Quick answer
Article 7(1) of Regulation (EU) 2024/573 requires the operator of equipment that has to be leak-checked under Article 5(1) to establish and keep records for each piece of such equipment.
“Each piece” is the part people get wrong. It is not one file for the supermarket — it is a record per machine, so that the history of a specific system can be followed from installation to decommissioning.
Seven items have to be in it. They are set out in points (a) to (g) of Article 7(1) and they are listed field by field below.
Article 29 requires competent authorities to carry out checks including on-site visits and verification of relevant documentation. Those checks are made without prior warning, except where prior notification is needed to make the check effective.
Which equipment needs a record
The record duty follows the leak-check duty. If Article 5(1) requires the equipment to be checked, Article 7(1) requires a record. If it does not, there is no Article 7(1) record.
| Test | Threshold |
|---|---|
| Annex I gases | 5 tonnes of CO2 equivalent or more |
| Annex II, Section 1 gases | 1 kilogram or more |
| Contained in foams | Excluded |
Hermetically sealed equipment is outside the check duty — and therefore outside the record duty — where it is labelled as hermetically sealed and contains less than 10 tonnes of CO2 equivalent of Annex I gases, or less than 2 kg of Annex II Section 1 gases. Hermetically sealed equipment installed in residential buildings is exempt below 3 kg.
Electrical switchgear is outside it where the tested leakage rate is below 0.1 % per year according to the manufacturer's technical specification and it is labelled accordingly, or it has a pressure or density monitoring device with an automatic alert, or it contains less than 6 kg of Annex I gases.
For Annex I gases the threshold is a CO2-equivalent figure: kilograms × GWP ÷ 1 000. A small charge of a high-GWP gas can cross 5 tonnes long before it looks large on the nameplate.
The seven fields
This is Article 7(1) in full, in the order the regulation sets them out.
| What has to be recorded | |
|---|---|
| (a) | The quantity and type of gases contained in the equipment, indicating separately, where applicable, the quantity added during installation. |
| (b) | The quantities of gases added during maintenance or servicing or due to leakage, including the date of each addition. |
| (c) | The quantity of gases recovered. |
| (d) | Where gases were added: their quantity and type, whether they were recycled or reclaimed, the name and address in the Union of the recycling or reclamation facility and, where applicable, its certificate number. |
| (e) | The identity of the undertaking that installed, serviced, maintained and, where applicable, recovered, repaired, checked for leaks or decommissioned the equipment — including, where applicable, its certificate number, and where that undertaking is a legal person, the identifying details of both the undertaking and the natural person who performed the operations. |
| (f) | The dates and results of the checks carried out under Article 5(1), as well as the dates and results of any leak repairs. |
| (g) | If the equipment was decommissioned, the measures taken to recover and dispose of the gases. |
Point (d) is the one most log sheets are missing. It is not enough to write “2 kg added”. Where the gas was recycled or reclaimed, the record has to name the facility, give its address in the Union, and where applicable its certificate number.
Point (e) is the second gap. A company name alone does not satisfy it where the servicing undertaking is a legal person: the record must identify both the company and the individual who did the work.
Who keeps it, and for how long
Article 7(2) opens with a condition that is easy to miss: the rules below apply unless the records are stored in a database set up by the competent authorities of the Member State. Where such a national database exists and is used, the retention duty sits there instead.
Otherwise:
- the operator keeps the records for at least 5 years;
- the undertakings carrying out the activities in point (e) — installation, servicing, maintenance, recovery, repair, leak checking, decommissioning — keep copies of those records for at least 5 years.
The records have to be made available, on request, to the competent authority of the Member State concerned or to the Commission.
The operator's record and the contractor's copy should tell the same story. Where they disagree — a top-up in one and not the other, different quantities, a missing repair date — that is exactly what an inspection surfaces.
What this means for the service company
Most of the entries in an operator's record are created by the contractor, on site, during a job. Practically, the service report is the source document.
A service report that feeds the record cleanly carries: the equipment identification, the gas type, the quantity added and the date, the quantity recovered, whether the gas was virgin, recycled or reclaimed with the facility details where relevant, the certificate number of the undertaking, the name of the technician who performed the work, the leak-check result, and the result of any repair.
Two obligations reinforce this from other articles:
- Article 7(3) — undertakings supplying Annex I or Annex II Section 1 gases keep records of the purchasers: certificate number and quantities, five years.
- Article 7(4) — undertakings selling non-hermetically sealed charged equipment keep records of the equipment sold and of the certified undertakings that will install it, five years.
The operator has to hold it. Handing over a paper ticket that never reaches the customer's file leaves the operator in breach — and leaves you without the copy you also have to keep.
The other records in Article 7
Article 7 is broader than the equipment log. Depending on what your business does, other paragraphs apply as well.
| Paragraph | Who | What |
|---|---|---|
| 7(1) and 7(2) | Operators, and the undertakings doing the work | The equipment record described above, plus the contractor's copy. |
| 7(3) | Undertakings supplying Annex I or Annex II Section 1 gases | Purchaser certificate numbers and quantities purchased. |
| 7(4) | Undertakings selling non-hermetically sealed charged equipment | The equipment sold and the certified undertakings that will install it. |
| 7(5) | Undertakings producing, placing on the market, supplying or receiving Annex I Section 1 substances for exempted uses | Substance name, quantities produced, imported, exported, reclaimed or destroyed, supplied and received per counterparty, contact details, quantity used and actual use, and stock on 1 January and 31 December. |
All of these carry the same five-year minimum, and all have to be produced on request. Article 7(6) allows the Commission to set the format of these records by implementing act.
Building a record sheet that survives an inspection
One sheet per machine
Identify the equipment unambiguously: location, manufacturer, model, serial number. A site-level file cannot answer Article 7(1).
State the charge and the CO2 equivalent
Gas type, kilograms, and the tonnes of CO2 equivalent that determine the check interval. Recalculate whenever the charge changes.
Date every movement of gas
Point (b) explicitly requires the date of each addition. Quantities without dates cannot be reconciled against the check schedule.
Record the origin of the gas
Virgin, recycled or reclaimed — and where recycled or reclaimed, the facility name, its address in the Union and its certificate number where applicable.
Name the company and the person
Point (e) requires both where the undertaking is a legal person, plus the certificate number where applicable.
Log the check result, not just the date
Point (f) asks for dates and results — of the leak check and of any repair.
Close the file properly
On decommissioning, point (g) requires the measures taken to recover and dispose of the gases.
Keep it retrievable for five years
Paper or digital both work. What matters is that it can be produced on request, and that the contractor's copy matches.
Common mistakes
- One folder for the whole site. Article 7(1) requires a record for each piece of equipment.
- Quantities without dates. Point (b) requires the date of each addition.
- No origin for the gas. Point (d) asks whether it was recycled or reclaimed, and for the facility's name, Union address and certificate number where applicable.
- Company name only. Where the undertaking is a legal person, point (e) requires both the company and the natural person who did the work.
- Recording that a check was done, but not what it found. Point (f) asks for results as well as dates.
- Nothing written when equipment is scrapped. Point (g) requires the recovery and disposal measures.
- The contractor keeping no copy. Article 7(2)(b) puts a five-year duty on the servicing undertaking too.
- Assuming a national database removes the duty. It only does so where the competent authorities have actually set one up and the records are stored in it.
Checklist
- A record exists per piece of equipmentIdentified by location, model and serial number.
- Charge recorded in kg and in tonnes of CO2 equivalentThe figure that sets the leak-check interval.
- Installation quantity shown separatelyPoint (a) asks for it where applicable.
- Every addition datedMaintenance, servicing and top-ups after leakage.
- Recovered quantities enteredPoint (c), including at decommissioning.
- Gas origin and facility detailsRecycled or reclaimed, with name, Union address and certificate number where applicable.
- Undertaking and technician both identifiedPlus the certificate number where applicable.
- Check and repair results recordedDates and results, not dates alone.
- Five-year retention on both sidesOperator's record and contractor's copy, retrievable on request.
Frequently asked questions
Which equipment needs a record?
Equipment that is required to be checked for leaks under Article 5(1) — that is, containing 5 tonnes of CO2 equivalent or more of Annex I gases, or 1 kg or more of Annex II Section 1 gases, other than gases contained in foams. Certain hermetically sealed equipment and electrical switchgear are exempt from the check duty and therefore from the record duty.
Can I keep one file for the whole site?
No. Article 7(1) requires records for each piece of equipment. A site-level file cannot show the history of an individual machine.
How long do the records have to be kept?
At least five years, both by the operator and, as copies, by the undertakings that installed, serviced, maintained, recovered from, repaired, leak-checked or decommissioned the equipment. This applies unless the records are stored in a database set up by the competent authorities of the Member State.
Does the service company have to keep a copy?
Yes. Article 7(2), point (b), requires undertakings carrying out the activities in Article 7(1)(e) for operators to keep copies of those records for at least five years.
Do I have to write down who did the work?
Yes. Point (e) requires the identity of the undertaking, its certificate number where applicable, and where the undertaking is a legal person, the identifying details of both the undertaking and the natural person who performed the operations.
Do I have to record where the gas came from?
Where gases have been added, point (d) requires their quantity and type, whether they were recycled or reclaimed, the name and address in the Union of the recycling or reclamation facility and, where applicable, its certificate number.
Is a digital record acceptable?
The regulation does not prescribe a medium. It requires the records to be established, kept for the retention period, and made available on request. Article 7(6) allows the Commission to determine the format by implementing act.
What happens when equipment is scrapped?
Point (g) requires the record to state the measures taken to recover and dispose of the gases. The recovery itself has to be carried out by a person holding the relevant certificate under Article 10.
Official sources
Articles 5, 7 and 29 were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
Some Member States operate their own database or prescribe a national form. Where they do, that form governs. The article references here were checked on the verification date shown at the top of the page.
This is general information prepared by EgoLog from the regulation and official Commission material. It is not legal advice.
Whether a specific machine is subject to the record duty depends on its charge, its gas and whether it is hermetically sealed. Where it is unclear, ask your national competent authority.