F-gas Regulation III: the challenges of the new regulation

The F-Gas III regulation, in force since March 2024, broadens the scope of fluorinated GHGs covered, reinforces controls, leak detection and training obligations.

Juliette Virly
EHS Consultant
Update : 
12.09.2025
Publication: 
08.03.2024
Contents
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As part of the European Green Pact and with the aim of reducing greenhouse gas emissions to achieve carbon neutrality by 2050, the new greenhouse gas regulation of February 7, 2024 strengthens the rules on the use of fluorinated greenhouse gases (GHGs).

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.

Extended scope of application

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

The fluorinated GHGs newly covered by 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).

Adaptation of provisions on the containment of fluorinated GHGs

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
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 TCO2 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 TCO2 eq.
Electrical switchgear HFCs, PFCs, SF6 and other (per)fluorinated compounds and fluorinated nitriles*. Load ≥ 500 TCO2 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).

Changes in company 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.

New bans on the use of fluorinated GHGs

Timetable for banning the use of fluorinated GHGs
Timetable for banning the use of fluorinated GHGs

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New bans on the marketing of fluorinated GHGs

Timetable for marketing bans on fluorinated greenhouse gases
Timetable for marketing bans on fluorinated greenhouse gases

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