Short answer
Regulation (EU) 2024/573 treats a sale of fluorinated greenhouse gases as a transaction with two ends. The buyer must be entitled to buy, and the seller answers for having sold only to someone entitled. The last sentence of Article 11(6), first subparagraph is addressed straight at you: sellers shall sell or offer for sale, directly or indirectly, such gases exclusively to the undertakings referred to in that paragraph.
Four practical duties follow, in the order they show up in a real delivery:
- Check the buyer's certificate before despatch — Article 11(6).
- Record the certificate number and the quantities sold — Article 7(3).
- Label correctly, in the language of the Member State of destination — Article 12(3) and (4).
- Keep the records for at least 5 years and make them available on request — Article 7(3), second subparagraph.
The buyer's side is handled separately in the guide on who can buy refrigerant gas. This page looks only from the side of the party doing the supplying.
No prices, commercial terms, delivery times or model contracts. No national trade-licensing procedures, forms or national registers either, because the Regulation does not set those. This page covers only the duties that follow from Regulation (EU) 2024/573 and its implementing regulations.
Who you are allowed to sell to
Article 11(6), first subparagraph allows the purchase of fluorinated greenhouse gases listed in Annex I or in Section 1 of Annex II, for the purpose of installation, maintenance or servicing, or repair of the equipment referred to in Article 5(2), points (a) to (f), and Article 5(3), points (a) and (b), only by:
- natural persons who hold a certificate required under Article 10(1), first subparagraph, point (a); or
- undertakings that employ such certified natural persons; or
- undertakings that employ persons holding a training attestation required under Article 10(1), second subparagraph, for the equipment covered by that subparagraph.
The certificates are the ones set out in Implementing Regulation (EU) 2024/2215. Its Article 3(2) lists the types: A1 for all the activities in relation to fluorinated greenhouse gases and hydrocarbons, A2 for the same activities limited to equipment with a charge size of less than 3 kilograms (less than 6 kilograms for hermetically sealed systems labelled as such), B for carbon dioxide, C for ammonia, D for recovery only from small equipment, and E for leak checks that do not entail breaking into the circuit.
Article 11(6), second subparagraph: the paragraph does not prevent non-certified undertakings that do not carry out the activities in the first subparagraph from collecting, transporting or delivering fluorinated greenhouse gases listed in Annex I and in Section 1 of Annex II. A courier or a warehouse keeper needs no certificate to move the cylinder. If, however, the party collecting the goods is the same one that will install them, you are no longer inside the exemption.
Watch the scope of the certificate. An A2 certificate does not cover equipment with a large charge, and a B or C certificate covers different fluids. Selling a quantity plainly incompatible with the certificate type presented is exactly the kind of mismatch an inspection notices. The categories are explained in the guide on F-gas certificate categories.
The pre-despatch check, step by step
Identify the undertaking, not the person on the phone
Full name, address, tax identification and the contact person. Article 3, point (27) defines an undertaking as any natural or legal person which carries out an activity referred to in the Regulation.
Ask for a copy of the certificate
The company certificate or the certificate of the employed natural person. Note the number, the type, the issuing body and the validity, as set out in Article 4(2) of Implementing Regulation (EU) 2024/2215.
Match the certificate type against what was ordered
An A2 certificate covers equipment with a charge below 3 kilograms, or below 6 kilograms for hermetically sealed systems labelled as such. Types B and C concern carbon dioxide and ammonia.
Establish the purpose of the purchase
Article 11(6) speaks of installation, maintenance or servicing, or repair. If the buyer states a different purpose — resale, export, destruction — a different regime and different paperwork apply.
Check who collects the goods
The exemption in Article 11(6), second subparagraph covers collection, transport and delivery by non-certified undertakings. Record who collected and on whose behalf.
Enter the delivery in the Article 7(3) records
The certificate number of the purchaser and the quantities of gases purchased. The entry is made per delivery, not once a year.
Check the cylinder label before it leaves
Article 12(3) for the content, Article 12(4) for legibility and for the language of the Member State of destination. A refilled cylinder is relabelled under Article 12(6).
Hand over the safety data sheet
The document required by Regulation (EU) 2020/878 travels with the product; section 14 is the one the carrier needs.
File the delivery pack
The copy of the certificate, the order, the delivery note, the invoice and the Article 7(3) entry. The minimum retention period for the records is 5 years.
Sales records: what, how long, to whom
Article 7(3) is short and very concrete. For the purposes of Article 11(6), undertakings supplying fluorinated greenhouse gases listed in Annex I or in Section 1 of Annex II shall establish records of relevant information on the purchasers, which include:
- point (a) — the certificate number of each purchaser;
- point (b) — the respective quantities of the gases purchased.
The second subparagraph adds the period and the recipient: the undertakings supplying the gases shall keep the records for at least 5 years and shall make them available, upon request, to the competent authority of the Member State concerned or to the Commission.
The Regulation prescribes no format. Article 7(6) allows the Commission to determine, by means of an implementing act, the format of the records referred to in paragraphs 1, 3, 4 and 5 and to specify how they should be established and kept. Until then the form is yours to choose; the content is not.
Article 29 provides for risk-based checks that include on-site visits and verification of relevant documentation, carried out without prior warning unless prior notification is necessary to ensure their effectiveness. A record that has to be assembled from invoices over three days is not a record within the meaning of Article 7(3).
The records your customer keeps for their own equipment are a different set with their own basis — Article 7(1) and (2). They are described in the guide on F-gas equipment records. Neither substitutes for the other.
When you sell equipment rather than bulk gas
The rule changes when the goods are not the cylinder but the charged equipment.
Non-hermetically sealed equipment. Article 11(7): non-hermetically sealed equipment charged with fluorinated greenhouse gases listed in Annex I and in Section 1 of Annex II may only be sold to an end user where evidence is provided that the installation is to be carried out by an undertaking certified in accordance with Article 10. The evidence is not optional and cannot be replaced by a verbal assurance.
Article 7(4) completes the picture: undertakings which sell such equipment shall keep records of the equipment sold and of the certified undertakings that will carry out the installation, for at least 5 years, and shall make those records available, upon request, to the competent authority of the Member State concerned. It is a separate record from the Article 7(3) one, with its own content.
The definition of hermetically sealed equipment is in Article 3, point (9): all parts containing fluorinated greenhouse gas are made tight during manufacture at the manufacturer's premises by welding, brazing or a similar permanent connection, and the joints in the sealed system have a tested leakage rate of less than 3 grams per year under a pressure of at least a quarter of the maximum allowable pressure. If the equipment does not meet that definition, Article 11(7) applies.
Pre-charged equipment. Where equipment has been pre-charged with hydrofluorocarbons listed in Section 1 of Annex I, Article 19(1) requires those substances to be accounted for within the quota system, and Article 19(2) requires the manufacturer or importer of the equipment to document compliance fully and to draw up a declaration of conformity, kept for at least 5 years. The full route is in the guide on importing pre-charged equipment.
The label, the delivery note and the invoice
The label. Article 12(1), point (g) puts all fluorinated greenhouse gas containers under the labelling obligation. Article 12(3) sets the content: an indication that the product contains fluorinated greenhouse gases, the accepted industry designation or the chemical name, the quantity in weight and in CO2 equivalent, and the global warming potential. Article 12(4) requires the label to be clearly legible and indelible and written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied. On a cross-border sale, the relevant language is that of the destination, not of your warehouse.
Implementing Regulation (EU) 2024/2174 sets the format: the information stands out clearly from the background and is readable (Article 1(1)); the label remains securely in place and legible under normal operating conditions (Article 1(2)); and an explicit statement about the fluorinated greenhouse gas content appears on it (Article 1(3)). Article 1(7) prescribes the wording for recycled or reclaimed gas and for the special uses.
For refilled cylinders, Article 12(6) requires relabelling with updated information. For reclaimed or recycled gas, Article 12(7) requires the corresponding indication and, in the case of reclamation, the batch number and the name and address of the reclamation facility in the Union. The distinctions are covered in the guide on reclaimed, recycled and virgin refrigerant.
The Regulation does not prescribe the content of an invoice. What it prescribes is the Article 7(3) record, and the simplest way to support that record is for the paperwork to carry the data already: the trade designation of the gas, the quantity in kilograms, the CO2 equivalent, the cylinder number, the purchaser's certificate number and the stated purpose of the purchase. Then the record and the commercial document say the same thing.
The document set that should accompany a cylinder is described in the guide on documents with a cylinder, and responsibility while it is moving in the one on transporting cylinders.
Reselling inside the Union and the quota system
A question that keeps coming back: if I resell a cylinder of hydrofluorocarbons to a service company, do I use quota?
The answer comes from the definition. Article 3, point (6) defines placing on the market as the customs release for free circulation in the Union, or the supplying or making available to another person within the Union for the first time, for payment or free of charge, or the use of substances produced or of products or equipment manufactured for own use. Article 16(1) attaches the quota to exactly that moment: the placing on the market of hydrofluorocarbons is allowed only to the extent that producers and importers have been allocated quota by the Commission as set out in Article 17.
So the quota is consumed when the gas first enters the Union market — at release for free circulation or at the first supply. A later resale within the Union is not a placing on the market and does not consume quota again. The maximum quantities in Annex VII, point 1 concern the amount of hydrofluorocarbons that may be placed on the Union market in a given year, not the number of subsequent transactions.
That does not put the reseller outside the Regulation. Article 11(8) provides that only undertakings with an establishment within the Union, or that have appointed an only representative with an establishment within the Union assuming full responsibility for compliance, may place on the market and subsequently supply bulk fluorinated greenhouse gases. And the checking, labelling and record duties above apply to every delivery.
Registration in the F-gas Portal is required for activities such as import and export, quota declarations, transfers and authorisations. The Commission's portal page lists the categories of undertaking that have to register. The differences between registration, quota, authorisation and transfer are explained in the guide on portal, quota, authorisation and transfer.
If the goods someone offers you look as though they come from outside the legal circuit, do not resell them: see the guide on counterfeit and illegal refrigerant.
Checklist before every delivery
- A copy of the buyer's certificate is on fileArticle 11(6), first subparagraph. The copy belongs in the delivery pack, not in the salesperson's memory.
- The certificate type covers the goods orderedImplementing Regulation (EU) 2024/2215, Article 3(2): A1, A2, B, C, D and E have different scopes.
- The certificate is valid on the date of deliveryThe dates of issue and validity are part of the information shown on the certificate.
- The purpose of the purchase is one of those in Article 11(6)Installation, maintenance or servicing, or repair. Any other stated purpose changes the regime.
- The certificate number and the quantity are recordedArticle 7(3), points (a) and (b), for every delivery.
- The records are kept at least 5 years and can be produced at onceArticle 7(3), second subparagraph; checks are carried out without prior warning (Article 29).
- The cylinder label is complete, legible and in the destination languageArticle 12(3) and (4), in the format set by Implementing Regulation (EU) 2024/2174.
- The safety data sheet leaves with the goodsIn the format required by Regulation (EU) 2020/878.
- For non-hermetic equipment, you hold evidence of certified installationArticle 11(7), with the separate records required by Article 7(4).
- You know who physically collected the goods and on whose behalfThe exemption in Article 11(6), second subparagraph covers collection, transport and delivery.
Frequently asked questions
Is it enough for the buying company to state that it is certified?
No. Article 11(6), first subparagraph places the duty on the seller: sellers shall sell or offer for sale, directly or indirectly, such gases exclusively to the undertakings referred to in that paragraph. And Article 7(3), point (a) requires you to record the certificate number of each purchaser. A number you have never seen cannot be recorded accurately.
I sell to a wholesaler who resells. What do I check?
If the purchase is not for the purpose of installation, maintenance or servicing, or repair, you are not in the situation of Article 11(6), first subparagraph but in a business-to-business supply. Article 11(8) on establishment in the Union or an only representative still applies, as do the labelling duties of Article 12. Record the stated purpose of the purchase in the delivery pack.
How detailed do the quantity records have to be?
Article 7(3), point (b) requires the respective quantities of the gases purchased. In practice that means per type of gas and per delivery, in a form that allows the picture to be reconstructed. The format may later be set by the Commission in an implementing act under Article 7(6); until then the content is mandatory and the form is not.
Should I refuse an order for a high-GWP gas for servicing?
You do not decide the use, but it is worth knowing the limits that bind your customer. Article 13(3) prohibits, from 1 January 2025, the use of gases with a GWP of 2 500 or more for the maintenance or servicing of any refrigeration equipment, subject to the exceptions it sets out; Article 13(4) extends the prohibition to air-conditioning equipment and heat pumps from 1 January 2026; Article 13(5) lowers the limit to 750 from 1 January 2032 for stationary refrigeration equipment excluding chillers. The full timetable is in the guide on the ban timetable.
Does the courier collecting the cylinders need a certificate?
No, not if it only collects, transports or delivers. Article 11(6), second subparagraph says expressly that the paragraph does not prevent non-certified undertakings that do not carry out the activities in the first subparagraph from doing those things. If the same company installs the system, it is no longer inside the exemption.
What if a buyer presents a certificate from another Member State?
Implementing Regulation (EU) 2024/2215 provides for the mutual recognition of certificates issued in other Member States. You may ask for a translation, but you cannot impose an additional examination. Record the certificate number exactly as it appears on the document.
Do I have to check what the customer does with the gas after delivery?
No. The duties on use, leak checking and equipment records fall on the operator under Articles 5, 6 and 7(1). Yours is the check at the moment of sale and the record under Article 7(3). What sits on the buyer's side is explained in the guide on who can buy refrigerant gas.
Official sources
Articles 3, 7, 10, 11, 12, 13, 16, 19 and 29, and Annex VII, were read directly in the Official Journal text. The certificate types come from the implementing regulation on certification, and the label format from the one on labelling.
How current this page is, and the limits of our liability
This page describes the seller's duties under Regulation (EU) 2024/573 and its implementing regulations. It does not cover national trade-licensing requirements, tax obligations or contractual terms, and it does not replace checking the buyer's actual documents.
General information prepared by EgoLog on the basis of the Regulation and official Commission material. It is not legal advice.
Work on the refrigerant circuit is carried out by competent persons certified under Article 10 of the Regulation and Implementing Regulation (EU) 2024/2215. Confirm the applicable requirements with your national competent authority before taking a commercial decision.