Quick answer
The move from a high-GWP HFC to a low-GWP or natural refrigerant changes the legal picture in two directions at once, and people usually notice only one of them.
- The F-gas operating duties narrow. Leak checks under Article 5, the equipment record under Article 7 and the recovery duty under Article 8 of Regulation (EU) 2024/573 all attach to fluorinated greenhouse gases. A system running on ammonia, CO2 or a hydrocarbon is not carrying those particular obligations.
- The certification duty widens. Implementing Regulation (EU) 2024/2215 brings installation, repair, maintenance, servicing and decommissioning involving ammonia (NH3), carbon dioxide (CO2) or hydrocarbons inside the certification requirement. Natural refrigerants are not outside the scheme.
The F-gas Regulation is one instrument among several. Pressure equipment law, workplace safety law and the national rules that apply to flammable and toxic substances are unaffected by which refrigerant the EU classifies as fluorinated. Take those from your national competent authority and the equipment manufacturer's documentation, not from this regulation.
Which activities need a certificate, and for which substances
Article 2 of Implementing Regulation (EU) 2024/2215 is precise about this, and the precision matters: the alternatives are named for some activities and not for others.
| Activity (Article 2(1)) | Fluorinated gases | NH3, CO2, hydrocarbons |
|---|---|---|
| (a) Leak checks | Yes | Not named |
| (b) Installation | Yes | Yes |
| (c) Repair, maintenance or servicing, and decommissioning | Yes | Yes |
| (d) Recovery from the cooling circuits listed there | Yes | Not named |
Legal persons are covered in parallel. Article 2(2) applies to undertakings carrying out installation, repair, maintenance, servicing or decommissioning for third parties on the equipment in Article 1, containing the listed fluorinated gases and the alternative substances ammonia, CO2 or hydrocarbons.
The equipment list in Article 1 is the same either way: stationary refrigeration; stationary air conditioning and heat pump equipment; stationary organic Rankine cycles; refrigeration units of refrigerated trucks and trailers; and refrigeration units of refrigerated light-duty vehicles, intermodal containers and train wagons.
If your undertaking works on ammonia, CO2 or hydrocarbon systems for third parties, Articles 5 and 6 of the implementing regulation apply: a certificate for the legal person, conditional on employing enough certified natural persons and on proof that the necessary tools and procedures are available to them.
Which certificate covers which refrigerant
Article 3(2) sets six types. Three of them are relevant here.
| Certificate | Substances | Limit |
|---|---|---|
| A1 | Fluorinated greenhouse gases and hydrocarbons | No charge-size limit |
| A2 | Fluorinated greenhouse gases and hydrocarbons | Under 3 kg, or under 6 kg for labelled hermetically sealed systems |
| B | Carbon dioxide (CO2) | — |
| C | Ammonia (NH3) | — |
So hydrocarbons do not have their own certificate — they sit inside A1 and A2 alongside the fluorinated gases. CO2 and ammonia each have a dedicated one.
Annex I to the implementing regulation shows how that is examined. Every certificate covers the skills and knowledge groups under headings 1, 2, 3, 4, 5, 10 and 11. On top of that:
- A1 and A2 add heading 12 — installation and good practice of servicing for equipment relying on hydrocarbons — and at least one theoretical question must relate to the specifics of CO2 and ammonia, plus at least one to energy efficiency.
- Certificate B adds heading 13 — R744 (CO2) — and at least one question on the specifics of hydrocarbons.
- Certificate C adds heading 14 — R717 (NH3) — and at least one question on the specifics of hydrocarbons.
The examination also covers at least one of headings 6, 7, 8 and 9 — compressors, condensers, evaporators and expansion devices — and the candidate does not know in advance which.
What falls away — and what does not replace itself
Three familiar duties in the F-gas Regulation are written around fluorinated greenhouse gases, and do not follow a system that no longer contains one.
| Duty | Scope as written |
|---|---|
| Leak checks — Article 5(1) | Equipment containing 5 tonnes of CO2 equivalent or more of Annex I gases, or 1 kg or more of Annex II Section 1 gases. |
| Equipment record — Article 7(1) | Equipment which is required to be checked for leaks pursuant to Article 5(1). |
| Recovery — Article 8(1) | Operators of equipment that contain fluorinated greenhouse gases. |
| Emission prevention — Article 4 | Release of fluorinated greenhouse gases. |
What does not change is that the machine is still a pressurised system, often now with a flammable or toxic charge. Article 10(5) of the F-gas Regulation says as much about the training itself: certification programmes must cover applicable regulations and technical standards, emission prevention, recovery, safe handling of equipment of the type and size covered by the certificate, safe handling of equipment containing flammable or toxic gases or operating under high pressure or involving other relevant risks, and measures for improving or maintaining energy efficiency during installation or servicing.
The F-gas Regulation stops applying to the charge. The obligations that come from pressure equipment law, from workplace and fire safety law, and from national rules on flammable and toxic substances are a separate question and are not answered here. Confirm them with your national competent authority before the first job.
When the site cannot take a flammable refrigerant
Annex IV anticipates this. Many of its rows end with “except if required to meet safety requirements at the site of operation”, and points 8(b), 8(c), 8(d) and 8(e) go further: where safety requirements at the site of operation would not allow gases with a GWP of less than 150, the GWP limit is 750.
That is a real route, and it comes with three attached obligations.
- The equipment must say so. Article 12(15): in the cases referred to in points 8(b) to (e) and 9(b) to (f) of Annex IV — among others — the product or equipment must be labelled with an indication that it is to be used only where required by the safety requirements or national safety standards, and those requirements or standards must be specified on the label.
- The operator must be able to prove it. Article 13(19) prohibits putting into operation or using the listed equipment after the prohibition date unless the operator can show that the safety requirements at that particular location do not permit equipment using gases below the specified GWP, or that the equipment was placed on the market before the date.
- The file runs five years. Article 13(20).
The derogation is about a specific installation. It is evidenced, labelled and kept — not asserted.
Why the refresher deadline matters here in particular
Article 10(9) of the F-gas Regulation requires Member States, by 12 March 2027, to make certified natural persons take refresher training or complete an evaluation process at least every 7 years — and requires holders of certificates or training attestations issued under Regulation (EU) No 517/2014 to do so for the first time no later than 12 March 2029.
That matters more than usual on this topic. Certificates issued under the old scheme were examined against the old minimum requirements, which did not carry the hydrocarbon, CO2 and ammonia content that Annex I to Implementing Regulation (EU) 2024/2215 now sets out. Article 10 of that implementing regulation makes the point directly: holders of old Category I and II certificates may only continue using them if they update their knowledge and skills to the level required for Certificates A1 and A2 respectively.
If your first ammonia or CO2 contract is signed before the certificate covering it exists, the job cannot lawfully start. Article 10(12) also requires an undertaking to verify that a subcontractor holds the necessary certificates before assigning the activity.
Working through it before the first job
Decide which refrigerant families you will actually take on
Hydrocarbons sit inside A1 and A2. CO2 needs Certificate B and ammonia Certificate C. Taking on all three is three separate examinations.
Check the company certificate covers the work
Article 2(2) of the implementing regulation applies to installation, repair, maintenance, servicing and decommissioning for third parties, including the alternative substances.
Count the certified staff against the workload
Article 6(1)(a) requires a sufficient number to cover the expected volume of activities.
Prove the tools and procedures
Article 6(1)(b) is a condition of the company certificate, and for a flammable or toxic charge it is not a formality.
Book the refresher training early
First one by 12 March 2029 for old-regulation holders, then at least every seven years — and it is the route by which old certificates reach the current content.
Decide site by site whether the safety derogation applies
If it does, the label has to specify the requirements and the operator has to hold the evidence for five years.
Close out the F-gas file properly on a conversion
The old charge still has to be recovered under Article 8, the record still has to record it under Article 7(1)(c) and (g), and the equipment still has to be relabelled under Article 12(3).
Common mistakes
- Assuming natural refrigerants are outside certification. Article 2(1)(b) and (c) of Implementing Regulation (EU) 2024/2215 names ammonia, CO2 and hydrocarbons.
- Expecting a separate hydrocarbon certificate. Hydrocarbons are inside A1 and A2, not in a category of their own.
- Using an A1 certificate for a CO2 or ammonia job. Those are Certificates B and C.
- Reading “no more F-gas duties” as “no more duties”. Pressure, fire and workplace safety law are separate instruments.
- Claiming the safety derogation without labelling it. Article 12(15) requires the requirements or standards on the label.
- Keeping no evidence after commissioning. Article 13(19) and 13(20) put that on the operator for five years.
- Leaving the refresher until the deadline. The old certificate content predates the flammable-refrigerant material now in Annex I.
- Subcontracting without checking. Article 10(12) requires verification before the activity is assigned.
- Forgetting to close the F-gas record on conversion. Recovery, record entry and relabelling are all still due.
Checklist
- Refrigerant families decidedHydrocarbons under A1 or A2; CO2 under B; ammonia under C.
- Certificates held for the activities actually performedInstallation, repair, maintenance, servicing, decommissioning.
- Company certificate covers the alternative substancesArticle 2(2) of Implementing Regulation (EU) 2024/2215.
- Enough certified staff for the expected volumeArticle 6(1)(a).
- Tools and procedures demonstrably availableArticle 6(1)(b), and appropriate to a flammable or toxic charge.
- Refresher dates bookedFirst by 12 March 2029 for old-regulation holders, then at least every seven years.
- Safety derogation documented where usedLabel under Article 12(15); evidence kept five years under Article 13(20).
- National safety requirements confirmedPressure equipment, workplace and fire safety rules are outside the F-gas Regulation.
- Old F-gas charge properly closed outRecovery under Article 8, record under Article 7, relabelling under Article 12(3).
Frequently asked questions
Do I need a certificate to work on a CO2 or ammonia system?
Yes, for the activities in Article 2(1) of Implementing Regulation (EU) 2024/2215 — installation, repair, maintenance or servicing, and decommissioning. Certificate B covers carbon dioxide and Certificate C covers ammonia.
Is there a certificate for hydrocarbons?
Not a separate one. Certificates A1 and A2 cover all the Article 2(1) activities in relation to fluorinated greenhouse gases and hydrocarbons.
Do leak checks apply to an ammonia or CO2 plant?
Not under Article 5 of Regulation (EU) 2024/573, which applies to equipment containing fluorinated greenhouse gases above the stated thresholds. Requirements from other legislation are a separate question — confirm them with your national competent authority.
Does the Article 7 equipment record apply?
Article 7(1) applies to equipment which is required to be checked for leaks pursuant to Article 5(1), so it follows the same scope.
Does the recovery duty apply?
Article 8(1) is written for operators of equipment that contain fluorinated greenhouse gases. When you convert a system, the F-gas charge you remove is still subject to it.
What if the site cannot take a flammable refrigerant?
Annex IV allows for it. Several rows carry an exception where required to meet safety requirements at the site of operation, and points 8(b) to (e) set the GWP limit at 750 in that case. The equipment must be labelled under Article 12(15) specifying the requirements, and the operator must keep the evidence for five years under Article 13(20).
My technicians were certified years ago. Is that enough?
Their certificates remain valid on their original conditions under Article 10(9), but holders of old Category I and II certificates may only continue using them if they update their knowledge and skills to the A1 and A2 level, and the first refresher is due no later than 12 March 2029.
Can I subcontract the ammonia work?
Yes, but Article 10(12) of Regulation (EU) 2024/573 requires you to verify that the other undertaking holds the necessary certificates before assigning the activity.
Official sources
The F-gas Regulation and the certification implementing regulation were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
This guide covers what the F-gas framework requires. It does not set out the safety requirements for working with flammable, toxic or high-pressure refrigerants — those come from other legislation, from national rules and from the equipment manufacturer's documentation, and they take precedence over anything here.
This is general information prepared by EgoLog from the regulations and official Commission material. It is not legal, safety or engineering advice.
Certification and training programmes are run nationally. Confirm what your Member State requires before taking on work with a refrigerant you have not handled before.