Quick answer
Article 8(1) of Regulation (EU) 2024/573 puts one duty on the operator of equipment containing fluorinated greenhouse gases: ensure that those substances are recovered and, after the equipment is decommissioned, that they are recycled, reclaimed or destroyed.
The same paragraph says who may do it: recovery has to be carried out by natural persons who hold the relevant certificates provided for in Article 10.
Article 4(1) closes the alternative. Intentionally releasing fluorinated greenhouse gases into the atmosphere is prohibited where the release is not technically necessary for the intended use. Venting to save a trip is not a technical necessity.
Article 8 addresses the operator. In practice the operator discharges it by engaging a certified undertaking — and the record of what was recovered goes into the equipment record under Article 7(1)(c).
Which equipment the duty covers
Article 8 lists the equipment in two blocks. Stationary first, in paragraph 2:
- the cooling circuits of refrigeration and air conditioning equipment and heat pumps;
- equipment containing fluorinated greenhouse gas-based solvents;
- fire protection equipment;
- electrical switchgear.
Then mobile, in paragraph 3:
- (a) the cooling circuits of refrigeration units of refrigerated trucks and refrigerated trailers;
- (b) the cooling circuits of refrigeration units of refrigerated light-duty vehicles and intermodal containers, including reefers, and train wagons;
- (c) the cooling circuits of air conditioning equipment and heat pumps in heavy duty vehicles, vans, non-road mobile machinery used in agriculture, mining and construction, trains, metros, trams and aircraft.
Article 8(5) gives operators of the equipment in paragraph 3, points (b) and (c), until 12 March 2027 before the recovery obligation applies to them. Points (a) and the whole of paragraph 2 apply now.
Who is qualified to recover
The regulation splits the qualification by equipment type, and the split matters when you assign a job.
| Recovery from | Qualification required |
|---|---|
| Equipment listed in Article 8(2), and Article 8(3)(a) | Certificate under Article 10(1), first subparagraph, point (c) |
| Vehicle air conditioning within Directive 2006/40/EC | At least a training attestation under Article 10(1), second subparagraph |
| Mobile equipment in Article 8(3), points (b) and (c) | At least a training attestation |
| Road vehicle air conditioning outside Directive 2006/40/EC | At least a training attestation (Article 8(10), second subparagraph) |
| Products and equipment not listed at all | Appropriately qualified natural persons (Article 8(10)) |
For the stationary side the certificate types come from Implementing Regulation (EU) 2024/2215: A1 and A2 cover recovery among all the other activities, and Certificate D covers recovery alone, limited to equipment under 3 kg — or under 6 kg for labelled hermetically sealed systems.
What may be done with the gas afterwards
This is where most of the value — and most of the misunderstanding — sits.
Article 8(6): recovered fluorinated greenhouse gases listed in Annex I and Section 1 of Annex II shall not be used for filling or refilling equipment unless the gas has been recycled or reclaimed. Straight back into another machine is not allowed.
What the two words mean in practice. Reclaimed gas is reprocessed to a specified quality by a facility, and under Article 12(7) its container has to be labelled as reclaimed, including the batch number and the name and address of the reclamation facility in the Union. Implementing Regulation (EU) 2024/2174 sets the wording: “100 % Reclaimed” where there are no virgin substances, or, for mixtures, where virgin additions to adjust the composition do not exceed 10 % of the mass. Recycled gas carries “100 % Recycled” on the same basis.
Article 13 allows recycled gas above the GWP service thresholds only where it was recovered from that kind of equipment, and only for use by the undertaking that carried out the recovery, or the undertaking for which the recovery was done. It stays inside that relationship — it cannot be bought in.
Empty containers. Article 8(7) is easy to overlook: an undertaking that uses a container with these gases must, immediately prior to its disposal, arrange for the recovery of any residual gases so that they are recycled, reclaimed or destroyed. A cylinder that is not fully empty is not scrap.
Foam panels, other products, and destruction
Foams in buildings. From 1 January 2025, Article 8(8) and 8(9) put a duty on building owners and contractors. During renovation, refurbishment or demolition that involves removing foam panels — or foams in laminated boards installed in cavities or built-up structures — containing Annex I or Annex II Section 1 gases, emissions have to be avoided as far as possible by handling the foam or the gas so that the gases are destroyed. Where the gases are recovered, only appropriately qualified natural persons may do it.
Where removal is not technically feasible, the owner or contractor has to draw up documentation evidencing that infeasibility in the specific case, keep it for 5 years and produce it on request.
Anything else. Article 8(10) catches products and equipment not listed in paragraphs 2, 3, 8 or 9: the operator arranges recovery unless it can be established that it is not technically feasible or entails disproportionate costs, and ensures appropriately qualified persons carry it out — or arranges destruction without prior recovery.
Destruction. Under Article 8(11), gases listed in Section 1 of Annex I, and products and equipment containing them, may only be destroyed by a destruction technology approved by the Parties to the Protocol. Other fluorinated gases without an approved technology may only be destroyed by a technology complying with Union and national waste law.
Write it down — and the same job on an R-22 system
The record. Article 7(1)(c) requires the quantity of gases recovered to be entered in the equipment record, and point (g) requires the measures taken to recover and dispose of the gases when the equipment is decommissioned. Point (e) requires the identity of the undertaking that carried out the recovery, its certificate number where applicable, and — where the undertaking is a legal person — the natural person who did the work.
Ozone-depleting substances. An old R-22 machine is not covered by the F-gas Regulation at all. HCFC-22 sits in Annex I of Regulation (EU) 2024/590, and Article 20(1) of that regulation imposes its own recovery duty: substances contained in refrigeration and air conditioning equipment and heat pumps, solvent equipment, fire protection systems and fire extinguishers must be recovered during maintenance or servicing, or before dismantling or disposal, for destruction, recycling or reclamation.
Article 21(5) of the same regulation requires records of the quantities recovered, the identity of the undertaking that performed the work, and the dates and results of leak checks — kept for at least 5 years.
Common mistakes
- Venting because the job is small. Article 4(1) prohibits intentional release unless technically necessary for the intended use.
- Putting recovered gas straight into the next machine. Article 8(6) requires recycling or reclamation first.
- Buying “recycled” gas from a third party for a high-GWP system. The Article 13 exemption only covers gas recovered by, or for, the undertaking using it.
- Scrapping a cylinder with heel gas in it. Article 8(7) requires recovery of residual gases immediately before disposal.
- Assuming mobile equipment is out of scope. Refrigerated trucks and trailers are covered now; the rest of the mobile list from 12 March 2027.
- Treating a demolition job as someone else's problem. Since 1 January 2025 the duty on foam panels sits on the building owner and the contractor.
- Recording nothing. The recovered quantity is a mandatory field in the equipment record.
- Treating an R-22 system under the F-gas rules. It falls under Regulation (EU) 2024/590, with its own recovery and record duties.
Checklist
- Recovery planned before the job startsCylinder capacity, recovery machine and destination of the gas decided in advance.
- Right qualification on siteCertificate for stationary work; training attestation where the regulation allows it.
- Recovered quantity weighed and recordedArticle 7(1)(c), into the equipment record.
- Destination decided: recycle, reclaim or destroyReuse only after recycling or reclamation.
- Reclaimed gas label checked“100 % Reclaimed”, batch number, facility name and Union address.
- Residual gas removed before scrapping a cylinderArticle 8(7), immediately prior to disposal.
- Decommissioning entry completedArticle 7(1)(g): the measures taken to recover and dispose of the gases.
- Foam work assessedBuilding owner and contractor duties since 1 January 2025, with the infeasibility file if relevant.
- R-22 jobs handled under the ODS regulationRecovery under Article 20 and records under Article 21(5) of Regulation (EU) 2024/590.
Frequently asked questions
Can I reuse the gas I just recovered in the same system?
Not as it is. Article 8(6) prohibits using recovered gases listed in Annex I and Section 1 of Annex II to fill or refill equipment unless the gas has been recycled or reclaimed.
Who is allowed to recover?
For the equipment in Article 8(2) and Article 8(3)(a), a natural person holding the certificate required under Article 10(1), first subparagraph, point (c). For vehicle air conditioning under Directive 2006/40/EC and for the mobile equipment in Article 8(3), points (b) and (c), at least a training attestation.
Does the duty apply to refrigerated trailers?
Yes. The cooling circuits of refrigeration units of refrigerated trucks and refrigerated trailers are in Article 8(3)(a), which applies now. Points (b) and (c) apply from 12 March 2027.
What do I do with a nearly empty cylinder?
Article 8(7) requires the undertaking using the container to arrange for the recovery of any residual gases immediately before disposal, so that they are recycled, reclaimed or destroyed.
What is the difference between recycled and reclaimed?
Both are recovered gas that has been treated, but the labelling rules differ and so does what you may do with them. Reclaimed gas carries “100 % Reclaimed” under Implementing Regulation (EU) 2024/2174, with a batch number and the reclamation facility's name and Union address, and can be bought. Recycled gas carries “100 % Recycled” and, where it is used above the Article 13 GWP thresholds, may only be used by the undertaking that recovered it or the one it recovered for.
Do I need to record how much I recovered?
Yes. Article 7(1)(c) requires the quantity of gases recovered in the equipment record, and point (g) requires the recovery and disposal measures on decommissioning.
What about R-22?
R-22 is an ozone-depleting substance listed in Annex I to Regulation (EU) 2024/590, not a fluorinated greenhouse gas. Article 20(1) of that regulation requires recovery during maintenance or servicing, or before dismantling or disposal, for destruction, recycling or reclamation.
Who deals with foam panels in a demolition?
Since 1 January 2025, building owners and contractors, under Article 8(8) and 8(9). Where the gases are recovered, only appropriately qualified natural persons may do it, and where removal is not technically feasible the infeasibility has to be documented and kept for five years.
Official sources
Articles 4, 7, 8, 10 and 13 of the F-gas Regulation and Articles 20 and 21 of the ODS Regulation were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
Recovery is physical work on pressurised systems. This guide covers the legal duty, not the safe procedure — follow the equipment manufacturer's instructions and the safety data sheet for the refrigerant you are handling.
This is general information prepared by EgoLog from the regulations and official Commission material. It is not legal advice and it is not a work instruction.
Whether a specific job falls under Article 8 depends on the equipment and the gas. Where it is unclear, ask your national competent authority.