Quick answer
A leakage detection system is not a comfort option. Above certain quantities Article 6 requires one, and it is the operator who answers for its existence.
- Mandatory for the stationary equipment in Article 5(2), points (a) to (d) — refrigeration, air conditioning, heat pumps and fire protection — containing 500 tonnes of CO2 equivalent or more of Annex I gases, or 100 kg or more of Section 1 Annex II gases.
- Mandatory as well for organic Rankine cycles and electrical switchgear, points (e) and (f), from 500 tonnes of CO2 equivalent, where they are installed from 1 January 2017.
- The system is itself checked: at least once every 12 months for points (a) to (e), at least once every 6 years for electrical switchgear.
- Effect on the calendar: where a system is installed, the intervals in Article 5(6) double.
No product standards, sensor technologies, alarm thresholds in ppm, brands or prices. The Regulation does not prescribe a technology; it defines the function, the threshold and the checking rhythm.
What counts as a detection system in the text
Article 3, point (26) defines a leakage detection system as a calibrated mechanical, electrical or electronic device for detecting leakage of fluorinated greenhouse gases which, on detection, alerts the operator.
Three elements follow straight from the definition. The device has to be calibrated. It has to detect the gas, not merely an indirect symptom. And it has to alert, that is, produce a signal that reaches somebody.
Article 6(1) and (2) complete the addressee of that alert: the system must alert the operator or a service company. A device that raises a local error without the alert reaching the operator or the servicing firm does not meet the wording of the text.
The text prescribes no product standard, no sensor technology and no alarm threshold. Those choices stay with the designer and with the safety requirements applicable at the place of installation.
When it becomes mandatory
Article 6 applies to stationary equipment listed in Article 5(2) only. The mobile equipment of Article 5(3) is not covered by Article 6.
| Equipment | Threshold | Extra condition | Basis |
|---|---|---|---|
| Refrigeration, air-conditioning equipment, heat pumps, fire protection — Article 5(2), points (a) to (d) | 500 t CO2 equivalent (Annex I) or 100 kg (Section 1 of Annex II) | None | Article 6(1) |
| Organic Rankine cycles and electrical switchgear — points (e) and (f) | 500 t CO2 equivalent (Annex I) | Installed from 1 January 2017 | Article 6(2) |
The differences are worth reading carefully. For points (a) to (d) the kilogram threshold for Section 1 Annex II gases exists; in paragraph 2 it does not appear, only the tonnes of CO2 equivalent. And the date condition — installed from 1 January 2017 — appears in paragraph 2 only.
The CO2 equivalent is calculated exactly as it is for the checks: kilograms × GWP ÷ 1000. For the typical large applications, see chillers and commercial refrigeration.
The system is checked in its own right
A detector that does not work is worse than no detector, because it creates false confidence. The Regulation treats that risk separately.
- Article 6(3): operators of the stationary equipment in Article 5(2), points (a) to (e), that is subject to paragraph 1 or 2 shall ensure that leakage detection systems are checked at least once every 12 months to ensure their proper functioning.
- Article 6(4): for electrical switchgear, point (f), that is subject to paragraph 2, the check is carried out at least once every 6 years.
Two observations follow directly from the text. First, the check of the system is not the leak check of Article 5; they are distinct duties with different bases and different rhythms. Second, Article 6 does not name a qualification for checking the detection system. Where the operation involves activities covered by Article 10(1), the certification requirements of that article apply.
The seven record fields in Article 7(1) do not include the check of the detection system. Writing down the date and the result remains the simplest evidence that the duty in Article 6(3) was met.
The effect on leak check intervals
Article 5(6) links the presence of a detection system directly to the checking frequency. The wording in each point is "where a leakage detection system is installed in such equipment".
| Charge | Without a system | With a system | Basis |
|---|---|---|---|
| Under 50 t CO2e, or under 10 kg | At least every 12 months | At least every 24 months | Article 5(6), point (a) |
| 50 to under 500 t CO2e, or 10 to under 100 kg | At least every 6 months | At least every 12 months | Article 5(6), point (b) |
| 500 t CO2e or more, or 100 kg or more | At least every 3 months | At least every 6 months | Article 5(6), point (c) |
The last row describes, in practice, exactly the situation in which the system is mandatory anyway under Article 6(1): at 500 tonnes or 100 kg the effective interval is 6 months.
The first two rows describe a voluntary installation. Article 5(6) does not make the doubling conditional on the system being compulsory; it turns on the system being installed. An operator who fits one below the threshold therefore gets the longer interval, and once fitted the system falls under the checking duty of Article 6(3) if the equipment is subject to paragraph 1 or 2. The full set of intervals is explained in leak check frequency.
What a detection system does not replace
The alarm changes the rhythm, not the duty. Nothing in Article 6 takes the equipment out of the other articles.
- The periodic check is still due — Article 5(1), at the doubled interval from paragraph 6.
- The precautions remain — Article 4(3) requires all technically and economically feasible measures to minimise leakage.
- The repair duty remains — Article 4(5), first subparagraph: where a leakage is detected, the equipment is repaired without undue delay. A detection made by the system is still a detection.
- The verification check remains — Article 4(5), second subparagraph, for equipment subject to Article 5(1): a check at the earliest after 24 hours of operating time and not later than 1 month after the repair, by a certified person. See after a major leak.
- The records remain — Article 7(1), with its seven fields. See F-gas equipment records.
For equipment that does not reach the checking threshold at all, the position is set out separately in equipment below the threshold.
Common mistakes
- Applying the threshold to mobile equipment. Article 6 addresses only the stationary equipment listed in Article 5(2).
- Extending the date condition to everything. "Installed from 1 January 2017" appears in paragraph 2 only, for organic Rankine cycles and electrical switchgear.
- Confusing the system check with the leak check. They are two distinct duties: Article 6(3) and (4) on one side, Article 5(1) and (6) on the other.
- Using the 6-year interval too widely. It concerns electrical switchgear, point (f), only; for points (a) to (e) the interval is 12 months.
- An alarm that reaches nobody. Article 6(1) and (2) require the operator or a service company to be alerted.
- Assuming the system suspends the checks. It doubles their interval; it does not remove them.
Checklist for detection systems
- You have the charge in tonnes of CO2 equivalent and in kilogramsBoth scales matter: Annex I in tonnes of CO2 equivalent, Section 1 of Annex II in kilograms.
- You have identified which point of Article 5(2) the equipment falls underPoints (a) to (d) fall under Article 6(1); points (e) and (f) under Article 6(2).
- For points (e) and (f) you have checked the installation dateThe duty in paragraph 2 concerns equipment installed from 1 January 2017.
- The alert actually reaches the operator or the servicing firmArticle 6(1) and (2).
- The system check is scheduled every 12 monthsArticle 6(3), for points (a) to (e).
- For electrical switchgear the check is scheduled every 6 yearsArticle 6(4).
- The leak check interval was recalculated after installationArticle 5(6): 12 becomes 24, 6 becomes 12, 3 becomes 6 months.
- The date and result of the system check are written downNot among the Article 7(1) fields, but the simplest evidence there is.
- When an alarm goes off, the repair starts without undue delayArticle 4(5), first subparagraph.
Frequently asked questions
Does a detection system replace the periodic leak check?
No. Article 5(1) continues to apply, and paragraph 6 only provides longer intervals where a system is installed: 24 instead of 12 months, 12 instead of 6, and 6 instead of 3.
Can I fit one voluntarily on a small system to check less often?
Article 5(6) speaks of the case "where a leakage detection system is installed in such equipment", without requiring the system to be compulsory. Once fitted, it has to match the definition in Article 3, point (26), and if the equipment is subject to Article 6(1) or (2) the checking duty in paragraph 3 applies as well.
Do refrigerated trucks need a detection system?
Article 6 covers only the stationary equipment listed in Article 5(2). The refrigeration units of refrigerated trucks and trailers sit in Article 5(3), point (a), and are not covered by Article 6.
Who may check the detection system?
Article 6(3) and (4) place the duty on the operator and do not name a qualification for that check. Where the operation involves activities listed in Article 10(1), the certification requirements of that article apply.
Does the system check go into the equipment record?
The mandatory fields in Article 7(1), points (a) to (g), do not mention it. The text does not forbid recording it either, and a note with the date and the result is the simplest evidence of compliance with Article 6(3).
What do I do if the system reports a leak between two checks?
Article 4(5), first subparagraph, applies: the equipment is repaired without undue delay. For equipment subject to Article 5(1) the verification check in the second subparagraph then follows, at the earliest after 24 hours of operating time and not later than 1 month after the repair.
Official sources
The thresholds, intervals and the definition were read in the Official Journal text.
Currency of this guide and limits of responsibility
This page reproduces Article 6 of Regulation (EU) 2024/573 and its link with Article 5. It recommends no product, sets no alarm thresholds, and does not replace the safety requirements applicable at the place of installation, in particular for flammable or toxic gases.
General information prepared by EgoLog from the Regulation and from official European Commission material. It is not legal advice and it is not design work.
Installation, commissioning and work on circuits containing fluorinated greenhouse gases are carried out by qualified personnel, under the conditions of Article 10.