What has to come with a refrigerant cylinder

Quick answer

Four documents surround a lawful cylinder, and they answer different questions.

A delivery that arrives with none of them is not a bargain. It is a compliance problem you have taken possession of.

The label: what must be on it

Article 12(1)(g) of Regulation (EU) 2024/573 puts all fluorinated greenhouse gas containers under the labelling requirement. Article 12(3) sets the content:

• an indication that the product or equipment contains fluorinated greenhouse gases, or that its functioning relies on them;
• the accepted industry designation for the gases concerned or, where none exists, the chemical name;
• the quantity expressed in weight and in CO2 equivalent, and the global warming potential of those gases.

Implementing Regulation (EU) 2024/2174 fixes the form. The label must include the text “contains fluorinated greenhouse gases”. Weight is expressed in kilograms or grams and the CO2 equivalent in tonnes, using the global warming potential values listed in the column “GWP” in Annexes I, II and III to the regulation.

The label has to stand out clearly from its background, be of a readable size and spacing, remain securely in place and stay legible under normal operating conditions throughout the period the container holds the gas. Article 12(4) requires it to be clearly legible and indelible, and to be written in the official languages of the Member State where the goods are placed on the market, made available or supplied.

Where a container is also labelled under Regulation (EC) No 1272/2008 — the CLP Regulation — the F-gas information goes in the section for supplemental information on the CLP label.

The special label texts

Some cylinders carry an extra line that changes what you may lawfully do with the contents. Implementing Regulation (EU) 2024/2174 sets the exact wording.

For hydrofluorocarbons listed in Section 1 of Annex I, several of those texts have to be completed by the statement “Exempted from quota under Regulation (EU) 2024/573 of the European Parliament and of the Council”. Article 12(14) adds the consequence: in the absence of that labelling, the hydrofluorocarbons are subject to the quota requirements of Article 16(1).

When the label has to be redone

Two situations require a fresh label, and both are easy to forget.

Refilled containers. Article 12(6): where relevant, refilled containers containing fluorinated greenhouse gases have to be relabelled with updated information as set out in the first subparagraph of Article 12(3). A cylinder that comes back from refilling with last season's figures on it is not correctly labelled.

Retrofitted equipment. The last subparagraph of Article 12(3): where products or equipment have been retrofitted and the fluorinated greenhouse gases have been changed, they must be relabelled with updated information. If you change the gas in a machine, the machine's label is part of the job.

Article 12(16) adds a related duty: the information in Article 12(3) and (5) has to be included in the instruction manuals for the products and equipment concerned, and for products and equipment containing gases with a GWP of 150 or more, also in descriptions used for advertising.

The safety data sheet

The safety data sheet is not an F-gas document — it comes from EU chemicals law, and its format is set by Commission Regulation (EU) 2020/878, which replaced Annex II to the REACH Regulation. It always has the same sixteen sections, in the same order:

Because the order is fixed, the sheet is navigable without reading it end to end. The composition of a blend is in section 3, first aid in section 4, what to do about a large release in section 6, and the transport classification — including the UN number and class for the gas you are carrying — in section 14.

The paperwork on either side of the sale

What the seller records. Article 7(3) requires undertakings supplying gases listed in Annex I or Section 1 of Annex II to keep records of the purchasers: the certificate number of each purchaser and the respective quantities purchased. Those records are kept at least five years and produced on request to the competent authority or the Commission. Article 7(4) adds a parallel record where non-hermetically sealed charged equipment is sold: the equipment sold, and the certified undertakings that will install it.

What backs a refillable cylinder. Article 11(4) requires the undertaking placing refillable containers on the market to produce a declaration of conformity evidencing binding return arrangements — actors, obligatory commitments and logistics — kept for at least five years. Suppliers to end users keep evidence of compliance with those arrangements for five years as well.

What an import needs. Article 23(3) requires the importer or declarant to give customs, in the customs declaration where relevant: the F-gas Portal registration identification number, the EORI number, the net mass of bulk gases and of gases contained in products and equipment, the commodity code, and the tonnes of CO2 equivalent. Article 23(6) requires importers of gases in refillable containers to make the declaration of conformity available when the declaration for release for free circulation is submitted.

Article 23(10) tells you what a physical customs control looks for: that the goods correspond to the licence and the customs declaration, that the product does not fall under the Article 11(1) or 11(3) prohibitions, and that the goods are appropriately labelled in accordance with Article 12 before release for free circulation.

If something is missing

Common mistakes

• Treating the label as decoration. It carries the legal identification of the contents and the basis for every tonne-of-CO2-equivalent calculation you make.
• Using the 20-year GWP column. The implementing regulation points at the “GWP” column of Annexes I, II and III.
• Ignoring a restrictive text. “For destruction only” or “For feedstock use only” is a legal condition, not a note.
• Not relabelling a refilled cylinder. Article 12(6) requires updated information.
• Not relabelling retrofitted equipment. Article 12(3) requires it when the gas has been changed.
• Keeping no safety data sheet. It is the source for first aid, release response and the transport classification.
• Assuming the seller's records are the seller's problem. Your certificate number is in them; an inspection can start from either end.
• Accepting a cylinder with no declaration of conformity behind it. Without binding return arrangements it may be a non-refillable container in law.

Checklist

• Label present, legible and indelibleSecurely attached and readable under normal conditions.
• “contains fluorinated greenhouse gases” on the labelThe exact text required by Implementing Regulation (EU) 2024/2174.
• Designation, weight, CO2 equivalent and GWP shownWeight in kg or g, CO2 equivalent in tonnes, GWP from the “GWP” column.
• Language correct for the marketOfficial languages of the Member State where it is placed on the market or supplied.
• Special texts read and understoodReclaimed, recycled, destruction, export, feedstock, MDI, military, semiconductor.
• Safety data sheet on file for every productCurrent version, sixteen sections.
• Declaration of conformity available for refillable cylindersWith the binding return arrangements identified.
• Purchase traceable to a certificate numberMatching what the seller records under Article 7(3).
• Import documents completePortal registration number, EORI, net mass, commodity code, tonnes of CO2 equivalent.

Frequently asked questions

Official sources

Articles 7, 11, 12 and 23 and the labelling and safety data sheet regulations were read directly in the Official Journal text through the EU Publications Office.

Currency of this guide and limits of responsibility

This is general information prepared by EgoLog from the regulations and official Commission material. It is not legal advice.

The safety data sheet for the specific product is the authority on how to handle it. Where a document is missing or contradictory, resolve it with the supplier before the cylinder is used.