Leak detection: obligations for refrigerants

A 2019 decree requires a leak detection system for fixed equipment containing >500 t CO2 eq. of refrigerants.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
03.10.2019

Refrigerants (e.g. R134a, R407c, R410a) are used in refrigeration and air-conditioning equipment such as chillers, air conditioners and heat pumps. These fluids are the source of certain greenhouse gases (GHGs). With the aim of controlling and reducing GHG emissions, regulations are becoming ever more stringent regarding the detection of refrigerant leaks.

We presented these regulations in a 2016 article, as well as previous developments in another 2017 article.

We propose to focus on certain equipment: fixed refrigeration, air-conditioning and thermodynamic equipment (*) with an HFC (e.g. R134a) or PFC (e.g. CF4) charge equal to or greater than 500 tonnes of CO2 equivalent. The latter must be fitted with a permanent leak detection system.

An order of July 15, 2019 amended the order of February 29, 2016 to specify the terms and conditions for implementing these systems.

(*) Fixed: not normally in motion during operation, including self-contained mobile air conditioners.

Mobile: normally on the move during operation

Prioritizing leak detection systems

The permanent HFC leak detection systems to be implemented are completed and prioritized:

1. A permanent HFC leak detection system based on an indirect measurement leak detection method (system no. 1) should be set up as a matter of priority.

As a reminder, such a system measures at least one of the following parameters:

  • pressure ;
  • temperature ;
  • compressor current ;
  • liquid levels ;
  • volume of the refilled quantity.

2. A permanent HFC leak detection system based on direct methods (system no. 2) can be implemented if the indirect measurement leak detection system cannot be implemented for technical reasons.

For the first two systems, the operator must be informed of the alarm at the latest when the leak leads to the greatest loss of HFCs, as shown below:

  • 50 grams per hour ;
  • 10% of the ton load of the fluid contained in the equipment.

In addition to these first two systems, there is a new possibility if the implementation of the previous systems is not technically possible:

The operator must then implement a permanent leak detection system that analyzes at least one of the following parameters:

  • pressure ;
  • temperature ;
  • compressor current ;
  • liquid levels ;
  • volume of the refilled quantity.

This system is linked to an alarm, for which the decree does not specify a trigger threshold, and a tightness check must be carried out every 3 months by direct measurement.

A study justifying the technical impossibility of implementing a permanent HFC leak detection system based on a leak detection method using indirect measurement (system no. 1) or direct measurement (system no. 2) must be carried out.

Leak detection system logbook

A register must now be set up to monitor the permanent leak detection system implemented. This register specifies :

  • fluids for which the permanent detection system is suitable;
  • a list of maintenance operations to keep it in good working order;
  • the results of any checks carried out, and any corrective action to be taken.

Frequency of leak checks

The frequency of periodic checks on equipment with a load greater than 500t CO2eq is specified according to the type of equipment (mobile or fixed) and the leak detection system in place:

Conclusion

We recommend that you review your refrigeration, air conditioning and thermodynamic equipment containing more than 500.t.eq CO2 in HFC/PFC with your maintenance department in order to :

  • set up a register to monitor your permanent leak detection systems;
  • draw up a study justifying the permanent leak detection system implemented if it does not operate by indirect measurement;
  • depending on the system used, adapt the frequency of leak checks.