F-Gas III: stricter obligations and controls

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🔎 Things to remember

A Broader Focus on Carbon Neutrality: As part of the European Green Deal, the new version of the F-Gas Regulation expands its scope to include newer technologies such as HFO refrigerants, while accelerating the drastic reduction of traditional HFCs.

Historic Tightening of Leak Detection Requirements: Operators are facing new maintenance obligations, including the introduction of a leak detection schedule based on gross mass in kilograms for HFO and the expansion of mandatory inspections to fleets of light and heavy-duty commercial vehicles by 2027.

Automated Leak Detectors: Regulations require the mandatory installation of automatic leak detection systems for large-scale refrigeration equipment or electrical switching equipment (threshold of 100 kg for HFOs and 500 metric tons of CO2 equivalent for other fluids).

A comprehensive overhaul of certifications and training: Technicians working on these systems—including air conditioning systems in various modes of transportation—must hold specific certifications, which will be reinforced by mandatory refresher courses or re-evaluations every 7 years starting in 2029.

As part of the European Green Deal and with the goal of reducing greenhouse gas emissions to achieve carbon neutrality by 2050, the new regulation of February 7, 2024, on greenhouse gases strengthens the rules governing the use of fluorinated greenhouse gases (F-gases).

Coming into force on March 11, 2024, the new F-Gas Regulation lays down provisions for the marketing, use, reduction and control of installations containing fluorinated GHGs. In particular, it aims to regulate the use of HFOs, accelerate the reduction of HFC use and set new marketing bans.

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Expanding the Scope of Application

The scope of the regulation has been broadened to take account of the development of technologies using new fluorinated GHGs: HFOs.

Thus, the fluorinated GHGs 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 GHGs are always included:

hydrofluorocarbons (HFCs);
perfluorocarbons (PFCs) ;
other perfluorinated compounds (e.g. SF6).

Need help implementing your CSR action plan? Let Tennaxia help you.

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Amendments to the Provisions on the Containment of Fluorinated Greenhouse Gases

Periodic inspection

Operators of equipment containing fluorinated GHGs must have a qualified person carry out periodic leak checks on such equipment.

As of March 13, 2027, the following equipment must be inspected for leaks:

Light commercial refrigerated vehicles ;
Intermodal containers ;
Air conditioning and heat pumps for heavy commercial vehicles, vans, non-road mobile machinery (used in agriculture, mining and construction), trains, subways, streetcars and aircraft.

Fluorinated GHGs newly covered by the regulation, i.e. HFOs, are now subject to leak checks at the frequencies defined below.

FLUID CATEGORY	EQUIPMENT REFRIGERANT CHARGE	INSPECTION FREQUENCY
FLUID CATEGORY	EQUIPMENT REFRIGERANT CHARGE	In the absence of a leak detection system	If a leak detection system is installed
HFCs, PFCs, other (per)fluorinated compounds and fluorinated nitriles*.	5 t. éq. CO₂ ≤ charge < 50 t. éq. CO₂	12 months	24 months
	50 t. éq. CO₂ ≤ charge < 500 t. éq. CO₂	6 months	12 months
	500 t._CO2 eq. ≤ load	3 months	6 months
Unsaturated HFCs* (e.g. HFC-1234yf, HFC-1234ze ...)	1 kg ≤ charge < 10 kg*	12 months	24 months
	10 kg ≤ charge < 100 kg*	6 months	12 months
	100 kg ≤ load*	3 months	6 months

*New provisions in the F-Gas regulation III.

It should be noted that, unlike the fluorinated GHGs already covered by the previous regulation (HFCs, PFCs, etc.), inspection frequencies are established on the basis of fluid charge in kg (and not in tonnes of CO2 equivalent). Please note that for older fluids, the charge is still based on tons of CO2 equivalent.

In addition, for these fluorinated GHGs, the frequency of leak checks remains unchanged.

Operators of equipment subject to periodic leak testing must keep a register of their equipment. The contents of this register are set out in the regulations.

Mandatory leak detection system

For certain equipment, leak detection systems must be installed to warn of leaks. 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 equal to or greater than 100 kg or containing (per)fluorinated (SF6) or fluorinated nitriles with a charge equal to or greater than 500 TCO2e ;
Rankine cycles containing (per)fluorinated (SF6) or fluorinated nitriles with a load of 500 TCO2e or more;
Electrical switchgear containing (per)fluorinated (SF6) or fluorinated nitriles with a load of 500 TCO2e or more.

Note: equipment containing HFCs and PFCs, already covered by the old regulations, remains subject to the existing requirements for load-dependent detection systems.

These leak detection systems must be inspected at regular intervals:

EQUIPMENT TYPES (FIXED)	FLUID CATEGORY	THRESHOLD REQUIRING THE INSTALLATION OF A LEAK DETECTION SYSTEM	INSPECTION INTERVALS FOR DETECTORS
Refrigeration, air conditioning, heat pump and fire protection equipment	HFCs, PFCs, SF6 and other (per)fluorinated compounds and fluorinated nitriles*.	Load ≥ 500 T_CO2 eq.	Annual
	Unsaturated HFCs (e.g. HFC-1234yf, HFC-1234ze)*	Load ≥ 100 kg*
Rankine cycles	HFCs, PFCs, SF6 and other (per)fluorinated compounds and fluorinated nitriles*.	Load ≥ 500 T_CO2 eq.
Electrical switchgear	HFCs, PFCs, SF6 and other (per)fluorinated compounds and fluorinated nitriles*.	Load ≥ 500 T_CO2 eq.	Half-yearly

*New provisions in the F-Gas regulation III.

In the event of a leak, a post-repair inspection must be carried out no sooner than 24 hours after the equipment has been put into operation, and no later than one month afterwards (previously, leak detection had to be carried out within a maximum of 24 hours).

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Trends in Corporate Certifications and Training

To carry out activities involving equipment containing fluorinated GHGs, individuals must hold specific training and certification. From now on, activities involving the following equipment will also be subject to training and certification requirements:

Rankine cycle ;
Refrigeration units for refrigerated trucks and trailers ;
Refrigeration units for refrigerated light commercial vehicles, intermodal containers, including reefer containers, and refrigerated railcars;
Air-conditioning equipment containing fluorinated GHGs or non-fluorinated alternatives, including natural refrigerants, in motor vehicles and mobile air-conditioning and heat pump equipment in heavy-duty vehicles, vans, non-road mobile machinery (used in agriculture, mining and construction), trains, subways, streetcars and aircraft.

Existing certificates and training attestations issued in accordance with the F-gas II regulation remain valid.

In addition, by March 12, 2029 at the latest, certified physical persons are required to have attended refresher courses or passed an assessment process. Refresher courses must be taken every 7 years thereafter.

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New Bans on the Use of Fluorinated Greenhouse Gases

Timetable for banning the use of fluorinated GHGs

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New Bans on the Marketing of Fluorinated Greenhouse Gases

Timetable for marketing bans on fluorinated greenhouse gases

Calendar	Prohibitions
January 1, 2025	• fire protection equipment containing fluorinated greenhouse gases (HFCs, PFCs), other (per)fluorinated compounds (SF6), and fluorinated nitriles;
	• any stand-alone refrigeration equipment, with the exception of chillers, that contains fluorinated greenhouse gases with a GWP ≥ 150;
	• commercial refrigerators and freezers (hermetically sealed equipment) containing other fluorinated greenhouse gases with a GWP ≥ 150;
	• Refrigeration equipment that contains or relies on fluorinated greenhouse gases with a GWP ≥ 2,500, except for equipment intended for applications designed to cool products to a temperature below –50 °C.
January 1, 2027	• (stationary) chillers that contain or rely on fluorinated greenhouse gases with a GWP of 150 or higher, for chillers with a rated capacity of 12 kW or less;
	• plug-in air conditioning units, monoblock air conditioning units, other stand-alone air conditioning units, and stand-alone heat pumps with a maximum rated capacity of ≤ 12 kW and containing fluorinated greenhouse gases with a GWP ≥ 150;
	• Monoblock air conditioning units and other stand-alone air conditioning equipment and stand-alone heat pumps with a maximum rated capacity of > 12 kW but not exceeding 50 kW, containing fluorinated greenhouse gases with a GWP of ≥ 150.
January 1, 2030	• technical aerosols containing fluorinated greenhouse gases, unless this is necessary to meet safety requirements or they are used for medical applications;
January 1, 2030	• Refrigeration equipment that contains or relies on fluorinated greenhouse gases with a GWP ≥ 150, except for equipment intended for applications designed to cool products to a temperature below –50 °C.
January 1, 2032	• (stationary) chillers that contain fluorinated greenhouse gases or whose operation depends on such gases, for chillers with a rated capacity of ≤ 12 kW;
	• plug-in air conditioning units, monoblock air conditioning units, other stand-alone air conditioning units, and stand-alone heat pumps with a maximum rated capacity of ≤ 12 kW and containing fluorinated greenhouse gases;
	• Other stand-alone air conditioning equipment and stand-alone heat pumps containing GHGs with a GWP ≥ 150.

Timetable for marketing bans on fluorinated greenhouse gases

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We invite you to check your equipment containing fluorinated greenhouse gases (refrigeration units, air conditioning, heat pumps, fire protection, etc.) in order to ..:

identify whether they are newly subject to leak testing and leak detection systems;
anticipate future charging bans.

Photo credit: 644392721 @David