regulation (EU) 2024/573

Under Article 3, the operator is the undertaking that exercises actual power over the technical functioning of the equipment. That is not necessarily the owner. Someone who rents an installation and runs it themselves can be the operator even if they do not own it. The duties lie with the owner only if a Member State has assigned them to the owner. Check rental and operating contracts on this point.

Leak checks are required under Article 5(1) when equipment contains at least 5 tonnes of CO₂ equivalent of fluorinated greenhouse gases, or at least 1 kg of unsaturated HFCs (Annex II Section 1). The tonnes of CO₂ equivalent follow from the charge in kilograms times the global warming potential, divided by 1,000. Covered are stationary refrigeration equipment, air conditioning, heat pumps, fire protection systems, organic Rankine cycles and electrical switchgear, as well as mobile equipment such as refrigerated vehicles and reefers.

Hermetically sealed equipment that is labeled as such is exempt from checks if it contains less than 10 tonnes of CO₂ equivalent or less than 2 kg of unsaturated HFCs. In residential buildings, the limit is 3 kg. The higher the global warming potential, the smaller the charge at which the duty starts. vi calculates the CO₂ equivalents per installation from the asset logbook.

The intervals depend on the charge. For less than 50 tonnes of CO₂ equivalent (for unsaturated HFCs, less than 10 kg), checks are required at least every 12 months. From 50 up to under 500 tonnes (10 to 100 kg), the interval is six months. From 500 tonnes (100 kg), it is three months. If a leakage detection system is installed, the intervals double to 24, 12 and 6 months (Article 5(6)).

For stationary refrigeration equipment, air conditioning, heat pumps and fire protection systems with 500 tonnes of CO₂ equivalent or more, and for unsaturated HFCs from 100 kg, a leakage detection system is mandatory. It must alert the operator or a service company of any leakage and be checked at least every 12 months to confirm it works properly (Article 6). For fire protection systems, the duty counts as met if the existing inspection system complies with ISO 14520 or EN 15004 and is inspected as often as paragraph 6 requires.

The extension to mobile equipment is new. For refrigeration units in light-duty refrigerated vehicles, reefers and refrigerated rail wagons, and for air conditioning and heat pumps in heavy-duty vehicles, vans, agricultural and construction machinery, trains and aircraft, the checking duty applies only from 12 March 2027. Operators of such fleets should record the equipment now and schedule technicians with the right certificates.

Leak checks on stationary refrigeration equipment, air conditioning, heat pumps, fire protection systems and organic Rankine cycles, and on refrigerated vehicles and reefers, are carried out by natural persons certified under Article 10 (Article 5(3)). For installation, maintenance, repair and decommissioning of this equipment, the company doing the work must also be certified (Article 4(7)). For air conditioning in commercial vehicles, trains and construction machinery, a training attestation is enough.

The German Chemicals Climate Protection Ordinance turns this into an operator duty: anyone who hands activities under Article 10 to another company must ensure that it can show the required competence certificate or company certificate (§ 14(1)). Ask to see the proof before you commission the work and keep copies. The certificate number also belongs in the logbook.

Watch the transition periods. Old competence certificates and company certificates remain valid until 12 March 2029. After that, you must show a refresher course no more than seven years old (§ 5(1) No. 2, § 17(3)). For equipment under Article 5(3) points (b) and (c), meaning refrigerated vehicles, reefers and mobile air conditioning, the German rules apply from 13 March 2027.

If a leak is detected, operators must ensure the equipment is repaired without undue delay (Article 4(5)). Where a leak in equipment subject to leak checks has been repaired, a person certified under Article 10 checks whether the repair was effective. That happens at the earliest after 24 hours of operation and no later than one month after the repair. For the mobile equipment in Article 5(3) points (a) to (c), the check can take place directly after the repair. Repair, follow-up check and result belong in the logbook.

Germany adds limits on annual refrigerant loss in normal operation (§ 2(1) ChemKlimaschutzV). For installations set up at their site after 30 June 2008, the limits are 3 percent below 10 kg charge, 2 percent from 10 to 100 kg and 1 percent above. For installations from 1 July 2005 to 30 June 2008, 6, 4 and 2 percent apply, and for older ones 8, 6 and 4 percent. With a 40 kg charge, a new installation may therefore lose at most 800 grams per year.

The operator must also ensure access to all detachable connections where technically possible and reasonable (§ 2(2)). The refrigerant loss is determined from the charge, the time and the sum of the top-up quantities (§ 1 No. 1). The top-up quantities in service reports are thus the basis for monitoring the limits. vi checks service reports for top-up quantities.

For each piece of equipment subject to leak checks, the operator keeps its own records (Article 7(1)). They contain the quantity and type of gases in the equipment, every top-up during maintenance or because of a leak with its date, the quantity of recovered gases and, for top-ups, whether the gas was recycled or reclaimed, with the name, address and where applicable certificate number of the facility. They also include details of the company that installed, serviced, repaired, checked or decommissioned the equipment, with its certificate number and, for a legal person, the natural person who did the work. The dates and results of leak checks and of all leak repairs must be recorded, and for decommissioning, the measures taken to recover and dispose of the gases.

The records must be kept at least five years unless they are stored in a database set up by the authorities. Companies that work for you keep copies for at least five years as well. On request, the records must be made available to the competent authority (Article 7(2)). The regulation prescribes no format.

In practice, the asset logbook for each installation is the place where everything comes together. Top-up quantities from service reports, technicians' certificate numbers and leak check results must match there. An incomplete logbook is an offense of its own with a fine.

Since 1 January 2025, using fluorinated greenhouse gases with a global warming potential of 2,500 or more for the maintenance or servicing of any refrigeration equipment has been prohibited (Article 13(3)). Before that, the ban applied only from a charge of 40 tonnes of CO₂ equivalent. Since 1 January 2026, the ban also covers air-conditioning equipment and heat pumps (Article 13(4)). That affects R404A, for example.

Exceptions apply to reclaimed gases when the containers are labeled accordingly, and to recycled gases that were recovered from such equipment and may only be used by the company that carried out the recovery or by the company for which it was done. For refrigeration equipment, this exception ends on 1 January 2030, for air conditioning and heat pumps on 1 January 2032. From 1 January 2032, using virgin gases with a global warming potential of 750 or more is also prohibited for servicing stationary refrigeration equipment other than chillers. Military equipment and cooling below minus 50 degrees Celsius are exempt.

A system running a high-GWP refrigerant therefore needs a conversion plan. If you keep servicing with reclaimed gas until 2030, you must clarify availability. Top-up quantities and the origin of the gas belong in the logbook so that you can show the use was lawful.

The regulation requires Member States to set effective, proportionate and dissuasive penalties (Article 31). These include fines and, for serious or repeated infringements, a temporary prohibition on using fluorinated greenhouse gases or equipment that contains them or relies on them to function.

In Germany, the Chemicals Sanctions Ordinance defines the offenses. Under § 13(6), it is an offense not to ensure that equipment undergoes a leak check, not to have a leak repaired, or not to install or not to check the leakage detection system. The Chemicals Act sets fines of up to 50,000 euros for this (§ 26(3) ChemG). Missing or incomplete records are an offense of their own under § 13(3) and cost up to 10,000 euros. The Chemicals Climate Protection Ordinance names further violations (§ 16): exceeding the loss limits, missing competence or a missing company certificate, and commissioning an uncertified company. For those, the same upper limit of 50,000 euros applies (§ 26(3) ChemG).

For serious or repeated infringements, the regulation provides for a temporary ban on using F-gases or equipment containing them. Focus on what cannot be repaired later: whether every leak check took place on time, and whether a record with a certificate number for each check is in the asset logbook.