The short answer
The Regulation treats transport refrigeration as mobile equipment, but not as one single category. It splits the fleet into two groups with the same thresholds and different timetables.
- Group 1 — Article 5(3), point (a): refrigeration units of refrigerated trucks and refrigerated trailers. For these, the leak check applies with no transitional date.
- Group 2 — Article 5(3), point (b): refrigeration units of refrigerated light-duty vehicles, intermodal containers including reefers, and train wagons. Article 5(5) provides that paragraphs 1 and 6 do not apply to their operators until 12 March 2027.
- Who checks: Article 5(3), second subparagraph, points to natural persons certified in accordance with Article 10, for both groups.
- What does not exist: no leakage detection system obligation (Article 6 concerns stationary equipment only) and no Annex IV entry for transport refrigeration.
No dangerous-goods transport requirements, no UN numbers, no ATP agreement requirements, no national penalty amounts, no prices and no delivery times. No charge size for any unit model either: that is read from the equipment label and the manufacturer documentation.
The definitions that decide which group you are in
Article 3 defines three vehicle types, and what separates them is mass and how they are moved, not the type of unit fitted.
| Term | Definition in Article 3 | Place in Article 5(3) |
|---|---|---|
| Refrigerated truck (point 23) | Motor vehicle with a mass of more than 3,5 tonnes, designed and constructed primarily to carry goods and equipped with a refrigeration unit | Point (a) |
| Refrigerated trailer (point 24) | Vehicle designed and constructed to be towed by a road vehicle or a tractor, primarily to carry goods, and equipped with a refrigeration unit | Point (a) |
| Refrigerated light-duty vehicle (point 25) | Motor vehicle with a mass of 3,5 tonnes or less, designed and constructed primarily to carry goods and equipped with a refrigeration unit | Point (b) |
| Intermodal containers and train wagons | Listed directly in the wording of point (b), together with reefers | Point (b) |
The object of the duty is the refrigeration unit, not the vehicle. A truck above 3,5 tonnes with no unit fitted falls nowhere; a unit mounted on a trailer falls under point (a) whatever the trailer happens to be carrying that day.
Cab air conditioning is a different entry altogether: it sits in Article 5(3), point (c), together with heavy duty vehicles and vans, and follows the rules described in the guide on vehicle air conditioning. One tractor unit can therefore carry two pieces of equipment governed by different rules on the same chassis.
Thresholds, intervals and records
The entry threshold. Article 5(1): operators and manufacturers of equipment that contains 5 tonnes of CO2 equivalent or more of the fluorinated greenhouse gases listed in Annex I, or 1 kilogram or more of gases listed in Section 1 of Annex II that is not contained in foams, shall ensure that the equipment is checked for leaks.
For the blends used in transport, the threshold in kilograms is 5 000 divided by the GWP of the blend calculated in accordance with Annex VI. At a GWP of 3 922, the case of R-404A, the threshold is reached at roughly 1,3 kilograms. At a GWP of about 2 139, the case of R-452A, it is reached at roughly 2,3 kilograms. In practice almost any transport unit is above the line.
The intervals. Article 5(6) uses the same bands as for stationary equipment:
| Contents | Without a detection system | With a detection system |
|---|---|---|
| Less than 50 t CO2 equivalent (Annex I) or less than 10 kg (Annex II Section 1) | At least every 12 months | At least every 24 months |
| 50 t CO2 equivalent or more but less than 500 t (or 10 kg or more but less than 100 kg) | At least every 6 months | At least every 12 months |
| 500 t CO2 equivalent or more (or 100 kg or more) | At least every 3 months | At least every 6 months |
The third column stays theoretical for transport: Article 6 imposes no detection system on mobile equipment, and fitting one voluntarily is not prohibited. Where a unit does have such a system, the wording of paragraph 6 ties the longer interval to the system being installed, not to an obligation to install it.
Records. Article 7(1) requires operators of equipment which is required to be checked under Article 5(1) to establish and keep records for each piece of such equipment: the quantity and type of gases, the quantities added during installation and during servicing, the quantity recovered, whether the gases added were recycled or reclaimed, the identity of the undertaking that carried out the work and its certificate number, the dates and results of the checks and of any leak repairs, and, on decommissioning, the measures taken to recover and dispose of the gases. Article 7(2) requires the records to be kept for at least five years by both the operator and the undertaking that did the work, unless they are stored in a database set up by the competent authorities.
One practical detail: the record follows the equipment, that is the unit, not the vehicle. If a unit moves from one trailer to another, its file moves with it. The individual fields are set out in equipment records, and the logic of the intervals in leak check frequency.
After a repair. Article 4(5), second subparagraph, requires equipment subject to leak checks to be checked again after a leak has been repaired, by a certified natural person, at the earliest after 24 hours of operating time and no later than one month after the repair. For the mobile equipment listed in Article 5(3), points (a), (b) and (c), the same subparagraph allows that check to be carried out directly after the repair.
Certificates, certified companies and buying the gas
Implementing Regulation (EU) 2024/2215 expressly covers, in Article 1, points (d) and (e), refrigeration units of refrigerated trucks and trailers as well as of refrigerated light-duty vehicles, intermodal containers and train wagons. Article 2(1) lists the activities that require a certificate: leak checks, installation, repair, maintenance or servicing and decommissioning, and recovery — the last one, in point (d), only for the cooling circuits of refrigeration units of refrigerated trucks and trailers.
| Certificate | What it allows under Article 3(2) |
|---|---|
| A1 | All activities in Article 2(1), for fluorinated greenhouse gases and hydrocarbons |
| A2 | The same activities, limited to equipment with a charge size of less than 3 kilograms or, for hermetically sealed systems labelled as such, less than 6 kilograms |
| B | All activities, in relation to carbon dioxide (CO2) |
| C | All activities, in relation to ammonia (NH3) |
| D | Recovery only, for equipment containing less than 3 kilograms or, for labelled hermetically sealed systems, less than 6 kilograms of fluorinated greenhouse gases |
| E | Leak checks only, provided the activity does not entail breaking into the refrigeration circuit |
The company, not just the technician. Article 10(2) of Regulation (EU) 2024/573 requires legal persons carrying out installation, maintenance or servicing, repair or decommissioning of the equipment listed in Article 5(2), points (a) to (e), and Article 5(3), points (a) and (b), to be certified. That includes workshops working on transport units. The conditions are in Article 6 of Regulation (EU) 2024/2215: enough certified staff for the expected volume of work, and proof that the necessary tools and procedures are available.
Narrow exemptions. Article 3(3) of the implementing regulation exempts persons carrying out brazing, soldering or welding of parts, provided they hold the qualification required under national law and are supervised by a certificate holder who is fully responsible for the correct execution. Article 3(4) allows trainees to work under supervision for periods not exceeding 24 months in total.
Recovery in group 2. For units of refrigerated light-duty vehicles, intermodal containers and train wagons, recovery is covered by a training attestation: Article 10(1), second subparagraph, point (b), of Regulation (EU) 2024/573, with the minimum requirements in Article 1(1), point (c), and Article 2(2) of Implementing Regulation (EU) 2025/1893, which provides attestations M1, M2 and M4 for that activity.
Buying the gas. Article 11(6) of Regulation (EU) 2024/573 reserves the purchase of gases listed in Annex I and in Section 1 of Annex II to certified persons or to undertakings employing such persons, for work on the listed equipment, which includes Article 5(3), points (a) and (b). The seller sells exclusively to those undertakings. What has to be shown is set out in who can buy refrigerant gas, and recognition of certificates between Member States, under Article 9 of Regulation (EU) 2024/2215 and Article 10(10) of the basic Regulation, in certificate validity and recognition.
Recovery during servicing and at end of life
Article 8(1) requires operators to ensure that the gases are recovered and, after decommissioning of the equipment, recycled, reclaimed or destroyed. The recovery is carried out by natural persons who hold the relevant certificates provided for in Article 10.
- Article 8(3), point (a): the duty applies to the cooling circuits of refrigeration units of refrigerated trucks and refrigerated trailers. There is no deferral here.
- Article 8(3), point (b): the same circuits, for refrigerated light-duty vehicles, intermodal containers including reefers, and train wagons. Article 8(5) provides that the duty applies to their operators from 12 March 2027.
- Article 8(6): recovered gases listed in Annex I and in Section 1 of Annex II shall not be used for filling or refilling equipment unless the gas has been recycled or reclaimed.
- Article 8(7): an undertaking that uses a container with fluorinated greenhouse gases shall arrange for the recovery of any residual gases immediately prior to its disposal.
Article 4 completes the picture: paragraph 1 prohibits intentional release where it is not technically necessary, paragraph 3 requires all necessary precautions against unintentional release, including during transport and storage, and paragraph 5 requires repair without undue delay. The practical steps are described in the recovery obligation.
Which gases may still go into the unit
The use restrictions sit in Article 13, and for transport refrigeration one distinction in the text does all the work.
The use of fluorinated greenhouse gases with a GWP of 2 500 or more for the maintenance or servicing of refrigeration equipment with a charge size of 40 tonnes of CO2 equivalent or more shall be prohibited. From 1 January 2025, the use of fluorinated greenhouse gases with a GWP of 2 500 or more for the maintenance or servicing of any refrigeration equipment shall be prohibited.
The text says refrigeration equipment, without limiting it to stationary equipment, so transport refrigeration units are caught. The second subparagraph exempts military equipment and equipment intended for applications designed to cool products to temperatures below minus 50 °C. The third subparagraph suspends the prohibition until 1 January 2030 for two categories: reclaimed gases listed in Annex I with a GWP of 2 500 or more used for maintenance or servicing of existing refrigeration equipment, provided the containers are labelled in accordance with Article 12(7); and recycled gases in the same range, provided they were recovered from such equipment and are used by the undertaking that carried out the recovery, or by the undertaking for which it was carried out.
The contrast with paragraph 5. From 1 January 2032, the use of gases listed in Annex I with a GWP of 750 or more for the maintenance or servicing of stationary refrigeration equipment, with the exclusion of chillers, is prohibited. The word stationary matters: paragraph 5 does not reach transport units. That asymmetry is why a transport unit can still be serviced with blends in the 2 000 to 2 500 band after 2032, while an equivalent stationary plant cannot.
What this means for a fleet: R-404A, with a GWP of 3 922 calculated in accordance with Annex VI, is above the 2 500 line and may no longer be used as virgin gas for servicing since 1 January 2025. R-452A, at a GWP of about 2 139, stays below the line. The status of each is set out on the R-404A page and the R-452A page, and the replacement options in replacing R-404A and in the servicing bans.
What the Regulation does not require for transport refrigeration
The list of what is absent is as useful as the list of duties. Each item below is a gap in the text, not an exemption granted.
- No compulsory leakage detection system. Article 6(1) and (2) address operators of the stationary equipment listed in Article 5(2). No transport unit falls there, whatever its charge.
- No Annex IV entry. Annex IV lists placing-on-the-market prohibitions for stationary refrigeration, chillers, stationary air conditioning and heat pumps, foams, aerosols and other products. Transport refrigeration does not appear, so there is no date from which a new unit with a given GWP may not be placed on the market under that Annex.
- No periodic check of the detection system. Article 6(3) and (4), which require the system itself to be checked, again concern stationary equipment.
- Ships: outside the list. Article 5(3) does not list refrigeration equipment on board ships. The recitals of the Regulation state that their operators should take precautionary actions to prevent leakage and repair without undue delay, and Article 35 includes the shipping sector among the matters the Commission examines when reviewing the implementation of the Regulation.
What does remain, for any equipment containing fluorinated greenhouse gases: the whole of Article 4, the recovery duty in Article 8 and the labelling requirements in Article 12. Under Article 12(3) the label must state that the equipment contains fluorinated greenhouse gases, the accepted industry designation of the gas, the quantity expressed in weight and in CO2 equivalent and the GWP of those gases, and the format is set by Implementing Regulation (EU) 2024/2174. The detail is in the equipment label.
Fleet checklist
- Classify every unitPoint (a) for trucks and trailers, point (b) for light-duty vehicles, containers and wagons. The timetables differ.
- Work out the threshold per unitArticle 5(1): 5 tonnes of CO2 equivalent for Annex I, 1 kilogram for Annex II Section 1. Divide 5 000 by the GWP of the blend.
- Set the interval from the correct bandArticle 5(6): 12, 6 or 3 months depending on the contents.
- Check who signs the leak checkArticle 5(3), second subparagraph: a natural person certified under Article 10.
- Confirm the company certificateArticle 10(2) and Article 6 of Regulation (EU) 2024/2215: the legal person must be certified.
- Open a file per unitArticle 7(1): records for each piece of equipment, kept for five years under Article 7(2).
- Plan the verification checkArticle 4(5), second subparagraph: for the mobile equipment of Article 5(3), the check may be carried out directly after the repair.
- Check the GWP before servicingArticle 13(3): 2 500 or more is prohibited since 1 January 2025, subject to the third subparagraph.
- Recover at every opening and at end of lifeArticle 8(1), (3), point (a), and 8(7).
Frequently asked questions
Does the unit on my trailer benefit from the deferral to 2027?
No. Article 5(5) provides that paragraphs 1 and 6 do not apply to operators of the mobile equipment in Article 5(3), points (b) and (c). Refrigerated trailers are in point (a), so the leak check applies to them with no transitional date. The same structure appears in Article 8(5) for recovery.
Do I have to fit a leakage detection system to the unit?
Not under the Regulation. Article 6(1) and (2) address operators of the stationary equipment listed in Article 5(2). Where a unit does have such a system installed, Article 5(6) allows the longer check interval for the relevant band.
Can I still top up a unit with R-404A?
Not with virgin gas. Article 13(3) prohibits, from 1 January 2025, the use of fluorinated greenhouse gases with a GWP of 2 500 or more for the maintenance or servicing of any refrigeration equipment, and R-404A has a GWP of 3 922 calculated in accordance with Annex VI. The third subparagraph allows, until 1 January 2030, reclaimed gas labelled in accordance with Article 12(7) and recycled gas recovered from such equipment, on the conditions set out there.
Does the GWP 750 ban from 2032 reach transport units?
Not as Article 13(5) is drafted: it addresses stationary refrigeration equipment, with the exclusion of chillers. Transport refrigeration units are not stationary within the meaning of Article 3, point (20). The 2 500 prohibition in paragraph 3 continues to apply.
Who may recover the gas from a reefer container?
Article 10(1), second subparagraph, point (b), of Regulation (EU) 2024/573 requires at least a training attestation for that activity, and Implementing Regulation (EU) 2025/1893 provides attestations M1, M2 or M4. For trucks and trailers, by contrast, recovery requires a certificate under Article 2(1), point (d), of Regulation (EU) 2024/2215.
Are records kept per vehicle or per unit?
Article 7(1) requires records for each piece of equipment subject to checks under Article 5(1). The equipment is the refrigeration unit. If the unit moves to another vehicle, the file goes with it, and the identity of the undertakings that intervened stays in the record under point (e).
Official sources
Chapters II and III of the Regulation were read in full in the Official Journal text, together with Annexes I, II, IV and VI and the implementing regulations cited.
How current this page is, and its limits
This page reproduces the F-gas regime for transport refrigeration units. It contains no dangerous-goods transport requirements, no ATP agreement requirements, no national inspection rules and no penalty amounts, and it does not confirm the charge size of any unit model.
General information prepared by EgoLog on the basis of the official texts. It is not legal advice and it does not replace the documentation of the unit manufacturer.
Work on the refrigerant circuit is carried out only by persons and companies holding the certificates required by Article 10 of Regulation (EU) 2024/573 and by Implementing Regulation (EU) 2024/2215. For flammable refrigerants, see safety classes.