Reclaimed, recycled and virgin refrigerant: the difference and the paper trail

Quick answer

The four words are not commercial synonyms, they are defined terms. Recovery is the collection and storage of the gas from equipment. Recycling is the reuse of recovered gas after a basic cleaning process. Reclamation is reprocessing to the equivalent performance of a virgin substance, in an authorised reclamation facility. Virgin means a substance that has not previously been used.

The difference has three practical consequences: recovered gas may not be used for refilling unless it has been recycled or reclaimed (Article 8(6)); a cylinder of reclaimed or recycled gas has to be labelled as such, and for reclamation with the batch number and the name and address of the facility (Article 12(7)); and some servicing prohibitions bite later for reclaimed or recycled gas (Article 13).

Recycled and reclaimed are not the same thing and one does not stand in for the other on paper. A batch described as recycled does not meet the written conditions for reclaimed, however clean it is.

The Article 3 definitions, side by side

All four terms are defined in Article 3 of Regulation (EU) 2024/573. The text is short and worth reading exactly:

Three elements in the reclamation definition are what separates it from recycling: performance equivalent to a virgin substance, an authorised facility with appropriate equipment and procedures, and that facility's ability to assess and attest to the level of quality. Recycling requires none of those three; it requires only a basic cleaning process including filtering and drying.

That last line deserves emphasis. Article 22(2) states, without conditions, that fluorinated greenhouse gases imported into the Union shall be considered as virgin gases. A batch brought in from outside the Union cannot be presented as reclaimed within the meaning of the regulation.

What you may do with recovered gas

The basic rule is short and carries no exception in the text.

In other words: you recover, but you do not put it straight back. Between recovery and refilling there has to be a recycling or reclamation step. The guide on the refrigerant recovery obligation covers the recovery duty itself in detail.

The rest of Article 8 completes the picture:

• Article 8(1) — operators of equipment containing fluorinated greenhouse gases shall ensure that those substances are recovered and that, after the decommissioning of the equipment, they are recycled, reclaimed or destroyed. Recovery is carried out by natural persons certified under Article 10.
• Article 8(7) — an undertaking that uses a container shall arrange, immediately prior to its disposal, for the recovery of any residual gases so that they are recycled, reclaimed or destroyed. An empty cylinder is not empty.
• Article 8(10) — for products and equipment outside the lists in paragraphs 2, 3, 8 and 9, operators shall arrange for recovery unless it is established that it is not technically feasible or entails disproportionate costs, and shall ensure the gases are recycled, reclaimed or destroyed.
• Article 8(13) — Member States shall promote the recovery, recycling, reclamation and destruction of the gases listed in Annexes I and II.

None of this turns recovered gas into a sellable product in itself. To be made available to someone else as refrigerant, it has to have gone through recycling or reclamation and to carry the matching label.

What has to be on the cylinder

Article 12(7) is the central provision for a reclaimed or recycled batch:

Note the asymmetry: for recycled gas, the indication that the substance has been recycled is enough; for reclaimed gas, the batch number and the identity of the facility are added. That is exactly the information that makes a reclaimed batch checkable, and its absence is a signal.

Implementing Regulation (EU) 2024/2174 sets the exact wording. Under Article 1(7), the label on the container shall include, as relevant:

• "100 % Recycled" for recycled gases listed in Annexes I and II that do not contain any virgin substances.
• "100 % Reclaimed" for reclaimed gases listed in Annexes I and II that do not contain any virgin substances or, in the case of mixtures, where the addition of virgin substances to adjust the mixture composition does not exceed 10 % of the mass of the mixture.

That 10 % threshold is the only quantity of virgin substance the text expressly allows inside a batch labelled "100 % Reclaimed", and only for mixtures, and only to adjust the composition.

The rest of the label stays as usual. Article 12(3) requires the indication that fluorinated greenhouse gases are contained, the accepted industry designation, the quantity in weight and in CO2 equivalent, and the GWP. Article 1(3) of Regulation (EU) 2024/2174 adds the text "contains fluorinated greenhouse gases", and Article 1(4) states that the weight is expressed in kilogram or gram and the CO2 equivalent in tonne, using the GWP values in the relevant column of Annexes I, II and III. Article 12(6) requires refilled containers to be relabelled with updated information.

Where the container also has to be labelled under CLP, Article 1(6) of Regulation (EU) 2024/2174 requires this information to appear in the supplemental information section of the CLP label referred to in Article 25 of Regulation (EC) No 1272/2008. The full list of papers that travel with a cylinder is in the guide on documents with a refrigerant cylinder.

Why it matters in servicing: the Article 13 exceptions

Article 13 prohibits the use of certain gases for the maintenance and servicing of existing equipment. For reclaimed and for recycled gas, the prohibitions bite later or not at all, under precise conditions.

The conditions differ between the two categories and have to be read carefully:

• For reclaimed gas — the exception applies only where the containers holding those gases have been labelled in accordance with Article 12(7). The label is not an administrative detail, it is the condition of the exception.
• For recycled gas — the exception applies only where the gases have been recovered from such equipment, and the recycled gas may be used only by the undertaking which carried out the recovery as part of maintenance or servicing, or by the undertaking for which the recovery was carried out. It is a closed loop, not a market product.

Two further provisions are worth knowing. Article 13(6) allows the Commission, following a substantiated request by a competent authority and where its assessment points to a verified shortage of reclaimed or recycled gas, to authorise by implementing act an exemption from the prohibitions in paragraph 4 or 5 for up to 4 years. Article 13(7) runs the other way for SF6: from 1 January 2035, the use of SF6 for the maintenance or servicing of electrical switchgear is prohibited unless it is reclaimed or recycled, except where it is proved that reclaimed or recycled SF6 cannot be used on technical grounds or is not available in an emergency repair situation.

The full ban timetable is in the guide on the F-gas ban timetable.

What documents prove a batch is reclaimed

The regulation does not create a single reclamation certificate with a prescribed format. Traceability is built from elements that already exist and that have to agree with one another.

• The cylinder label — the indication of reclamation or recycling and, for reclamation, the batch number and the name and address of the reclamation facility in the Union (Article 12(7)), in the wording set by Article 1(7) of Regulation (EU) 2024/2174.
• The safety data sheet — product identity and composition, in the format required by Regulation (EU) 2020/878. The name on the label and the name in the sheet have to match; Article 18(1) of Regulation (EC) No 1272/2008 requires exactly that.
• The commercial document — the invoice or delivery note identifying the batch with the same number as the label. If the numbers do not match, traceability breaks there.
• The equipment record — Article 7(1), point (d), requires that, where gases have been added, the quantity and type are recorded together with whether they have been recycled or reclaimed, and the name and address in the Union of the recycling or reclamation facility and, where applicable, the certificate number. It is the one place in the regulation where this information becomes mandatory in the operator's records.
• The retention period — Article 7(2) requires those records to be kept for at least 5 years, both by the operator and, in copy, by the undertaking that carried out the work, unless the information is stored in a database set up by the competent authorities.
• The sales record — Article 7(3) obliges undertakings supplying Annex I or Section 1 Annex II gases to record each purchaser's certificate number and the quantities, for at least 5 years.

If the label and the safety data sheet disagree, see what to do when the cylinder label does not match the sheet. If you have reason to believe the batch is not what it claims, see the guide on counterfeit and illegal refrigerant. The detail on records is in the guide on F-gas equipment records.

Reporting and the position on quota

Reclamation is a reportable activity in its own right. Article 26(6) requires that, by 31 March 2025 and every year thereafter, each undertaking that reclaimed quantities exceeding 1 metric tonne or 100 tonnes of CO2 equivalent of fluorinated greenhouse gases shall report to the Commission the data specified in Annex IX on each of those substances for that calendar year.

Annex IX, point 8, says what is reported: the quantities of each substance listed in Annexes I, II and III that the undertaking has reclaimed, and any stocks held at the beginning and the end of the reporting period of each substance waiting to be reclaimed.

On the buying side, the rules on who may purchase bulk gas are the same whether the batch is virgin, recycled or reclaimed: see the guide on who can buy refrigerant gas.

Checklist when a reclaimed batch arrives

• The label expressly says the substance has been reclaimed or recycledArticle 12(7). Without that indication the batch cannot be treated as reclaimed.
• For reclamation, the label carries the batch numberArticle 12(7). It is the element that ties the cylinder to the facility.
• The label gives the name and address of the reclamation facility in the UnionArticle 12(7). The text expressly says the facility is in the Union.
• The label wording matches Regulation (EU) 2024/2174Article 1(7): 100 % Recycled or 100 % Reclaimed, as relevant.
• The batch number on the label matches the commercial documentIf it does not, stop there and ask for clarification in writing.
• The safety data sheet identifies the same product as the labelArticle 18(1) of Regulation (EC) No 1272/2008.
• You checked whether the batch is meant for an Article 13 exceptionThe reclaimed exception requires the Article 12(7) label; the recycled one requires the closed loop.
• You prepared the entry for the equipment recordArticle 7(1), point (d): quantity, type, recycled or reclaimed, name and address of the facility, certificate number where there is one.
• You settled who keeps the records and for how longArticle 7(2): at least 5 years, by the operator and in copy by the undertaking carrying out the work.

Frequently asked questions

Official sources

The definitions, duties and thresholds cited were read directly in the Official Journal text. The label wording comes from the applicable implementing regulation, and the hazard labelling rules from CLP.

Currency of this page and limits of responsibility

General information prepared by EgoLog from the regulation and official Commission material. It is not legal advice.

Recovery, recycling and reclamation involve handling gases under pressure and are carried out by certified persons. Confirm the applicable requirements with your supplier and your national competent authority.