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🔎 Key takeaways
Broader Targeting for Carbon Neutrality: As part of the European Green Deal, the new version of the F-Gas regulation expands its scope to recent technologies like HFO fluids, while accelerating the drastic reduction of traditional HFCs.
Historic Tightening of Leak Checks: Operators face new maintenance obligations, including the introduction of a leak detection schedule based on gross mass in kilograms for HFOs, and the extension of mandatory checks to light and heavy commercial vehicle fleets by 2027.
Leak Detectors Now Automated: The regulation mandates the compulsory installation of automatic leak detection systems for large volumes of refrigeration or electrical switchgear equipment (threshold starting at 100 kg for HFOs and 500 tonnes CO2 equivalent for other fluids).
A Complete Overhaul of Certifications and Training: Technicians working on these installations — including air conditioning systems in various modes of transport — must hold specific certifications, reinforced by mandatory refresher courses or re-evaluations every 7 years starting from 2029.
As part of the European Green Deal and with the aim of reducing greenhouse gas emissions to achieve carbon neutrality by 2050, the new regulation of February 7, 2024, concerning greenhouse gases strengthens the rules regarding the use of fluorinated greenhouse gases (F-gases).
Having entered into force on March 11, 2024, the new F-Gas regulation sets out provisions concerning the placing on the market, use, reduction, and control of installations containing fluorinated greenhouse gases. It aims in particular to regulate the use of HFOs, accelerate the reduction of HFC use, and establish new market prohibitions.
Expansion of Scope
The scope of the regulation is expanded to take into account the development of technologies using new fluorinated greenhouse gases: HFOs.
Thus, the F-gases newly covered by the provisions of the regulation are:
- unsaturated hydro(chloro)fluorocarbons (known as HFOs), e.g., R.1234yf;
- fluorinated substances used as inhalation anaesthetics;
- other perfluorinated compounds (e.g., NF3)
- fluorinated ethers, ketones, and alcohols.
The following fluorinated greenhouse gases (F-gases) are still covered:
- hydrofluorocarbons (HFC);
- perfluorocarbons (PFCs);
- other perfluorinated compounds (e.g., SF6).
Adaptation of provisions relating to the containment of fluorinated greenhouse gases (F-gases)
Periodic inspection
Operators of equipment containing fluorinated greenhouse gases (F-gases) must have these equipments periodically checked for leaks by a qualified person.
As of March 13, 2027, the following equipment must undergo a leak check:
- Refrigerated light commercial vehicles;
- Intermodal containers;
- Air conditioning and heat pumps in heavy-duty commercial vehicles, vans, non-road mobile machinery (used in agriculture, mining, and construction), trains, subways, trams, and aircraft.
Fluorinated greenhouse gases (F-gases) newly covered by the regulation, i.e., HFOs, must now undergo leak checks according to the frequencies defined below.
| FLUID CATEGORY | REFRIGERANT CHARGE OF THE EQUIPMENT | INSPECTION FREQUENCY | |
| Without a leak detection system | With a leak detection system | ||
| HFCs, PFCs, other (per)fluorinated compounds and fluorinated nitriles* | 5 t. CO2 eq. ≤ charge < 50 t. CO2 eq. | 12 months | 24 months |
| 50 t. CO2 eq. ≤ charge < 500 t. CO2 eq. | 6 months | 12 months | |
| 500 t. CO2 eq. ≤ charge | 3 months | 6 months | |
| Unsaturated HFCs* (e.g. HFC-1234yf, HFC-1234ze, etc.) | 1 kg ≤ charge < 10 kg* | 12 months* | 24 months* |
| 10 kg ≤ charge < 100 kg* | 6 months* | 12 months* | |
| 100 kg ≤ charge* | 3 months* | 6 months* | |
*New provisions from the F-Gas III regulation.
It should be noted that, unlike the fluorinated greenhouse gases (F-gases) already covered in the previous regulation (HFCs, PFCs, etc.), the inspection frequencies are established based on the refrigerant charge in kg (and not in CO2 equivalent tonnes). Please note, for older refrigerants, the charge is still considered in CO2 equivalent tonnes.
Furthermore, for these fluorinated greenhouse gases (F-gases), the frequency of leak checks remains unchanged.
Operators of equipment subject to periodic leak checks must maintain a register of their equipment. The content of this register is determined by the regulation.
Mandatory Leak Detection System
For certain equipment, leak detection systems must be installed to provide an alert in case of a leak. The following equipment must now be fitted with a leak detection system:
- Refrigeration, air conditioning, heat pump, and fire protection equipment containing HFOs with a fluid charge of 100 kg or more, or containing (per)fluorinated compounds (SF6) or fluorinated nitriles with a charge of 500 TCO2e or more;
- Rankine cycles containing (per)fluorinated compounds (SF6) or fluorinated nitriles with a charge of 500 TCO2e or more;
- Electrical switchgear containing (per)fluorinated compounds (SF6) or fluorinated nitriles with a charge of 500 TCO2e or more.
Note: equipment containing HFCs and PFCs, already covered by the previous regulation, remain subject to existing leak detection system obligations based on their charge.
These leak detection systems must undergo periodic inspection according to the defined frequencies:
| EQUIPMENT TYPES (STATIONARY) | FLUID CATEGORY | THRESHOLD REQUIRING A LEAK DETECTION SYSTEM | DETECTOR INSPECTION FREQUENCY |
| Refrigeration, air-conditioning, heat pump and fire protection equipment | HFCs, PFCs, SF6 and other (per)fluorinated compounds and fluorinated nitriles* | Charge ≥ 500 t. CO2 eq. | Annual |
| Unsaturated HFCs (e.g. HFC-1234yf, HFC-1234ze)* | Charge ≥ 100 kg* | ||
| Organic Rankine cycles | HFCs, PFCs, SF6 and other (per)fluorinated compounds and fluorinated nitriles* | Charge ≥ 500 t. CO2 eq. | |
| Electrical switchgear | HFCs, PFCs, SF6 and other (per)fluorinated compounds and fluorinated nitriles* | Charge ≥ 500 t. CO2 eq. | Six-monthly |
*New provisions stemming from the F-Gas III regulation.
In case of a leak, the post-repair check must be carried out no sooner than 24 hours after the equipment has been put back into operation and no later than one month after (previously, leak detection had to occur within a maximum of 24 hours).
Changes in company certifications and training
For activities involving equipment containing fluorinated GHGs, individuals must hold specific training and certification. Now, activities involving the following equipment are also subject to the training and certification requirement for personnel:
- Rankine cycles;
- Refrigeration units for refrigerated trucks and refrigerated trailers;
- Refrigeration units for refrigerated light commercial vehicles, intermodal containers, including refrigerated containers, and refrigerated railway wagons;
- Air conditioning equipment containing fluorinated GHGs or non-fluorinated alternative solutions, including natural refrigerants, in motor vehicles and mobile equipment; air conditioning and heat pumps in heavy-duty vehicles, vans, non-road mobile machinery (used in agriculture, mining, and construction), trains, metros, trams, and aircraft.
It is clarified that existing certificates and training attestations issued in accordance with the F-Gas II regulation remain valid.
Furthermore, by March 12, 2029, at the latest, certified individuals are required to have participated in refresher courses or to have passed an evaluation process. Subsequently, refresher training must be undertaken every 7 years.
New bans on the use of fluorinated GHGs
New prohibitions on placing F-gases on the market
Timeline of placing-on-market bans for fluorinated GHGs
| Timeline | Bans |
|---|---|
| 1 January 2025 | • fire protection equipment containing fluorinated GHGs: HFCs, PFCs, other (per)fluorinated compounds (SF6), fluorinated nitriles; |
| • any self-contained refrigeration equipment, except chillers, containing fluorinated GHGs with a GWP ≥ 150; | |
| • commercial refrigerators and freezers (hermetically sealed equipment) containing other fluorinated GHGs with a GWP ≥ 150; | |
| • refrigeration equipment containing, or whose operation relies on, fluorinated GHGs with a GWP ≥ 2,500, except equipment intended for applications designed to cool products to a temperature below −50°C. | |
| 1 January 2027 | • (stationary) chillers containing, or whose operation relies on, fluorinated GHGs with a GWP ≥ 150, for chillers with a rated capacity of 12 kW or less; |
| • plug-in air-conditioning equipment, single-split air-conditioning equipment, other self-contained air-conditioning equipment and self-contained heat pumps, with a maximum rated capacity ≤ 12 kW and containing fluorinated GHGs with a GWP ≥ 150; | |
| • single-split air-conditioning equipment and other self-contained air-conditioning equipment and self-contained heat pumps, with a maximum rated capacity > 12 kW but not exceeding 50 kW, containing fluorinated GHGs with a GWP ≥ 150. | |
| 1 January 2030 | • technical aerosols containing fluorinated greenhouse gases, unless required to meet safety requirements or used for medical applications; |
| • refrigeration equipment containing, or whose operation relies on, fluorinated GHGs with a GWP ≥ 150, except equipment intended for applications designed to cool products to a temperature below −50°C. | |
| 1 January 2032 | • (stationary) chillers containing, or whose operation relies on, fluorinated GHGs, for chillers with a rated capacity ≤ 12 kW; |
| • plug-in air-conditioning equipment, single-split air-conditioning equipment, other self-contained air-conditioning equipment and self-contained heat pumps, with a maximum rated capacity ≤ 12 kW and containing fluorinated GHGs; | |
| • other self-contained air-conditioning equipment and self-contained heat pumps containing GHGs with a GWP ≥ 150. |
Schedule of prohibitions on placing F-gases on the market
We encourage you to check your equipment containing fluorinated greenhouse gases (chillers, air conditioning, heat pumps, fire protection, etc.) to:
- identify if they are newly subject to leak checks and a leak detection system;
- prepare for future recharging bans.
Photo credit: 644392721 @David